Reviewing the ASTM Phase I ESA Standard

ASTM LogoThe American Society for Testing and Materials (ASTM) is a standards organization headquartered right outside of Philadelphia in Conshohocken, PA. ASTM publishes technical standards for a range of products, materials, and services. REPSG conducts our famous Phase I Environmental Site Assessments (ESAs) in accordance with the ASTM Phase I Standard entitled “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process.” This standard is commonly referenced as E 1527.

ASTM E 1527 was last revised in 2005, when the United State Environmental Protection Agency (USEPA) released the ‘All Appropriate Inquiries Rule’. According to the ASTM by laws, standards must be updated at least every eight years, and beginning last fall, an ASTM Task Group has been meeting to once again review the text of E 1527. Revisions to the standard have been proposed that would strengthen and clarify the requirements of E 1527.

Some of the key proposed updates to E 1527 were highlighted by Environmental Data Resources (EDR). Three of the proposed revisions include:

  • Introduction of the term “Controlled Recognized Environmental Condition.” Past soil and/or groundwater contamination which had been remediated would be classified as a CREC. This designation will be addition to recognized environmental conditions (RECs) and historical recognized environmental conditions (hRECs).
  • Expanded discussion on how vapor encroachment should be addressed in a Phase I ESA. In the new E 1527 draft, a vapor plume is proposed to be treated as any other source of contamination. (ASTM published a vapor encroachment standard in 2010 entitled “Standard Guide for Vapor Encroachment on Property Involved in Real Estate Transactions” E 2600-10. Stay tuned for upcoming blog posts about vapor!)
  • Clarification about when regulatory file reviews need to be completed during the course of a Phase I ESA.

The ASTM Task Group is anticipated to publish the updated E 1527 in 2013, but the standard will have to be approved by the USEPA.

As E 1527 evolves, REPSG will continue to provide the most current, highest quality reporting to its clients. If you have any questions about what these updates will mean for you and your property, drop us a line! Each of us on the Phase I team have copies of E 1527 and E 2600 within arms’ reach (and no, I’m not kidding!)

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About Laura Eosso

“When your work speaks for itself, don't interrupt.” Henry J. Kaiser
Laura has a M.S. in Environmental Science from Drexel University and a B.S. in Biology with minor in Chemistry from Gordon College, where she spent a semester abroad in Lithuania. Since joining REPSG in 2007, Laura has been hoping that we would open an Eastern European Branch. When she’s not subtly dropping hints about satellite offices, Laura manages Phase I Environmental Site Assessments, Compliance Audits, HUD Form 4128 and State Historic Preservation Office (SHPO) submittals, and historic records searches in Pennsylvania, New Jersey, Delaware, Maryland, Massachusetts, Connecticut, and Virginia.