Journal of Environmental Planning and Management,

46(5), 771780, September 2003

Reinsurer Opinions of Environmental Management

Systems Concerning Insurance for Pollution

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D. M. MINOLI* & J.N.B. BELL

*2 Parklands, Goytre, Monmouthshire NP4 OBE, UK. E-mail: Dino.Minoli@btinternet.com

Imperial College London, Department of Environmental Science and Technology,

Royal School of Mines Building, London SW7 2AZ, UK.
(Received August 2001; revised April 2002 and February 2003)

ABSTRACT Despite an increasing interest in reinsurance and environmental management systems (EMSs) concerning pollution, little research has been conducted on the
subject. This paper presents the findings from a survey of reinsurers views on this issue.
Reinsurers give EMSs a cursory consideration in their pollution risk assessments
because they inadequately appraise pollution liability, have no explicit requirements
regarding risk management and there is little evidence to show that they are effective at
reducing environmental risks. Reinsurers underwriting assessments and post-loss
investigations are poorly developed concerning public liability insurance. Reinsurance
and EMSs are currently weak methods to prevent and control pollution risks.
Introduction
Insurers, reinsurers, industry, academics and the UK government, are intensifying their focus on EMSs and insurance to lessen and control pollution risks
(Gunningham et al., 1999; Minoli, 2001). However, there is little, if any, practical
inquiry on using insurance and EMSs, separately and in conjunction with one
another as instruments in defence of the environment (Minoli, 2001).
To investigate this issue, a case study (involving a desk study and survey) was
conducted on the reinsurance industry, for the following reasons. Reinsurers
underwrite insurers and consequently, poor insurance underwriting can adversely affect reinsurers underwriting performance. Reinsurers, therefore, have
a personal stake in ensuring that pollution risks are properly assessed, rated and
priced. Additionally, reinsurers can potentially influence insurer practices regarding pollution because they can refuse to support insurance policies that
expose them to an unacceptable level of risk. For these reasons, it is important
to evaluate the attitudes of reinsurers on EMSs concerning pollution insurance,
in order to explore further the idea that insurance and EMSs can be used as
instruments in defence of the environment.
Accordingly, the case study had five purposes. First, to review current
reinsurer pollution risk assessment practices. Second, to determine if EMSs are
considered within these practices. Third, to identify any factors affecting reinsurers consideration of EMSs. Fourth, to determine if reinsurers were inclined to
0964-0568 Print/1360-0559 Online/03/050771-10 2003 University of Newcastle upon Tyne
DOI: 10.1080/0964056032000138490

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D. M. Minoli & J. N. B. Bell

support the development in EMSs, and, fifth, to determine the reinsurers

response to the United Nations Environment Programme (UNEP) statement of
environmental commitment by the insurance industry (UNEP, 1996). This statement was launched in 1995 by the insurance industry in conjunction with the
UNEP and, as of July 2002, almost 90 signatories from 27 countries had signed
the statement (UNEP, 2002).
The research presented here comes from a PhD thesis on The response of the
insurance industry towards the developments in environmental management
systems (Minoli, 2001). The primary research of this thesis comes from four case
studies. Case one explores the opinions of the UK insurance industry on the
above subject (Minoli & Bell, 2002a). Case two (presented here) investigates the
opinions of the reinsurance industry on the same topic. Case three examines the
views of key professional practitioners (brokers, surveyors, underwriters, claims
managers, loss adjusters, and a solicitor) on EMSs regarding the assessment of
pollution risks and the handling and settling of pollution claims (Minoli & Bell,
2002b). Case four analyzes two leading UK composite insurers pollution claims
records regarding the prevention and control of pollution risks (Minoli & Bell,
2003).
Insurance and EMSs Concerning Pollution
Insurance for pollution is traditionally provided in a public liability (PL) policy.
These policies were not specifically developed to provide cover for pollution
risks and until the late 1970s they had no restrictions regarding pollution
liabilities. Then following insurance claims emanating from the USA, the Association of British Insurers (ABI) in 1991 recommended to its members that the
pollution wording in a PL policy be changed, so that future PL policies would
only cover sudden and accidental pollution (Loss Prevention Council, 1997) and
exclude cover for gradual pollution, for example that caused by a leaking
underground oil tank (Hay, 1993). However, the major reinsurer, Cologne Re,
believes PL policies still provide cover for gradual pollution. As Wilhelm Zeller,
a member of Cologne Res executive board, said:
The deplorable results of providing coverage for losses arising out of
sudden and accidental pollution under general liability policies in the
United States are well known. Yet most markets either have no
pollution exclusion at all or still offer sudden and accidental pollution
coverage under general liability policies. Perhaps those who support
this practice believe that the problems plaguing US insurers could only
happen under the crazy American legal system. But the belief that this
cannot happen in our market might turn out to be an expensive error:
both the insurance and reinsurance clauses aimed at excluding gradual
pollution actually achieve much less. So we are sitting on pollution
time-bombs. (ENDS, 1995)
Furthermore, as Brian Street, Director of Operations at ECS Underwriting said:
UK insurers have for many years been giving pollution insurance away
as a freebie without any inspection or influence on the insured party to
behave itself. British insurers will have the choice of either continuing
to give away policies, without reinsurance support, or pulling the plug.
Those that do decide to come back into the market, hopefully, will take

