As environmental consultants, we are provided a Phase I Environmental Site Assessment (ESA) template to follow and assume it meets the ASTM E1527 standard (Standard). Those in charge of the Phase I ESA template at an environmental consulting firm concentrate on the new items when an updated Standard is released. They rightfully assume that the current Phase I ESA blank had been fully vetted to that point.

There have been several articles posted regarding the upcoming changes to ASTM E1527-21. Section 9 (Site Reconnaissance) and Section 10 (Interviews with Past and Present Owners, Operators, and Occupants) were not significantly changed and as such there is limited or no discussion of these sections in most articles. Therefore, when new Phase I ESA blanks are prepared by a company, those sections will likely remain the same.

However, it has been my experience that all Phase I ESAs do not fully document the requirements outlined in Section 9 and Section 10 of the Standard. During third-party reviews, the deficiency in these sections is rarely identified. This is likely due to 1) the environmental consultant reviewing the Phase I ESA not being fully aware of the Standard and/or 2) the deficiency is not a significant enough to warrant identification.

Environmental consultants should update Section 9 and Section 10 of their Phase I ESA report templates to bring them in accordance with the Standard. However, it is imperative that those conducting the site inspection become proficient in understanding the requirements of those sections while conducting the site inspection and Owner/Key Site Manager interview.

As an alternative to changing the Phase I ESA report templates, CSTAT has created a Phase I ESA Field Inspection Form (Field Form) that fully documents ALL the requirements of Section 9 and Section 10 of the Standard. Therefore, the utilization of the Field Form and the inclusion of the Field Form Report in the Appendix of a Phase I ESA eliminates the deficiency in most consultant's report templates.

It is important that all site inspections (both staff and subcontractors) use the Field Form, regardless of experience level. That is because the purpose of the Field Form is documentation - not training or reminders. I assume that senior reviews like yourself will appreciate the Field Form which should provide a significant time savings during your reviews.