All Appropriate Inquiries
The environmental due diligence industry is in an unprecedented period of transition. The market barely had time to read EPA’s final All Appropriate Inquiries rule (40 CFR Part 312) released on November 1, 2005, when they were hit with another significant development two weeks later: a revised ASTM Phase I E 1527 standard. The federal rule, which recognizes the E 1527-05 standard as an acceptable guidance document for satisfying AAI and took effect on November 1, 2006, gave Phase I consultants less than one year to familiarize themselves with the new requirements. The attached Executive Summary, based on EDR’s 2005/2006 Due Diligence at Dawn workshop series, covers the fundamentals of meeting the new federal pre-transaction requirements, and the details of CERCLA’s post transaction continuing obligations.
