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CLEAN HARBORS, INC.
1501 WASHINGTON STREET
BRAINTREE, MASSACHUSETTS 02185
TEL. 781-849-1800
August 31, 2005
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Registration Statement on Form S-4
File No. 333-126193
Ladies and Gentlemen:
Clean Harbors, Inc. (the "Company") and certain of the Company's
subsidiaries (the "Guarantors") have filed the registration statement described
above in connection with a proposed exchange offer (the "Exchange Offer")
pursuant to which the Company and the Guarantors will offer to exchange up to
$150.0 million principal amount of the Company's 11 1/4% Senior Secured Notes
due 2012 and related guarantees by the Guarantors (collectively, the "Exchange
Securities") registered under such registration statement in exchange for a like
principal amount of the Company's outstanding 11 1/4% Senior Secured Notes due
2012 and related guarantees (collectively, the "Initial Securities"). The
Company and the Guarantors are registering the Exchange Securities for purposes
of the Exchange Offer in reliance on the position taken by the Commission's
staff in EXXON CAPITAL HOLDINGS CORPORATION (available April 13, 1989), MORGAN
STANLEY & CO. INCORPORATED (available June 5, 1991), SHERMAN AND STERLING
(available July 2, 1993), and similar letters.
In connection with the Exchange Offer, the Company, on its own behalf and
on behalf of the Guarantors, represents as follows:
1. The Company and the Guarantors have not entered into any arrangement
or understanding with any person to distribute the Exchange Securities to be
received in the Exchange Offer and, to the Company's and the Guarantors' best
information and belief, each person participating in the Exchange Offer will be
acquiring the Exchange Securities in its ordinary course of business and has no
arrangement or understanding with any person to participate in the distribution
of the securities to be received in the Exchange Offer.
2. The Company will make each person participating in the Exchange Offer
aware (through the Exchange Offer prospectus and the transmittal letter provided
to each current holder of the Initial Securities) (i) that if the Exchange Offer
is being registered for the purpose of secondary resales, any securityholder
using the Exchange Offer to participate in a distribution of the Exchange
Securities to be acquired in the registered Exchange Offer (1) may not rely on
the staff position enunciated in EXXON CAPITAL HOLDINGS CORPORATION (available
April 13, 1989) or similar letters and (2) must comply with the registration and
prospectus delivery requirements of the Securities Act of 1933 in connection
with a secondary resale transaction, and (ii) that any broker-dealer who holds
Initial Securities
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Securities and Exchange Commission
August 31, 2005
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acquired for its account as a result of market-making or other trading
activities, and who receives Exchange Securities in exchange for such Initial
Securities pursuant to the Exchange Offer, may be a statutory underwriter and
must deliver a prospectus meeting the requirements of the Securities Act as
described in (1) above in connection with any resale of such Exchange
Securities. The Company and the Guarantors acknowledge that such a secondary
resale transaction should be covered by an effective registration statement
containing the selling securityholder information required by Item 507 of
Regulation S-K.
3. The Company will include in the transmittal letter to be executed by
the exchange offeree in order to participate in the Exchange Offer
representations to the effect that (i) by accepting the Exchange Offer, the
exchange offeree represents to the Company that it is not engaged in, and does
not intend to engage in, a distribution of the Exchange Securities, and (ii) if
the exchange offeree is a broker-dealer holding Initial Securities acquired for
its own account as a result of market-making activities or other trading
activities, such exchange offeree acknowledges that it will deliver a prospectus
meeting the requirements of the Securities Act in connection with any resale of
Exchange Securities received in respect of such Initial Securities pursuant to
the Exchange Offer, provided, however, that by so acknowledging and by
delivering a prospectus, an exchange offeree which is a broker-dealer will not
be deemed to admit that it is an "underwriter" within the meaning of the
Securities Act.
Very truly yours,
Clean Harbors, Inc.
By: /s/ Carl d. Paschetag
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Carl d. Paschetag,
Vice President and Treasurer