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a much more professional attitude and inspect insureds very carefully

and charge increased premiums that reflect the risk more accurately.
(ENDS, 1995)
Consequently, Cologne Re had considered withdrawing their support for PL
policies and replacing them with environmental impairment liability (EIL)
policies (ENDS, 1995). These policies provide insurance for sudden and accidental and gradual pollution based on a technical risk assessment and suitable risk
control. The ABI also agrees that pollution insurance is likely to become a
separate class of business that is supported by the appropriate skills in underwriting and risk control (Department of the Environment, 1994). However, it
feels these changes will not occur in the near term for the following reasons.
First, insurers are reluctant to underwrite pollution because of USA liability
experiences. Second, there are environmental liability uncertainties. Third, firms
have traditionally not perceived the risk to be so significant as to justify the
purchase of EIL insurance (ENDS, 1995). Fourth, cover needs to be removed
from PL policies to encourage the uptake of EIL insurance (ABI, 1996). However,
about 50 million of environmental insurance was written in the London market
in 2001 (ENDS, 2002). Furthermore, the Pensions Act 1994 requires insurers to
say how much social and environmental considerations are considered in their
investments (ENDS, 2000). Therefore, market and legislative developments
should heighten insurer interest in pollution insurance and EMSs.
The development in EMSs began in 1984 when Canadas Chemical Industries
Association created the Responsible Care Programme. This contained the first
set of principles addressing the management of environmental affairs. The first
formally adopted standard for EMSs (British Standard BS 7750) was developed
in 1992 by the British Standards Institution. This was followed in 1993 by the EU
Eco-Management and Audit Scheme (EMAS). In 1996, BS 7750 was superseded
by the International Standards Organisation (ISO) 14001 industrial standard for
the environment. This latter standard was introduced to harmonize the different
and conflicting requirements of EMSs (Swiss Re America, 1998). The above
standards represent voluntary quality standards on the environment. Some
standards, however, are certified (e.g. EMAS and ISO 14001), which means that
they require an independent accredited third party to verify that the companys
EMS meets the requirements of a standard. In contrast others are non-certified
(e.g. Responsible Care) and as such are validated internally. In terms of EMS
uptake, worldwide and company reaction to the standards has varied greatly.
One important reason for this is that there is often an insufficient business case
to encourage companies to certify their EMSs (Swiss Re America, 1998). This
situation is particularly apparent at the small-to-medium sized enterprise level
(Minoli, 1993). In addition, reinsurer reaction to EMSs can be described as
cynical and sceptical. Several reasons help to explain this position. First, there is
no claims history on EMSs and pollution to show how effective or ineffective
such systems are at reducing pollution risks. Second, EMSs offer no guarantee
that pollution will not occur, since companies with such systems are being
prosecuted for environmental offences. Third, environmental management standards do not have any explicit requirements on the use of risk management
techniques as a prerequisite to achieve certification (Swiss Re America, 1998).
Despite this position, companies with more evolved management systems are
incorporating risk management into their EMSs and an increasing number of
companies are adopting EMSs (ENDS, 1998).

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Research Methods
The data presented in this paper come from a desk study review of the literature
and a postal survey questionnaire. The questionnaire included open and closed
questions on the following seven topics:

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(1)
(2)
(3)
(4)
(5)
(6)
(7)

reinsurer practices for assessing clients for pollution risks

reinsurer consideration of EMSs
reinsurer opinions and attitudes toward certified and non-certified EMSs
potential reinsurer benefits of EMSs
potential reinsurer support of EMSs
factors affecting reinsurers consideration of EMSs
reinsurer response to the UNEP sponsored statement of environmental
commitment by the insurance industry.

