ASTM E1528-14, the revised Standard Practice for Limited Environmental Due Diligence: Transaction Screen Process, was approved and became effective this week.
A number of editorial changes were agreed to by the ASTM editors and the updated E1528 document is now available on the ASTM website. The key changes from the previous E1528-06 version of the standard include:
- Beefed up language that a Transaction Screen Assessment (TSA) is not an Environmental Site Assessment (ESA). The standard states that a TSA is “not sufficient to identify Recognized Environmental Conditions (RECs) as defined in 3.2.74 of Practice E1527 and 3.2.80 of Practice E2247″. Specific language has been added to the ASTM E1528-14 standard to discourage the use of a TSA as a so-called “light Phase I ESA” report.
- Added clarification that a TSA does not need to be performed by an Environmental Professional.
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- Confirmation that aerials can be used as one of three historical sources (fire insurance maps and city directories being the other two sources).
- Discussion of the relevance of purchase price to potential environmental concerns was removed from ASTM E1528-14.
A Transaction Screen Assessment is a cost-effective environmental due diligence report to evaluate the environmental liability of a site. But, unlike the Phase I ESA, a TSA does not meet the requirements of the EPA’s All Appropriate Inquiries and, therefore, doesn’t offer exemption from CERCLA liability!
Transaction Screen Assessments are often used by lenders, brokers, and investors as part of a tiered approach to environmental risk management, along with other reports such as an Environmental Desktop Review or a more comprehensive Phase I ESA conducted to appropriate ASTM standards.