Changes are coming to the ASTM E1527 Phase I ESA standard, and environmental professionals (EPs) are preparing to transition to the updated standard practice when it is published later this year. In this article, we take a look back at the history of the ASTM E1527 standard, a look ahead to what EPs may see in the -21 version, and how to prepare.
The ASTM E1527 Task Group updates the Phase I ESA standard at least every eight years. This round of revisions primarily focuses on adding clarifications and updating terminology throughout the standard, in contrast to the more substantive changes driven by regulatory changes in previous versions. However, understanding the nuances of these revisions will be critical for professionals to ready their report templates, processes, and practices when the new version takes effect.
An overview of the ASTM E1527 standard
It’s important for EPs and their staff to stay on top of the forthcoming updates and prepare to make the necessary changes while also keeping clients educated about the updated guidance, definitions and terminology. The proposed revisions are expected to clarify a number of definitions.
The proposed revisions are expected to add clarity to the E 1527 in a number of areas, including:
- New guidance for EPs in making determinations about Recognized Environmental Conditions (RECs), Historical Recognized Environmental Conditions (HRECs), and Controlled Recognized Environmental Conditions (CRECs) that could help improve consistency in reporting findings, opinions, and conclusions. CREC will be clarified to establish how current onsite conditions are allowed to exceed current regulatory unrestricted use criteria.
- The Physical Setting section may be revised to emphasize consideration of Subject Property-specific information during agency file reviews.
- The Site/Property definition has been revised to Subject Property for consistency in referring to the property that is the focus of the assessment.
- The language on Land Title Records for Activity and Use Limitations (AULs) and Environmental Liens may be clarified to include more guidance on responsibilities, sources, and search requirements.
How to prepare for change
Consulting firms must keep their due diligence staff updated on potential changes and provide guidance on how the changes might impact how they conduct Phase I’s and write reports. In addition to internal education, environmental consulting firms will play an important role in educating their clients on how these changes might impact their businesses.
EPs should develop a proactive strategy for monitoring Task Group revisions and re-familiarize themselves with the current standard. They should also review client scopes of work to determine which ones may be impacted by proposed changes and whether immediate updating might be required.
There will also be some key questions your organization must address. Does our report template need to change? Do we need to revisit protocols for conducting historical research? Does it impact who does site visits? Do we need to set new requirements for report review?
Keeping some of these basic steps top of mind will help ensure your company is best prepared to manage ASTM E1527 when it comes out later this year.
For more resources on ASTM E1527, check out our resource center here.