Since the passage of AAI and multiple updates to the ASTM 1527 standard, there has been confusion and questions among some environmental professionals (EPs) about which databases are required to meet ASTM and which databases are supplemental. GRS | Corteq recently sat in on a webinar led by Julie Kilgore from Wasatch Environmental (chair of ASTM 1527 group) and Patricia Overmeyer (EPA).
The key point of the presentation was that professional judgment of the Environmental Professional (EP) is the main factor in compliance with the ASTM requirements. The database report(s) provided by vendors like EDR is only an information tool.
In other words, assessment service providers need to use their heads, think through the data presented, and be sure it is thoroughly analyzed in reports. Over reliance on the database reports as the sole source of information for determining whether a particular site is a concern is the real danger.
ASTM E1527-13 lists various Standard Environmental Records to be reviewed. But in addition, ASTM states that other environmental records shall be reviewed to enhance and supplement the standard sources if, in the judgement of the EP, the data is 1) reasonably ascertainable, 2) useful, and 3) is generally obtained as part of good commercial and customary practice. Many of these supplemental databases are also included in the database reports receive from vendors like EDR.
The presenters cautioned listeners to work on managing the flow of data received from vendors like EDR. In their view, the best reports are not necessarily the ones with the most databases included, but the ones where the EP employs professional judgment to sift through all the available data sources and utilize the ones that are useful.
What are your thoughts on this subject?
About the Author: Ross Simmons, based in Beaverton, OR, is a project manager at GRS | Corteq. He has over 26 years experience in commercial real estate performing Phase I, Phase II, and other environmental due diligence services.
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