Standard Guides For Compliance Audits, Activity And Use Limitations, And Environmental Site Assessments
June 1, 2000
Amy L. Edwards- Washington
At its semi-annual
meeting in early April, the ASTM E50 committee approved three new or revised
Standard Guides pertaining to Compliance Audits, Activity and Use Limitations,
and Phase I Environmental Site Assessments.
The Standard Practice
for Environmental Regulatory Compliance Audits outlines a series of steps for
conducting an environmental regulatory compliance audit. It also defines
commonly used terms and clarifies the responsibilities of the auditor and the
audited entity. Frank Priznar of PRIZIM chaired the Task Group that developed
this standard practice.
The Standard Guide on
the Use of Activity and Use Limitations, Including Institutional and Engineering
Controls, is the first guidance of its kind to be issued by either a private or
regulatory entity. The Guide clarifies commonly used terminology (and attempts
to correct some common misuses of terminology), describes the four principal
types of institutional controls (proprietary controls, local governmental
controls, consent decrees and orders, and notice devices), emphasizes the
importance of long-term stewardship, and gives examples of best practices
currently being used in different parts of the country. This Task Group was
chaired by Amy Edwards of Holland & Knight.
Finally, the ASTM E50
committee issued revisions to the existing Phase I Environmental Site
Assessment (E 1527) and Transaction Screen (E 1528) Standard Practices. The
revised standards introduce the concept of business risk and issues that are
technically outside the scope of the Phase I ESA and the Transaction Screen
(such as asbestos, radon, and institutional controls) and stresses the
importance of the user and the consultant discussing the scope and purpose of
the Phase I ESA/Transaction Screen. The standard also provides a mechanism for
describing recognized environmental conditions (RECs) that have been corrected;
they may now be referred to as “historical RECs.” Tony Buonicore, CEO of EDR,
chaired this Task Group.