On November 6, 2013, the American Society for Testing and Materials (ASTM) issued the revised version of the ASTM E1527 Standard for Phase I Environmental Site Assessments. The newly released standard attempts to clarify interpretations of the previous standard.
On December 30, 2013, EPA published a Final Rule including the reference to the newly released ASTM E1527-13 as part of the "All Appropriate Inquiries Rule" to advise the public that they may use the new standard to comply with the AAI Rule. Instead of replacing the reference to ASTM E1527-05, which was in effect when EPA promulgated the AAI rule in 2005, the EPA added ASTM E1527-13 as an additional acceptable standard. However, in promulgating the Final Rule, EPA also announced its intent to subsequently publish a proposed rule to remove the reference to ASTM E1527-05 in the AAI Rule.
While the Final Rule promulgated by EPA on December 30, 2013, retains the reference to ASTM E1527-05, ASTM expressly stated that the new standard supersedes the prior 2005 standard. Accordingly, any Phase I Environmental Site Assessment conducted after the issuance of ASTM E1527-13 should conform to that standard. ASTM E1527-13 has previously been published and available for purchase on the ASTM website.
The 2013 amendment to ASTM E1527 provides clarification on the definitions of Recognized Environmental Condition and Historical Recognized Environmental Condition. The amendment also includes a new term, Controlled Recognized Environmental Condition, and addresses the potential assessment for Vapor Migration Risk. The amendment further clarifies requirements for the requisite regulatory file review and includes updates to User responsibilities under the standard. The EPA has summarized the updates and changes from the E1527-05 standard in a document in the EPA docket. (See Amendment to Standards and Practices for All Appropriate inquiry.)
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