The questionnaires were piloted on six reinsurance companies and subsequently

forwarded to the top 100 worldwide companies (Anon, 1996). Ten replies were
received, which gave a sample of 16 (inclusive of piloting). The survey data were
then collated and analyzed using Miles & Hubermans (1994) interactive model
of qualitative analysis, which involved data reduction, data display and conclusion verification.
The findings and conclusions should be interpreted in light of its limitations,
namely, that there is a small sample (16 professional practitioners) of multinational reinsurers. Nevertheless, this research does capture some of the views of
the reinsurance world, since a few companies dominate the market and several
of these were included in the survey. In addition, as far as the researcher knows
it is the first of its kind to explore the subject of reinsurance and EMSs
concerning insurance for pollution risks. It thus provides preparatory insight on
an important and under-researched field of enquiry.
Findings of the Research
Reinsurer Practices for Assessing Clients for Pollution Risks
In the UK, reinsurance is generally underwritten on a facultative or treaty basis.
The latter is the most common because the former is expensive and cumbersome (Lawrence, 1991). A common form of treaty reinsurance is the excess of
loss treaty. Here the policy excess is high, i.e. 1 million, and there is an upper
limit of indemnity of about 5 million. Amounts below and above these figures
are met by the insurer (Hansell, 1999).
The way in which reinsurance is underwritten also affects reinsurer practices
for assessing clients for pollution risks. In facultative reinsurance the insurer has
to make a specific inquiry on the pollution risk before it is accepted or declined
(Hansell, 1999). Therefore, facultative reinsurance and insurance are very similar, as both forms of insurance require first-hand knowledge of the individual
risk. In contrast, in treaty reinsurance the insurer makes a legal contract with the
reinsurers, who usually agree to provide reinsurance automatically within the
terms and scope of the treaty. As such, treaty business has no direct contact with
the insured. Consequently, reinsurers are assessing the insurers expertise, policy
wording, experience and attitude to risk. The following reinsurer comments
received in the current work further clarify and explain their approach and
opinions regarding pollution:

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775

Although we analyze environmental risks intensively, we would like to

point out that industrial risks are investigated rather incompletely
within the framework of traditional industrial liability insurance.
As a treaty reinsurer, virtually all our account is written on an excess
of loss basis that is either subject to a total pollution exclusion or a
sudden and accidental restriction. Furthermore, there is insufficient
demand in the UK market for EIL insurance to justify resources.

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When asked to assume pollution liability, we do so on a limited basis.

If the loss exceeds this limit, the insurer keeps the loss. When we
assume this liability, we get environmental studies from the insurer
plus copies of policy forms to understand the risk they assume in the
first place.
We look to the extent that the insurer uses surveys, their quality, scope
and completeness. In addition, we have interviews with insurer personnel, not the original insureds and conduct audits of the insurers
underwriting and claims.
When necessary we call in our environmental technology group.
We issue questionnaires, if the insurer does not have one of its own (a
reinsurer who was a leader in the field of EIL had a 24-page pollution
insurance questionnaire) [Winterthur, 1994]).
Reinsurer Practices for Conducting Technical Risk Assessments
Three out of 10 reinsurers conducted technical pollution risk assessments. For
example, one reinsurer used the following procedure. Step one: risk rating per
class of industry (scale of 1100). Step two: environmental questionnaire for
enhanced or critical risks as identified in the first step. Step three: risk analysis
of the individual customer based on information in the questionnaire, supplemented by information received from an optional site inspection. Another
reinsurer adopted a system called ABCD, which involved an assessment of:
(a) source of emissions (industrial activity, processes, substances and emissions/waste);
(b) site of consequences: neighbourhood (people/property);
(c) carriers of emissions (air, soil, water); and
(d) legal and political framework on environmental liability.
Both procedures, for economic and practical reasons, tend to be used in conjunction with large companies, involved in hazardous trades, under EIL insurance.
These procedures are generally not applied to small-to-medium sized companies, which are involved in less hazardous trades, under PL insurance.
Reinsurer Attitudes on Risk Control
Reinsurers thought the following management practices were important concerning the prevention and control of pollution risk. They are:
(1) management attitude and commitment to risk control and loss prevention;

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D. M. Minoli & J. N. B. Bell

(2) allocation of resources (time, capital and technical expertise) for pollution
risk management;
(3) management practices for preventing potential pollution (e.g. monitoring
and checking programmes, internal risk assessments of company weak
points, and external assessments by competent bodies to avoid internal
blindness); and
(4) management practices for controlling potential pollution (e.g. emergency
response procedures and crisis management plans).

