(July 2013; 38 pages) David J. Freeman and Harry H. Clayton IV, of Gibbons P.C., and Earl L. Hagstrom, of Sedgwick LLP, discuss whether and how the scope of "arranger" liability and apportionment have been altered, four years after the Burlington Northern & Santa Fe Railway Co. v. United States decision. In addition, two Bloomberg BNA reporters provide additional perspective on decisions interpreting Burlington Northern and its impact on liability and apportionment under CERCLA.