As of February 13, 2024, ASTM International’s E1527-13 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process will no longer be recognized by the United States Environmental Protection Agency (US EPA) as satisfying the requirements of the All Appropriate Inquiries rule. The All Appropriate Inquiries rule is the research into potentially contaminated properties that must be conducted by purchasers in order to obtain liability protection under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund.
ASTM International issued an updated Phase I standard (E1527-21) in November 2021, which was subsequently approved by the US EPA as satisfying the requirements of All Appropriate Inquiries on December 15, 2022. The US EPA noted that its final ruling would take effect on February 13, 2023; and that after one year, E1527-13 would no longer be recognized by the Agency as meeting the requirements of All Appropriate Inquiries.
LaBella was an early adopter of the updated Phase I standard, and Phase I ESAs completed by LaBella have been in accordance with E1527-21 since early 2022. We are familiar with the updated standard and are committed to providing our clients with due diligence services that meet all current standards and guidance to ensure compliance with the All Appropriate Inquiries rule.
For additional information regarding the changes in the updated standard, please review our previously issued insights on E1527-21, linked below:
- US EPA Adopts ASTM E1527-21 Standard as Meeting All Appropriate Inquiries (With Webinar)
- ASTM E 1527-21 Has Been Published… Now What?
- 5 Things Commercial Lenders Should Know About the New ASTM Phase I Standard