Originally published in the Environment Reporter, 43 ER 3080, 11/30/2012.

Phase II Site Assessments -

This article reviews the background of the revised Phase II Environmental Site Assessment Standard issued in July 2011 by ASTM International. The author, who chaired the task group responsible for the revisions, reviews the background of the standard and the reasons for the revisions, outlines significant changes in the new standard, and describes the revised assessment process.

The idea of a ‘‘phase I site assessment’’ means roughly the same thing to property owners and buyers, lenders, insurers, environmental engineers, and regulators. A federal rule and ASTM standard issued in 2005 have cemented this understanding to a degree that these diverse constituencies can meaningfully be said to have a common understanding of what a ‘‘phase I’’ is and is not.

The same historically has not been true of ‘‘phase II’’ assessments. Beyond the general idea that a ‘‘phase II’’ involves sampling and testing of environmental media, investigative activity under the phase II label has been highly diverse. The scope of investigation has been a particularly problematic species of diversity: where Phase I assessment has long involved looking at all conditions presenting the potential for a release to have occurred, phase II assessment often is focused on addressing a single issue or group of issues, such as whether an underground tank leaked. The archetype of the resulting challenge is the property owner who presents a lender with a phase II report claiming ‘‘the property is clean’’ when in fact the investigation addressed only limited issues and resulted in findings that cannot be extrapolated to the property as a whole.