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Controlled Recognized Environmental Condition (CREC)

Controlled Recognized Environmental Condition (CREC) is a new term introduced in the ASTM E1527 standard for Phase I Environmental Site Assessments (ESAs). The Controlled REC concept was introduced to address contaminated sites that have received risk-based regulatory closure, where no further remediation is required but residual contamination still exists at a site and the property is subject to some sort of control or use restriction. These sites, where contamination is controlled but could still pose ongoing or future obligations on the owner (such as special precautions during construction or grading activities), have been a source of some confusion to the environmental due diligence industry with regards to how they should be classified.

The CREC, as subset of the Recognized Environmental Condition (REC) category and a distinct category from Historical Recognized Environmental Condition (HREC), is intended to clarify the level of risk these sites represent. The environmental professional is required to list any CRECs (as well as RECs) identified in the findings and conclusions section of the Phase I Environmental Site Assessment report.

The ASTM definition of CREC in the E1527-13 standard is as follows: “a recognized environmental condition resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority (for example, as evidenced by the issuance of a no further action letter or equivalent, or meeting risk-based criteria established by regulatory authority), with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls).”

Environmental Due Diligence Terminology