Meeting the New ASTM Standard for Phase I Environmental Site Assessments
In November 2021, ASTM International published the updated Phase I Environmental Site Assessment standard to replace the version used since 2013. After taking effect on February 13, 2023, the new standard satisfies the requirements of the “All Appropriate Inquiries” provision under the Comprehensive Environmental Response, Compensation and Liability Act.
AKRF proactively updated our Phase I ESA practices and has been providing deliverables compliant with both standards since early 2022. With the new ruling now in effect, our clients enjoy a seamless transition to the new standard moving forward. As industry leaders, our goal is to navigate and streamline updates to regulatory criteria and standards and deliver the highest level of technical and regulatory expertise for our clients and partners.
The updated ASTM E1527-21 Phase I ESA standard was developed to comply with current industry practices and to clarify and improve existing language and ultimately strengthen the report deliverable. Key components of the new standard include:
- Updates and clarifications to certain definitions, including those for Recognized Environmental Conditions (RECs), Historic Recognized Environmental Conditions (HRECs), and Controlled Recognized Environmental Conditions (CRECs).
- Clarification regarding the expiration of certain components of the Phase I ESA – specifically, reports are valid 180 days after the earliest date of the relevant sections (e.g., order date of regulatory agency database report, date of site reconnaissance, etc.), and not the date of the final report issuance.
- Expansion of historical research standards, including evaluation of adjoining property.
- Recognition of a new term “Significant Data Gap” (a data gap that could affect the environmental professional’s ability to identify RECs), with guidelines for addressing.
- The addition of “Emerging Contaminants” (e.g., per- and polyfluoroalkyl substances [PFAS]) to the list of non-scope considerations.
The EPA’s ruling recognizing the new standard can be found here.