The Phase I Environmental Site Assessment (ESA) standard- ASTM 1527-13 is currently going through committee review. It is anticipated that the updated standard (ASTM 1527-21) will be ready for approval in December 2021. The list below highlights a few of the areas that are proposed for changes:
- Clarification of the recognized environmental condition (REC) definition. The proposed changes are to provide additional clarification and improve consistency.
- Clarification regarding the User’s responsibility to conduct a search for Activity and Use Limitations for the Property.
- Clarification of the shelf-life of a Phase I ESA report (180 days) There is a common misunderstanding that the date of the report is the date that you use to determine the age of the report. however, the dates that have to be utilized to determine the viability of the document include the date of the site reconnaissance and the date of the database report.
- Discussion of emerging contaminants. Phase I ESAs evaluate RECs based on hazardous substances as defined under CERCLA. As new research is completed, additional compounds can be defined as hazardous and require evaluation in a Phase I ESA. A recent example of this is PFAs, which are not yet designated as hazardous substances under CERCLA, but it is expected they will soon be added.
It should be noted that the majority of changes proposed for the standard are related to definitions and providing clarification to allow the standard to be more easily utilized and understood. The exact changes to be made to the standard have not been released and may be further modified.
For additional information please contact:
Susan E. Yarger, CP, VAP CP
Phone (419) 214-5060