An essential component of environmental due diligence, the Phase I Environmental Site Assessment (ESA), is guided by the ASTM E1527 standard. In a process taking over three years and involving more than 150 industry professionals, the ASTM E1527 standard underwent its required Octennial (once every 8 years) re-approval, which included revisions improving the standard’s clarity, consistency and usability.
In an article published in July of this year (linked below), we summarized the proposed changes to the ASTM E1527 standard. We are pleased to report that the proposed revisions have been finalized in the new standard, E1527-21, which was formally approved and published by ASTM on November 1, 2021.
The approved ASTM E1527-21 standard has been submitted to the U.S. Environmental Protection Agency to begin the formal process of recognizing E1527-21 as AAI-compliant.
As anticipated, changes were made to the following areas:
Improved definitions of critical terminology
Clarifying the existing terms “Recognized Environmental Condition” (REC), “Controlled Recognized Environmental Condition”(CREC), and “Historical Recognized Environmental Condition” (HREC); and formalizing definitions for “Property Use Limitation” (PUL) and “Significant Data Gap”.
Clarifications to strengthen historical records review
The standard now requires a more thorough review and discussion of standard historical sources for the subject property and adjoining properties.
Providing more details and guidance on:
- The REC/HREC/CREC decision process
- Relevant legal topics
- Proper report preparation
- Business risks associated with emerging environmental contaminants.
As stakeholders who guide our clients through the due diligence process every day, PM Environmental applauds the greatly improved standard and the industry experts whose hard work made it happen.
To view PM Environmental's original article on E1527-21 and changes to the ASTM standard, click here.