Editors' Summary: It has been almost three years since the enactment of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) and the prospects for rapid achievement of the Act's goals are not bright. Implementation of CERCLA has been plagued by lack of information on the scope and incomplete scientific understanding of the mechanisms of hazardous waste pollution. Hasty legislative drafting of an approach to pollution control different from that of the regulatory schemes already in use in federal environmental law created a legal puzzle that cannot be solved easily or quickly. These intrinsic barriers to carrying out the Superfund mandate were magnified by the recently ended political debacle surrounding administration of the program at EPA. Mr. Rogers reviews the status of CERCLA implementation and assesses the prospects for further progress. He argues that while the data base is improving and EPA is restoring confidence in its Superfund office, by continuing to pursue expansive theories of generator liability for hazardous substance cleanup the federal government is ensuring that the Superfund program will be mired in slowmoving litigation for years to come.