On November 1st, ASTM International approved its revised
standard for Phase I Environmental Site Assessments, the first such
update since November 2013.
Phase I Environmental Site Assessments help identify potential
environmental issues that may need to be further assessed and to
efficiently satisfy the Environmental Protection Agency's All
Appropriate Inquiries ("AAI") rule set forth at 40 CFR
312. Satisfaction of the AAI rule avails potential purchasers of
real property of certain liability protections available under the
Comprehensive Environmental Response, Compensation, and Control Act
("CERCLA") – specifically, Bona Fide Prospective
Purchaser protection.
Although the new standard does not break significant new ground,
there are several changes with the potential to have an impact on
future Phase I findings. The following are the key changes to the
Phase I standard: