ASTM E1527 Standard Practice for Environmental Site Assessments

Get Certified ASTM E1527 Testing

ASTM E1527 assessments may be used by property owners, prospective buyers, commercial real estate professionals, lenders, attorneys, developers, property investors, environmental professionals, and others who are considering the environmental condition of commercial real estate. An environmental professional performs the Phase I ESA by reviewing the property’s existing records, inspecting the property and surrounding area, interviewing relevant parties, assessing environmental conditions, and documenting the scope and limitations of the investigation. Assessment is a process that includes the use of professional judgment. A well-performed Phase I ESA can provide documented environmental due diligence data before a real property transaction and help users determine whether conditions may require further investigation or additional environmental services.

• Property Type: Commercial real estate and specific parcels being evaluated for environmental conditions.
• Assessment Objective: Evaluate the environmental condition of the subject property and identify recognized environmental conditions.
• Recognized Environmental Conditions: Evaluate the presence, likely presence, or material threat of future release of hazardous substances or petroleum products.
• Historical Research: Review historical property use and ownership information relevant to environmental conditions.
• Regulatory Research: Review applicable federal, tribal, state, and local environmental records.
• Site Reconnaissance: Visually inspect the subject property and adjoining properties for conditions relevant to the assessment.
• Interviews: Obtain information from owners, operators, occupants, and other appropriate sources.
• Environmental Professional: The Phase I ESA is performed by an environmental professional using professional judgment.
• Documentation: Sources, records, information, findings, limitations, and conclusions are documented in the written report.
• Point-in-Time Assessment: The assessment reflects conditions and information available at the time the applicable assessment elements are completed.
• Limitations: The practice is not an exhaustive investigation and does not eliminate all uncertainty concerning potential environmental conditions.
• Non-Scope Issues: Certain conditions outside the defined scope may warrant additional investigation depending on the property and transaction.

What are the Uses of ASTM E1527?

ASTM E1527 provides a standardized framework for environmental due diligence associated with commercial real estate. The assessment can be performed voluntarily by parties seeking information about a property’s environmental condition and is not limited solely to transactions involving potential CERCLA liability. The information developed through the assessment can help users understand historical property use, current environmental conditions, regulatory concerns, and potential recognized environmental conditions. The results can also help determine whether additional environmental investigation should be considered. Common uses include:

• Real Estate Due Diligence: Evaluate environmental conditions before acquiring commercial property.
• Property Transactions: Provide standardized environmental information for buyers, sellers, and other transaction participants.
• Lender Review: Support environmental review associated with commercial real estate financing.
• Risk Evaluation: Identify recognized environmental conditions requiring further consideration.
• Regulatory Record Review: Evaluate available environmental records associated with the property and surrounding area.
• Historical Property Evaluation: Investigate previous ownership and uses that may indicate potential environmental concerns.
• Brownfields Activities: Support environmental assessment activities conducted under applicable AAI requirements.
• Property Management: Provide environmental information for existing commercial properties.
• Further Investigation Planning: Identify conditions that may warrant Phase II ESA or other environmental services.

Which Materials Can Be Assessed According to ASTM E1527?

ASTM E1527 does not test a specific material or product. Instead, it assesses commercial real estate and the environmental conditions associated with a property. The inquiry focuses particularly on hazardous substances and petroleum products and on conditions that could indicate an existing release, likely release, or material threat of a future release. The assessment may consider properties containing or historically associated with:

• Commercial and industrial facilities
• Manufacturing properties
• Warehouses and distribution facilities
• Retail and commercial properties
• Former industrial properties
• Properties with historical petroleum-related activities
• Properties with historical chemical or hazardous-substance use
• Commercial properties with documented or suspected environmental concerns
• Adjacent properties whose activities may affect the subject property

Why is ASTM E1527 Important?

ASTM E1527 offers a standardized environmental due diligence process and not a random check of the property. It is based on historical research and regulatory records, site observations, interviews, and professional judgment to minimize uncertainty relative to known environmental conditions. It is also noteworthy that EPA has approved ASTM E1527-21 as being consistent with the federal AAI rule. But a Phase I ESA does not remove environmental uncertainty and is not necessarily an investigation, nor does it guarantee no contamination exists.

ASTM E1527 Testing Process and Data Collection

The environmental professional begins by defining the subject property and understanding the purpose and scope of the assessment. Historical sources, regulatory databases, property records, maps, aerial imagery, and other reasonably ascertainable information are reviewed to identify previous uses and conditions that may be relevant to environmental concerns. Observations that are relevant to the project may include use of the property, storage areas, tanks and drums, waste handling areas, staining, stressed vegetation, drainage features, floor drains, wells, transformers, and other conditions that may warrant evaluation. The report includes details on the assessment method, property information, records checked, interviews, site observations, known environmental conditions, or other relevant evidence, limitations, key assumptions, supporting sources, and findings/conclusions. 

Common Challenges and Troubleshooting

Incomplete historical information can make it difficult to determine previous property uses. Environmental professionals should review multiple historical sources and document unavailable or incomplete records rather than assuming that missing information indicates an absence of environmental concerns. Overreliance on the Phase I ESA can also create problems. ASTM E1527 is not an exhaustive investigation and does not eliminate environmental uncertainty. Conditions outside the scope of the practice or findings that require additional investigation may require a Phase II ESA or other specialized environmental services.

• ASTM E1527 does not produce a conventional numerical test result. Instead, the environmental professional evaluates collected information and determines whether identified conditions fall within the applicable environmental-condition definitions, including recognized environmental conditions. 
• The report includes details on the assessment method, property information, records checked, interviews, site observations, known environmental conditions, or other relevant evidence, limitations, key assumptions, supporting sources, and findings/conclusions. 
• The report includes the property identification; assessment purpose and scope; records reviewed; historical information; regulatory database information; site reconnaissance observations; interviews; environmental-condition evaluations; recognized environmental conditions; limitations; assumptions; supporting documentation; and conclusions. 
• The practice does not measure a physical property of the product but instead gives an environmental assessment, and therefore, a universal SI unit does not apply to the result of the practice reported in this ASTM E1527 document. Numbers of the other types of information, such as property size, distances, dates, addresses, regulatory identifiers, and other quantitative information, may be represented in the units and forms suitable to the assessment and the source. 
• Environmental professionals can provide a structured, reproducible, and well-documented Phase I Environmental Site Assessment through consistent records, research, site reconnaissance, interviews, source documentation, professional evaluation, and report preparation.

Link to ASTM E1527