ASTM E1527-13 A Done Deal!
Just in time for the New Year, ASTM E1527-13 has been officially approved by the Environmental Protection Agency (EPA). The updated standard practice for the Phase I Environmental Site Assessment process will be effective from today, Monday December 30.
The EPA previously announced ASTM E1527-13’s compliance with all industry regulations, but the new standard was not officially recognized as meeting All Appropriate Inquiry (AAI) requirements until today’s final ruling. The ASTM E1527-13 standard that was adopted today is unchanged from the document published in November, but now includes a preliminary statement that addresses public comments, and emphasizes EPA’s position on implementing the new standard.
Although the previous version of the standard (ASTM E1527-05) will technically continue to meet AAI, ASTM E1527-13 replaces its predecessor as the industry best practice for Phase I ESAs, and the EPA advises parties seeking to claim protection from liability under CERCLA to follow the updated ASTM E1527-13 format.
The new standard introduced a number of key changes including revised definitions for Recognized Environmental Conditions (RECs) and Historic Recognized Environmental Conditions (HREC), a new definition (Controlled Recognized Environmental Condition) as well as stronger recommendations for conducting file reviews and assessing vapor migration risk.
As a member of the ASTM committee tasked with updating the standard and having been involved in the committee’s revision process, I believe the updates in ASTM E1527-13 clarify existing language, strengthen the deliverable and reflect good commercial and customary practice, and will thereby improve the quality of Phase I ESAs across the board. If you want to read about the changes in more detail, and understand how the updated ASTM E1527-13 standard may affect the industry take a look here.
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