EPA Recognizes ASTM E1527-21 As Satisfying All Appropriate Inquiries Rule

Highlights

• ASTM International's E1527-21 Standard Practice on Phase I Environmental Site Assessments (ESAs) has been recognized by the U.S. Environmental Protection Agency (EPA) as satisfying the all appropriate inquiries (AAI) rule (40 CFR Part 312).
• EPA will no longer recognize both the older version of the standard, E1527-13, and the newer version, E1527-21. Nevertheless, users can continue to use the older standard, E1527-13, until Feb. 13, 2024, while they become familiar with the new standard.
• EPA acknowledged in its response to comments that the ASTM 1527 standard is not an EPA regulation and that use of the E1527 standard is not required to comply with AAI.

It has taken a year to obtain greater certainty of what is required to satisfy the U.S. Environmental Protection Agency's (EPA) all appropriate inquiries (AAI) rule (40 CFR part 312). Earlier this year, EPA issued a direct final rule, 87 Fed. Reg. 14174 (March 14, 2022), as well as a companion