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EPA amends standards and practices for conducting “all appropriate inquiries” under the CERCLA [US]

“All Appropriate Inquiries” is the process of evaluating a property’s environmental condition and assessing the likelihood of contamination.  Every Phase I assessment conducted under CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act) and pursuant to EPA’s Brownfields program must be conducted in compliance with the All Appropriate Inquiries Rule at 40 CFR 312.  ASTM International’s E1527-05 standard from 2005 is currently listed as the standard that sites must follow in conducting a Phase I Assessment, and EPA is proposing to replace the 2005 standard with the 2013 standard E1527-13.  The amendments would replace reference to E1527-05 with E1527-13.

The updated 2013 standard is a recognized industry consensus-based standard to conduct all appropriate inquiries under CERCLA.  The amendment would not preclude sites from using E1527-05, but allows the use of E1527-13 as well. EPA’s proposed action would not prevent parties from continuing to use other standards, methods, or customary business practices for conducting all appropriate inquiries, so long as they comply with the standards and procedures set forth in the All Appropriate Inquiries Rule. Instead, the proposed action removes the reference to a standard that ASTM International no longer recognizes as current and that it no longer represents as reflecting its current consensus-based standard.

Written comments must be received by EPA by July 17, 2014.


EPA Updates All Appropriate Inquiries Rule, Federal Register, 79 FR 34480, June 17, 2014 (https://federalregister.gov/a/2014-14032)

40 CFR 312

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