Late 2013 promises to be a period of education and adjustment following the release of a revised protocol for Phase I environmental site assessments. ASTM submitted the final version to the U.S. Environmental Protection Agency for formal approval of the revised ASTM E 1527 standard as “AAI-compliant.” According to industry insiders, ASTM is expecting to publish the standard (as E 1527-13) in late summer/early fall. These standards typically take effect at the time of release, so implementation could be as little as five months away. Now is the time to start thinking about what you can be doing to prepare.
Learning Curve on E 1527-13
Awareness about the revisions to E 1527 is far from widespread. Consider the results from EDR Insight’s recent quarterly surveys:
- Three out of five risk managers at financial institutions are not aware that a new version of the ASTM E 1527 standard is being released this year. (Of those who are aware, most cannot name the key areas of change.)
- One out of three environmental professionals are not following the ASTM revision process at all and “are not familiar with what’s being revised.”
In light of these results, there is a fair amount of education that still needs to take place in both sectors.
E 1527-13: The 5th Phase I ESA Standard
Industry veterans have lived many periods of adjustment as producers and users respond to a new version of E 1527. The 2013 version will be the sixth iteration since the standard’s birth back in 1993. The last time E 1527 was updated was back in 2005, on the heels of the first federal “All Appropriate Inquiries” rule. The ASTM standard incorporated changes to bring the practice in line with the federal requirements for CERCLA liability protection under three possible avenues (i.e., innocent purchaser, bona fide prospective purchaser or contiguous property owner). The 2005 revision brought to the surface a new emphasis on the qualifications of environmental professionals, activity and use limitations (i.e., engineering and institutional controls), continuing obligations, user responsibilities, local and tribal government records, data gaps and report shelf life.
Continue reading the rest of this brief which outlines how to prepare your firm and your clients for the upcoming changes and includes a large list of resources detailing everything you need to know about E 1527-13 now.