ASTM Update: Revised E1527 Standard Anticipated for 2020

The ASTM E50 Committee on Environmental Assessments met in Denver in early April to discuss revisions to various property due diligence standards and the creation of new guide.  

Updates to the E1527 standard are expected to go to a first ballot this fall, with the plan that a new standard will be published in 2020.  Working groups have formed around topics like historical research, government records, lien searches and AULs, site visits, definitions and more. Some updates to the standard for the October ballot include:  

  • Clarifications to the HREC and CREC definitions.  The task group is working to refine the definitions for HRECs and CRECs and relationships between the various types of recognized environmental conditions.  
  • Expansion of Historical Research to adjoining properties.  The current version of the standard requires historical research of the subject property only, but the task group plans to ballot changes that would also require the investigation of adjoining properties and the surrounding area.   
  • A footnote and edits to the Non-Scope Considerations appendix to acknowledge growing regulator attention to emerging contaminants, especially PFAS. Chemicals will not be expressly named in the standard, but language will be included to alert Phase I ESA providers that releases of chemicals that are not classified as “hazardous substances” for compliance with federal regulation may be considered “in scope” for compliance with state regulations or contractual obligations. 

The E1528 Transaction Screen standard is also set to undergo revisions. The task group is in early stages of determining the direction to take the changes and is seeking participation and feedback from wide range of users. In their research, the task group found that the standard is currently being utilized by many lending institutions, but usually with the assistance of an environmental consultant. The task group is considering revisions to the standard and accompanying questionnaire to improve usability by both professionals and non-professionals.  

The E2790 Standard on Continuing Obligations recently completed a successful ballot. The Continuing Obligations guide is intended to help property owners maintain CERCLA liability protection over the life of a property once a REC has been found. The task group is waiting to publish the updated standard as EPA revises its Common Elements guidance and anticipates a new E2790 standard to be available in late 2019.  

 A new standard on building energy performance is expected to be balloted in October. This standard will help professionals benchmark commercial properties against others in their area and identify improvements that could be made to increase energy efficiency. The standard will work in conjunction with existing practices including Property Condition Assessments and Fannie Mae and Freddie Mac requirements.   

 All who are interested in learning more about these revisions or getting involved in the process are encouraged to join ASTM. The next E50 Committee Week meetings will take place in Houston, October 21-24, 2019.