The American Society for Testing and Materials (ASTM) E50 task group is preparing an update to the
E1527 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment
(ESA) Process which is due by the end of 2021.
This standard, which provides the framework on which to conduct a Phase I ESA, was last updated in
2013 and requires recertification every eight years. How the revisions will impact the current Phase I
ESA process is still being finalized.
Potential revisions discussed include clarifying the definitions of Recognized Environmental Condition
(REC), Historical Recognized Environmental Condition (HREC), and Controlled Environmental Condition
(CREC). Currently, some terms in the standard are ambiguous, and a more unified approach is being
considered—including the development of a decision-making flowchart provided in the standard to
assist in the determinations.
Record review is also currently being considered for revision, and may include more stringent
requirements regarding historical research. As the standard currently stands, Environmental
Professionals are only required to “use only as many historical resources as necessary to achieve the
objectives.” More emphasis is being proposed on the need to obtain sufficient historical documents
(including requiring topographical maps, aerials, Sanborn Fire Insurance Maps, and city directories) to
provide a complete picture of the historical use on the subject property. The historical record review
requirements are also being proposed to extend onto the nearby adjoining properties, to better
evaluate the risk these properties pose to the subject property.
A popular question is whether the standard update will address emerging contaminates such as Per- and
polyfluoroalkyl substances (PFAS). Currently the standard considers petroleum products and hazardous
substances listed under the federal Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) in the determination of RECs. Since potential future liability may be associated and
the growing public awareness of these constituents, should Environmental Professionals be required to
consider these emerging contaminants when conducting assessments, in order to better inform clients
of the risks? The update to the standard in 2013 required the emerging concern of vapor encroachment
to be considered, but did not include specific instructions on how they should be assessed. It is possible
that emerging contaminants may be addressed in a similar fashion during the 2021 revision.
The ASTM E1527 update is anticipated to be completed by mid-2021 but may be delayed until later in
the year depending on balloting and the Environmental Protection Agency’s final rule process. ERMI will
stay up to date with the ASTM E1527 updates so that we can continue to provide industry-leading
Environmental Due Diligence services throughout the State of Florida.