scope:

Purpose In the language of the Standard, the purpose of E 1527 is to define a practice for conducting Phase I Environmental Site Assessments. The EP is going to be considering only a range of contaminants covered by CERCLA and petroleum products. The Phase I Standard is designed to permit the user to satisfy one of the requirements for the landowner liability protections (LLPs) to CERCLA liability, that is, the practice that constitutes "all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice" as defined at 42 U.S.C. § 9601(35)(B). The goal of the Phase I ESA is for the EP to identify recognized environmental conditions (RECs).

Prior to the publication of the first edition of the ASTM Standard on Phase I Environmental Site Assessments, the users and the environmental professionals had to develop the ESA scope on their own. Consequently, Phase I assessments came in many variations. On one hand, the users were seeing Phase I reports without any interviews or historical research. Some reports consisted of "driveby" photo documentation without any evidence of the EP ever setting a foot on the property. On the other hand, Phase I sometimes included issues such as radon, electromagnetic radiation, clean air issues, fire hazards, and structural evaluations of build-ings, which are not CERCLA issues. In summary: The term "Phase I" meant different things to different people. The Phase I Standard was developed by ASTM through its Committee E-50 on Environmental Assessment to establish uniform (standardized) site assessment practices. The intent was to define some of the due diligence responsibilities of the participants (our referenced players) in a commercial real estate transaction. Through standardization, the E-50 Committee made it possible for the Phase I ESA to mean the same thing to different people.

Let's examine the scope section of the Standard and see how the EPs can apply it to their work. This section of E 1527 defines three essential issues: purpose of the Standard, objectives of the Standard and considerations beyond the scope of the Standard. Let's look at each separately.