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However, the existence of EMSs is not as important as there being hazardous

materials and substances, which are in close proximity to watercourses and
urban centres. The latter set of factors means that the potential for pollution is
high, despite the existence of EMSs (Minoli & Bell, 2002b).
Reinsurer Opinions and Attitudes on EMSs Concerning Pollution Insurance
Reinsurers only considered certified EMSs, such as the EMAS and ISO 14001, in
their pollution risk assessments if such systems had addressed the issue of
pollution liability. Otherwise, EMSs tend not to be very useful for reinsurers.
Few reinsurers examined the non-certified Chemical Industry Associations
Responsible Care Programme, because chemical risks, following USA liability
experiences, have been excluded from cover. In addition, reinsurers did not
know if they preferred certified or non-certified EMSs, which is not surprising,
since there is little evidence to show that the former are more effective than the
latter in reducing pollution risks.
The Potential Reinsurer Benefits of EMSs?
Despite a lack of evidence on the positive effects of EMSs on pollution risks,
reinsurers apparently thought EMSs might help facultative reinsurers assess
pollution risks and handle pollution claims. However, it is unlikely that EMSs
will replace reinsurer risk assessments for two reasons. First, reinsurers need to
conduct risk assessments to determine if the will to attend to environmental
risks is evident, as opposed to EMSs being used to window dress the company,
and systems also need to be checked and tested. Second, surveys are required
because EMSs, as already mentioned, inadequately address pollution liability.
Nevertheless, reinsurers believed EMSs indicate a positive attitude of management to environmental matters that should help companies assess, control and
reduce their exposure to environmental risks. However, as several reinsurers
pointed out this is all speculation, since there is no hard evidence to date to
show that EMSs are effective regarding pollution risks. Reinsurers used the
following words to explain their position on the matter:
EMSs could help assess the risk, but sudden and accidental exposures
are the main concern and it is doubtful how much an EMS will help
assess these.
The adoption of an EMS indicates a positive attitude of management to
environmental matters, however, it does not assess or measure the risk
and is dependent upon the merits of the case.

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777

The presence of an EMS will never replace our own assessment and this
is partly because there are many loopholes and sticking points.
The effect of an EMS on claims experience is presently not a significant
driver to warrant their consideration as the positive effects of EMS on
loss experience have yet to be established.
EMS could be used as a risk management tool, provided the will is
there and the insured is not just window dressing/being fashionable.
I feel EMSs are only relevant for primary writers i.e. insurance from the
ground up.

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Possible Reinsurer Initiatives in Support of EMSs

Six out of 10 reinsurers thought it is likely that they would educate customers
about EMSs. Three out of 10 reinsurers thought they would add EMSs to
environmental risk assessment criteria. A further two out of 10 reinsurers would
support research and development in EMSs, whereas one reinsurer suggested
making EMSs a condition of cover and offering lower premiums to companies
with EMSs. However, there are a number of problems concerning reinsurer
support of EMSs, as the following reinsurers said:
Using premiums to encourage the uptake of EMS was unlikely to
happen because premium reductions are only useful if liability aspects
are considered; there are also good companies without certified EMS.
The responsibility for these initiatives/incentives probably rests with
direct insurers rather than reinsurers, as reinsurers are too far removed
from the risk to exert a strong enough direct influence.
EMSs indirectly affect reinsurers, so reinsurers should be fully aware of
their impact.
The value of an EMS is limited and presently largely unproven.
The quality of the clients may institute a programme by themselves.
Reinsurers Consideration of the UNEP Sponsored Statement of Environmental Commitment by the Insurance Industry
Two out of 10 reinsurers had signed the UNEP sponsored statement of environmental commitment by the insurance industry. Of those that had not signed it,
only one out of eight reinsurers said it was likely that it would sign the
statement. The remaining seven companies said it was either somewhat unlikely or very unlikely that they would sign the UNEP statement. The following reinsurer comments partly explain the mixed reaction to the statement:
This statement was never a requirement for conducting any business.
We have been working at environmental issues by ourselves and we
are considering whether to sign the statement or not.
Nevertheless, UNEP signatories reported an increase in environmental activity,
both within the firm and amongst its clients.

