ASTM International, known until 2001 as the American Society for Testing and Materials (ASTM), is an international standards organization responsible for developing and publishing voluntary consensus technical standards for a wide range of materials, products, systems and services.

In 1993, the first ASTM E1527 Standard for Phase I Environmental Site Assessments (ESAs) was published and became widely recognized as “Good Commercial and Customary Practice” for conducting Phase I ESAs.  This standard has since been revised three times; in 1997, 2000 and 2005 (1527-05).  On November 6, 2013, ASTM published another revised ASTM standard (1527-13) and therefore ASTM E 1527-05 is no longer
valid.  However, this newly revised standard has not yet been recognized by the Environmental Protection Agency (EPA) under its All Appropriate Inquires (AAI) Rule.  As such, this puts the consumer in a bind.  While the EPA has proposed to recognize E1527-13 as “satisfying AAI,” the agency has not issued its final ruling and does not expect to until the end of 2013 or the beginning of 2014 at the earliest.  The quandary the consumer now faces is that by ASTM publishing its new standard, it is now considered an industry best practice, however the EPA states E1527-05 is the only method by which to qualify for “innocent landowner, contiguous property owner, or bona fide prospective purchaser” limitations under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Many are left to ask “what to do now?”

As a company, EI wants to ensure that we protect our clients and provide the protections under CERCLA.  EI will continue to use ASTM E1527-05 until the EPA issues its ruling concerning 1527-13 as AAI.  In the meantime, we will recognize the three big ticket items in E1527-13 in its E1527-05 Phase I ESAs – regulatory agency file reviews, vapor migration and the new term “controlled recognized environmental condition”).

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