Farallon’s Associate Regulatory Specialist Ms. Tina Huff recently returned from ASTM International October 2010 Committee Week meetings held in San Antonio, Texas. Tina is a voting member of the ASTM E50 Committee overseeing Environmental Assessment, and participates in the ASTM Phase I (E1527) Task Group and two related focus groups. Voting members review ballots regarding edits to ASTM E50 standards and provide input on content.
The purpose of ASTM Standard E1527-05 is to define good commercial and customary practice for conducting an environmental site assessment (ESA) of a parcel of commercial real estate with respect to the contaminants within the scope of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). The Standard is undergoing a 5-year review and has a sunset date of 2013.
Standard Practice Revisions Under Consideration
In reviewing E1527, the Phase I Task Group is taking into consideration suggestions for revising or clarifying various components of the Standard. Tina serves on the focus groups reviewing de minimis conditions and historical recognized environmental conditions (HRECs). Among the issues being discussed by the first focus group is whether a standard definition of a de minimis condition should be finalized and put into effect. The second focus group is working to better define what constitutes an HREC, and is considering whether presentation of HRECs should be required in the Conclusions section of a Phase I ESA Report also, rather than in the Findings section only, as is currently the case.
Another notable area undergoing revision for the new ASTM E1527 standard is case law, which has not been updated in over 10 years. Significant changes in environmental assessment standard practices have occurred during that time. Legal members of the committee are incorporating court decisions from that 10-year period as part of the update of case law, which is included as an Appendix to the Standard.
Farallon is Voting ASTM Member
If you have a question or comment related to ASTM E50 standards or their review and revision, feel free to contact Tina at (425) 295-0800. Tina is available to respond to your question directly or can present comments on your behalf at upcoming ASTM committee meetings.
Additional information on Farallon’s Phase I ESA and other due diligence services is available on the Farallon Web site here.