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Discussion
It was postulated that poor insurer underwriting performance adversely affects
reinsurers underwriting performance. However, high deductibles and indemnity limits confine reinsurers exposure towards the financial consequences of
pollution risks. As such, insurers are buying catastrophe pollution cover. In the
UK market, however, there are not many pollution indemnities and those that
do arise are settled for under 500 000 (Minoli & Bell, 2003). Consequently, it can
be argued that inadequate risk assessment and poor risk control affect insurers
and insureds, rather than reinsurers, since the latter have few pollution indemnifications in the UK market. It was also suggested that reinsurers are in a
potentially important position to affect insurer practices concerning pollution,
since they can refuse to support insurance policies that expose them to an
unacceptable level of risk. Yet, at the time of writing, despite warning from
Cologne Re, reinsurers continue to support pollution cover under a PL policy in
the UK market.
With regard to reinsurer practices concerning pollution the following points
can be made. Some reinsurers conduct technical pollution risk assessments.
However, for practical and economic reasons, these assessments are generally
confined to large companies involved in hazardous trades, when underwriting
pollution under an EIL policy. These assessments are generally not used in
conjunction with small-to-medium sized companies, under a PL policy. This is
an unsatisfactory situation, since all companies have the potential to cause
pollution and a small amount of pollution can cause a disproportionate amount
of damage.
The following points can be made on EMSs concerning reinsurer pollution risk
assessments. EMSs are generally given a cursory examination by reinsurers in
their pollution risk assessments for three reasons. First, and most importantly,
there is no evidence to show that such systems are effective at reducing
pollution risks, or that such systems have any practical relevance for reinsurers.
Second, EMSs inadequately assess pollution liability. Third, these systems have
no explicit requirements regarding the use of risk management. On the other
hand, if the remit of EMSs was broadened to include pollution liability and risk
management, coupled with it being shown that such systems are effective at
reducing pollution risk, then in theory reinsurers should have a heightened
interest in EMSs. This in turn could lead to companies with EMSs receiving
relatively better insurance terms and conditions. Moreover, even if EMSs reduced pollution risks, it is likely that insurers and insureds, rather than reinsurers, would gain the most, because the latter are generally too far removed from
the risk to take advantage of these benefits.
Reinsurers apparently believe that they could provide the following incentives/initiatives in support of EMSs. They are: educating insureds about EMSs,
providing risk management guidelines, adding EMSs to risk assessment criteria,
making EMSs a condition of cover and offering lower premiums to companies
with EMSs. The last two mechanisms, however, are unwise and unsound. This
is because they are somewhat draconian and ineffective since there are, respectively, good companies without EMSs and premiums are not a significant enough
inducement to encourage single-handedly the uptake of EMSs. In addition, for
such support to transpire, it needs to be shown that EMSs are effective at
reducing pollution risks, since it makes no commercial sense for reinsurers to

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779

support something of unknown value. Furthermore, insurers rather than reinsurers are in a relatively better position to initiate such support of EMSs (should
it transpire) because the former come into direct contact with insureds. Nevertheless, reinsurers could encourage insurers to improve their practices regarding
risk assessment and risk control, if they were to offer their support on the
condition that these matters were considered. However, these changes are
unlikely to happen in the near term, since reinsurers continue to offer their
support of pollution cover under a PL policy and the ABI believes that their
policy wording is robust.
Reinsurers, with the exception of those that have specialist pollution underwriting departments, also have a poor understanding of their potential exposure
toward the financial consequences of pollution risks, for two reasons. First,
pollution risks under a PL policy in the UK market are inadequately assessed,
rated and priced. Second, reinsurers have insufficient claims histories to calculate and set pollution premiums. Therefore, reinsurers do not really know if they
are charging the correct premium or setting aside enough money to meet future
claims. These practices regarding pollution could have serious financial implications for reinsurers. It is thus recommended that more reinsurers (and insurers)
sign the UNEP sponsored statement of environmental commitment by the
insurance industry, since it encourages companies to consider the environment
within their daily working practice.
Consequently, the conclusion is that there is little evidence to suggest that
reinsurance and EMSs separately and in conjunction are currently sufficiently
developed to act as instruments in defence of the environment.
Acknowledgements
The authors would like to express sincere appreciation to the Economic and
Social Research Council and the Loss Prevention Council (now part of the
Building Research Establishment) for the provision of the CASE PhD Studentship which supported D.M.Ms research, Dr Charles Kirk for acting as an
industrial supervisor and the case study participants for answering the survey
questionnaire.
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