Editors' Summary: Estimates of hazardous waste cleanup costs now reach $500 billion nationwide, or $2,000 for every man, woman, and child in the United States. And historically, estimates of cleanup costs have nearly always gone up. As the magnitude of the problem has become clearer, governments and private plaintiffs have searched for more deep pockets to pay for cleanups. CERCLA's liberal liability scheme has been a fertile ground for litigation seeking to expand the net of liability: banks, insurance companies, real estate developers, and corporate holding companies now regularly evaluate their environmental liability exposure.

So too should corporate officers. This Comment analyzes recent cases dealing with the issue of when individual corporate officers, rather than the corporate entity itself, can be held personally liable under CERCLA. There are still conflicts among the cases, but several distinct lines of cases are emerging. This Comment traces the lines of cases and concludes that urging good environmental practices may be the wisest legal advice a lawyer can provide.