ASTM E1527-13: Are you prepared?

Wednesday, June 19th, 2013

Are you prepared for the pending revisions to the Phase I Environmental Site Assessment standard, ASTM E1527? If not, you’re not alone. According to a survey of lenders conducted by Environmental Data Resources and published in a May 30, 2013 EDR Insight report, 43% of respondents either “don’t know enough” or are “waiting for our EP’s” to educate them. This finding correlates well with another survey by EDR of Environmental Professionals that found 69% have not yet educated their clients.

Given that the revision is expected to be published within the next few months I hope to see the percentage of educated clients and EP’s rise sharply. It’s human nature that some will wait until after the fact and respond in “crisis mode” scrambling to make sense of the changes. Since you’re reading this post then chances are you fall in the group who will be be prepared ahead of time.

Three Key Changes

Why bother preparing now? While the proposed revisions are not drastic changes they are important. There are three key changes proposed:

1. New definition (Controlled REC) and revised definitions (HREC, REC);
2. New emphasis on Vapor Encroachment Screening; and
3. Stricter file review requirements.

The new and revised Environmental Conditions definitions will undoubtedly lead to confusion for those not prepared ahead of time. What would have been listed only in the findings and opinions sections as an HREC under E1527-05 could be listed as a CREC in the conclusions under E1527-13.  If you don’t understand the new CREC definition you are almost certain to be alarmed (unnecessarily).

Vapor Encroachment, the migration of contaminant vapors onto the target property, is not new but it has been gaining more attention over the past several years.  The need to consider Vapor Encroachment during a Phase I ESA was the subject of debate within the industry.  The revised standard (as proposed) settles this debate. Vapor Encroachment must be considered just the same as contaminant migration through soil and groundwater.  The new terminology associated with the Vapor Encroachment Screening process (ASTM E2600-10) and the relationship between a Vapor Encroachment Condition and a Recognized Environmental Condition will also cause confusion for those not prepared.

The new emphasis on file reviews may affect the price and turn around time for those who don’t already include them in the standard scope of work.  This change will be felt nationally but is unlikely to be an issue for most clients working with local firms in southern New England. It’s worth checking with your Environmental Professional now so you’re not surprised with a spike in fees and unexpected delays.

Detailed information pertaining to the proposed revisions are plentiful online.  Anthony Buonicore prepared a particularly thorough slide show that was presented during an EDR webinar in April.

Be Prepared

What you should be doing now:

1. Become familiar with the proposed definitions of REC, HREC, and CREC;
2. Become familiar with the concept of vapor migration and the difference between a VEC and a REC;
3. Ask your Environmental Professional if price and turn around time will be affected by the revisions;
4. Update your review checklists or download them here:
   ASTM E1527-13 Review Checklists

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I fall in the 31% of Environmental Professionals who have already begun educating my clients.  Contact us if you would like to arrange a presentation or if you have any questions.

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Blog post written by Jason Gold, P.E.