Key Differences between All Appropriate Inquiries (AAI) and ASTM E 1527-00 The EPA specified ASTM E 1527-00 for Phase I Site Assessments as the designated “interim standards.” Since then ASTM issued the ASTM E 1527-05 which meets and surpasses the new regulations. The key differences between All Appropriate Inquiries standard specification and the old ASTM […]
by Robert S. Harris The EPA Lender Liability Rule does not encourage controlling borrowers but rather it supports proper loan management. Also see: Environmental management for banks, financial institutions & other lenders It may appear the EPA holds financial institutions responsible for the failings of others because lenders have attempted to be responsible in their dealings […]
Key Points Under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), persons may be held strictly liable for cleaning up hazardous substances at properties that they either currently own or operate or owned or operated at the time of disposal. Strict liability in the context of CERCLA means that a potentially responsible party may […]
