Standard Guides For Compliance Audits, Activity And Use Limitations, And Environmental Site Assessments
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.