Clean Harbors Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Clean Harbors provides only limited insight into how it governs lobbying and policy engagement. The company notes that its Environmental, Health and Safety Committee "was established with the principal purposes of (1) fulfilling the Board’s oversight responsibilities for the Company’s policies and practices related to human health and safety, operational safety and regulatory and environmental compliance" and that the committee will "review the Company’s corporate social responsibility, including sustainability, community relations, and legislative activities." It also states that this body will "review emerging environmental, health and safety issues, as well as proposed laws and regulations, and their potential impact on the Company" and "review the Company’s benchmarking of environmental, health and safety programs of other companies… to ensure that best practices are being implemented." These references demonstrate that a Board-level committee has a mandate to look at legislative activities, implying some oversight of engagement, which indicates a rudimentary governance process. However, we found no evidence of a dedicated procedure to align either direct lobbying or trade-association activity with the company’s climate goals, no disclosure of a formal review or audit of lobbying positions, and no public commitment "to conduct your engagement activities in line with the goals of the Paris Agreement," which the company explicitly confirms: "No, and we do not plan to have one in the next two years." Accordingly, while there is Board oversight of sustainability-related legislative matters, the disclosure lacks detail on monitoring mechanisms, alignment criteria, or accountability specific to climate lobbying. View Sources	D

Overall Assessment

Analysis

Score

Limited

Clean Harbors provides only limited insight into how it governs lobbying and policy engagement. The company notes that its Environmental, Health and Safety Committee "was established with the principal purposes of (1) fulfilling the Board’s oversight responsibilities for the Company’s policies and practices related to human health and safety, operational safety and regulatory and environmental compliance" and that the committee will "review the Company’s corporate social responsibility, including sustainability, community relations, and legislative activities." It also states that this body will "review emerging environmental, health and safety issues, as well as proposed laws and regulations, and their potential impact on the Company" and "review the Company’s benchmarking of environmental, health and safety programs of other companies… to ensure that best practices are being implemented." These references demonstrate that a Board-level committee has a mandate to look at legislative activities, implying some oversight of engagement, which indicates a rudimentary governance process. However, we found no evidence of a dedicated procedure to align either direct lobbying or trade-association activity with the company’s climate goals, no disclosure of a formal review or audit of lobbying positions, and no public commitment "to conduct your engagement activities in line with the goals of the Paris Agreement," which the company explicitly confirms: "No, and we do not plan to have one in the next two years." Accordingly, while there is Board oversight of sustainability-related legislative matters, the disclosure lacks detail on monitoring mechanisms, alignment criteria, or accountability specific to climate lobbying.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Clean Harbors Inc provides only limited insight into its climate-policy lobbying. In its disclosures it notes involvement in the "ongoing development of definitions, scope and acceptable practices" for managing waste streams and the "ongoing development of policies and requirements for re-refining of used oil instead of burning," indicating that it engages with policy formation, but it neither identifies the government bodies it approaches nor explains whether this engagement occurs through meetings, written submissions or industry associations. The company references broad policy areas—how waste must be collected, processed and finalized, and potential mandates that a minimum percentage of re-refined oil be purchased by public organizations—yet it does not cite any bill numbers, regulatory dockets or named legislative initiatives. Likewise, the outcomes it seeks are expressed only in general terms, such as wanting a "requirement for re-refining of used oil to be a minimum percentage of products bought by government or other organizations" and encouraging replacement of used-oil burning with collection and processing, without specifying quantitative targets or detailing the amendments it advocates. Because these disclosures stop short of naming specific policies, lobbying channels or policy targets, and provide only high-level descriptions of desired changes, the company’s lobbying transparency remains limited.	D