On November 6th, 2013, ASTM published the long anticipated new standard for conducting Phase I Environmental Site Assessments, ASTM E1527-13. ASTM E1527-13 will take effect immediately and will replace the E1527-05 standard as the industry best practice for Phase I ESAs.
Partner is Ready
Partner is an active member of the ASTM committee tasked with updating the E1527 standard. We have been involved throughout the committee’s revision process and are fully prepared to implement the new standard.
What You Should Know About the Changes
The changes from the 2005 to 2013 ASTM standards do not significantly alter the Phase I ESA report or process, but there are a few key changes you should be aware of.
You may also want to ensure that your policy and contract documents reference the “most current” ASTM E1527 standard or update them to specifically reference the E1527-13 standard to ensure that you are receiving the most current standard and best quality report.
The most significant changes include:
The E1527-13 standard imposes a stronger imperative for conducting regulatory file reviews. The environmental professional reserves the right to forego such a review, but must explicitly explain in the report why a review is not warranted.
E1527-13 places greater emphasis on assessing impacts to the subject property from vapor migration. This is done through several changes in the standard: 1) clarifying that the definition of a release does include contamination in the soil vapor phase, not just in soil or groundwater; 2) adding a definition of “migration” that includes vapor (as well as soil and groundwater); and 3) clarifying that vapor migration/intrusion does not fall under the category of an Indoor Air Quality concern (which is out of the ASTM 1527 scope of work).
Several definitions have been clarified and simplified, and a new definition has been added of a “Controlled Recognized Environmental Condition” or “CREC.” You will now see CREC as an additional section being discussed in the executive findings and conclusions.
The simplest explanation of the difference between a Historical Recognized Environmental Condition or “HREC” and “CREC” is as follows:
- HREC = A closed release that has been cleaned up to unrestricted use criteria (i.e. you could put a residence on the property)
- CREC = A closed release that has been cleaned up but not to unrestricted use criteria, such as to “commercial/industrial standards” (i.e. you could not put a residence on the property)
Click to view key new definitions:
Articles and Blogs on E1527-13
The Changing Landscape of Phase I ESAs
By Kathryn Peacock
Published in the RMA Journal
2013 Changes to the Phase I Environmental Site Assessment
By Joseph Derhake, PE
Published by California Mortgage Brokers Association
Update on the New Phase I Environmental Standard ASTM E1527-13
By Jenny Redlin, REPA
Published on GlobeSt.com