Q&A: ASTM Standards
Charlene Drake, LSRP, PG, Associate, interviewed Christina Lewis, PG, Senior Project Manager, on what our clients can expect from ASTM’s changes to the Phase I Environmental Site Assessment standard practice.
Charlene: Christina, our clients want to know what to expect from ASTM’s changes to the Phase I Environmental Site Assessment (ESA) standard practice and what the main goals were for those changes. From your perspective working on the ASTM Task Force and now preparing Phase I’s following the new standard, what would you say?
Christina: The changes to the Phase I ESA standard practice were intended to provide clarity. The commercial real estate industry does not need to learn new terms or definitions, or prepare for unfamiliar scope items. What our clients can expect is more consistency in the level of detail in reports, especially for historical reviews, and in how practitioners classify conclusions.
Charlene: Consistency sounds like a good thing! Is there anything our clients should do differently when contracting for a Phase I?
Christina: In my opinion, here are the top two things clients should be doing if they are seeking CERCLA liability protection and need to complete All Appropriate Inquiry:
Have title searches completed, including a search for activity and use limitations, as well as environmental liens, or include them in your consultant’s scope. The new standard clarifies this is a client (user) requirement.
If you want to discuss emerging contaminants or other state-regulated contaminants/issues, make sure to tell your consultant during the project proposal phase. The revisions clarify the definition of “non-scope consideration” to explicitly state that emerging contaminants that are not federally regulated under CERCLA, such as PFAS, are not included in the ASTM scope.
Charlene: Great advice! Any last “pro tips” for our clients?
Christina: Keep a copy of the “Simplified REC Logic” flowchart from the new ASTM standard handy. It’s a great resource for understanding the conclusions of your reports.
About Christina Lewis, PG
Christina Lewis is a Senior Project Manager in Langan’s Arlington, VA office. She provides environmental consulting with a specialization in contaminated site investigation and remediation and transactional services due diligence. Her professional experience includes environmental assessments and remediation at various active and inactive commercial and industrial facilities primarily throughout the mid-Atlantic region. Christina is an active member of Langan’s ASTM working group, staying up-to-date on the latest developments and communicating changes with the firm.