A New Phase in Phase I ESAs

After almost eight years with the current guidelines, ASTM International (formerly the American Society for Testing & Materials [ASTM]) stands poised to revise its standards for conducting Phase I Environmental Site Assessments (ESAs) in 2021. Changes to the Phase I ESA guidance document are not expected to be sweeping, with many of them involving clarification of various definitions. Revisions are also proposed to specify the historical records review required to be performed, as this is an area where one often finds dramatic differences in the level of diligence conducted by industry consultants. Additionally, ASTM reportedly intends to “modernize” interview requirements of the Phase I ESA process.

Several modifications to the reporting requirements are planned for the new standard. Further emphasis is to be placed on the consultant providing rationale for developing its findings and opinions. For instance, what is the environmental professional’s justification for determining whether an issue represents a “historical” or a “controlled” recognized environmental condition (HREC or CREC)? It is also expected that “significant” data gaps, those impacting the consultant’s ability to evaluate potential concerns, will now be required to be discussed in the Phase I ESA’s Conclusions section which was previously reserved exclusively for a listing of recognized environmental conditions. Additionally, it is anticipated that a photographic log and site diagram will now be required elements of the report after the new standard is finalized.

According to Ms. Julie Kilgore, chairperson of ASTM’s environmental subcommittee, consultants that are currently producing “quality deliverables” are expected to experience little to no change in their procedures and methodologies. As such, pricing is not anticipated to be significantly impacted by the new guidelines. Following approval by the US EPA and consensus voting, ASTM expects to finalize its updated Phase I ESA standard, E1527-21, in the middle to latter part of this year.

Pioneer Engineering & Environmental Services strives to stay abreast of changes in the regulatory scenery — and to keep its clients and partners informed of how they will affect them. If you have any questions about on-going revisions to the Phase I ESA standard or feel we may be able to help you move your project forward, please do not hesitate to contact us.

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