ASTM Task Group Action 2010
Members of the ASTM International (ASTM) Task Group overseeing the Standard Practice for the Phase I Environmental Site Assessment Process recently convened to evaluate that standard for possible revisions. ASTM Standard E1527-05 defines good commercial and customary practice for conducting an environmental site assessment of a parcel of commercial real estate with respect to the contaminants under CERCLA and petroleum products, and is recognized by the U.S. Environmental Protection Agency (EPA) as compliant with the All Appropriate Inquiries Regulation that went into effect in November 2006. Qualifying for protection from potential liability under CERCLA as an innocent landowner, a contiguous property owner, or a bona fide prospective purchaser requires that all appropriate inquiries be conducted in compliance with ASTM standard.
Ms. Tina Huff, Farallon’s Associate Regulatory Specialist, is an active ASTM member and serves on the ASTM Standard 1527 Task Group. In its evaluation of Standard 1527-05, the Task Group is taking into consideration feedback received from the marketplace, which has included a call for a stronger deliverable. Suggestions submitted to the Task Group have included: 1) changing the report’s table of contents and making it a required component of the report; 2) requiring that the report contain recommendations; and 3) reducing the size of the report and the records it contains. Another recommendation was to require a review of agency records if the subject property is identified as a release site or a regulatory program site.
The Standard 1527 Task Group continues to meet on a regular basis to address marketplace concerns while upholding conformance to the EPA All Appropriate Inquiries Regulation. Task Group developments will be updated on the Farallon Web site.
For further information about ASTM 1527-05 or to discuss how Farallon can help you with due diligence needs, please contact Ms. Huff at (425) 295-0800 or tinahuff@farallonconsulting.com. As manager of Farallon’s due diligence program, Ms. Huff has conducted hundreds of environmental site assessments and compliance audits throughout the United States at sites ranging from single residences to large portfolios of commercial properties. She meets the EPA requirements to qualify as an Environmental Professional and is a Registered Environmental Assessor.
Additional information on ASTM Standard E1527-05 is available on the ASTM International Web site.