Are you prepared for the transition? Upgrading to ASTM E1527-21 for Phase I Site Assessments
by Scott Davis
SVP, Industry Engagement, ERIS
Austin, TX
December 2023
In December 2022, the U.S. Environmental Protection Agency (EPA) amended its All Appropriate Inquiries (AAI) rule to reference ASTM International’s updated Phase I Environmental Site Assessment (ESA) standard, E1527-21.
The rule, which took effect on Feb. 13, 2023, allowed the prior standard, E1527-13, to be used for one more year. But beginning Feb. 14, 2024, E1527-13 can no longer be used to satisfy AAI requirements under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). While the revised standard is not an EPA regulation and is not required for AAI compliance, it is now widely recognized as the industry standard for Phase I assessments, which are required for most CRE transactions.
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