Loss Contingencies - Environmental

The company I work for has a site that manufactures chemicals in Latin America. To my knowledge there has never been a major spill, major accident, or regulatory violation. Currently the site does not have an accrual for loss contingency (environmental / remediation). Based on the fact that this site is manufacturing and mixing chemicals I believe that there is an inherent risk of ground contamination due to small spills, slow drips, and the day to day operations. However, I am having a hard time justifying a loss contingency under the FAS5 requirements of 1.) a liability has been incurred and 2.) the amount of loss can be reasonably estimated. I have no idea how to determine when this liability has been incurred or what would even be a reasonable estimate. The only thing I can think of would be for the company to hire a consultant to perform testing of the site and then provide an estimate if necessary. However, I don't foresee management wanting to open a can worms if they don't have too. If anyone has any experience in this industry and or topic I would greatly appreciate any feedback on how you and or your company managed this issue.