One Step Closer to ASTM E1527-13
Today, the EPA announced its approval of the proposed changes for ASTM E1527-13. With that, we’re now only one step away from the implementation of the updated industry standard.
As we discussed in a recent blog, the American Society for Testing Materials (ASTM) has been in the process of updating the industry’s Standard Practice for Phase I Environmental Site Assessments to reflect recent changes in the due diligence world.
Until today, the updated standard was awaiting review and approval by the US Environmental Protection Agency (EPA). The EPA has just announced that the 2013 version of ASTM E1527 is compliant with the All Appropriate Inquiries regulation. In other words, they have concluded that it meets all requirements and can be used as the industry’s Standard Practice for environmental due diligence.
Unless the EPA receives adverse comments by September 16 – which is unlikely, but possible! - , the revised standard will become effective as of November 2013. All Phase I ESAs will have to be conducted in accordance with the new standard one year from this date.
Some of the key changes of ASTM E1527-13 include:
• More explicit definitions of the various Environmental Conditions (REC and HREC), and the addition of a new category: the Controlled Recognized Environmental Condition (CREC), which applies to sites where the contamination incident has received a risk-based closure, but could still pose ongoing or future obligations for the owner, such as special precautions during development or maintenance of an engineered control such as a vapor barrier. These definition adjustments will allow environmental professionals to provide greater clarity in disclosing the degree of risk.
• A greater emphasis on assessing Vapor Migration Risk, and a stronger imperative for conducting regulatory file reviews. These extra requirements should improve the quality of Phase I ESAs across the board, especially for those consultants who were not already meeting these criteria. These changes will also further help clients to understand and minimize exposure to environmental risks.
For a more detailed discussion about the changes, and how they will impact pricing and report timing, see my colleague Jenny Redlin’s blog.
Be sure to check out Partner Engineerings webinarDevelopment is Back! Mitigate Risk with Due Diligence for an in-depth look at the key engineering, environmental and energy due diligence items that can identify potential "fatal flaws" to a development or redevelopment project and help to prevent them. Click here to download.
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