The EPA deadline has arrived. Here is some practical information to help get you prepared.
In its December 2022 direct final rule, the USEPA announced that it will no longer recognize the ASTM E1527-13 as an avenue for satisfying “All Appropriate” as of February 13, 2024. As E1527-13 rides off into the sunset, here are five important things to be aware of if you are not using the current industry standard, E1527 -21:
- Complying with the new Standard Practice could change your workflow, turnaround time, and reporting methods. It’s important to ensure that your teams are prepared to account for that in the transition. It will take time to educate yourself so the sooner you’re up to speed, the easier it will be to make the transition.
- You also may have to update all of your report templates, contracts, and proposals to reflect the updated Scope of Work as well as incorporate updated terminology.
- Making the transition now could minimize exposure to potentially significant risks for your business, particularly if there’s a dispute on a transaction over your Phase l’s findings and conclusions. Having relied on the retired -13 standard could put your firm in a very difficult position to define why you didn’t follow -21 and if there was an error or omission, it could be too late to go back and fix it.
- Given the long timeframe since the standard was adopted, it’s a very steep uphill battle to argue at this point that you didn’t have enough time to prepare for the transition given that ASTM E1527-21 is now considered the industry best practice.
- If you still need to move to -21, LightBox EDR has you covered! We have environmental data resources to help you learn about the transition, including articles, webinars, and educational materials. We also have a 21-optimized PARCEL report template, a search for environmental liens back to 1980, and much more.
If you have questions or want assistance, get in touch with your LightBox sales representative or contact us at info@lightboxre.com.
You can also visit the LightBox ASTM Resource Center for more insights.
