The current Phase I Standard, ASTM E15227-13, is anticipated to be replaced with an updated version in late 2021. Based on available information and preliminary discussions, it appears that at least the following changes and/or clarifications will be implemented with the updated standard:
• Clarify that a Phase I ESA is “valid” for 180 calendar days from either the date on the environmental database, date the interviews were conducted, date of the site reconnaissance, or the date the EP signed-off on the report, whichever is earliest
• Create a new section on adjoining properties to ensure they are discussed and appropriately evaluated
• Classify the evaluation of Emerging Contaminates as a non-scope item – this category would include PFOS/PFOA for states that do not have their own cleanup criteria established
• Clarify that recommendations are not required to be within a Phase I ESA report. Recommendations may be provided as a separate letter or memo if desired by the client
• Require that Phase I ESAs include site photographs, which is not a current requirement (but is current best-practice)
Additional changes are likely, although specific details are unknown at this time. Please feel free to contact us with any questions at 616-459-3737.