ASTM International Phase I ESA Standard and Emerging Contaminants


Environmental regulations and best practices are constantly evolving. As a consulting firm, it’s our job to help our clients understand the regulatory landscape and predict how changes may affect their business. Right now, we’re watching PFAS.  

Per- and polyfluoroalkyl substances, or PFAS, are a class of synthetic fluorine compounds known for their ability to repel water and oil. PFAS are used in a variety of consumer products and in firefighting foams. They are also persistent, bioaccumulative, and toxic. PFAS are as widespread as they are difficult to remediate. They have been detected in every type of environmental media—from sediments to surface water—and even in wildlife tissue.  

On November 1, 2021, ASTM International acknowledged PFAS for the first time in its newest Phase I ESA standard (E1527-21). PFAS are not yet federally regulated by the Environmental Protection Agency (EPA), but we expect the EPA to adopt these new ASTM standards within the next few months to a year.  ASTM now recommends that PFAS (and other emerging contaminants) be included in Phase I ESAs as “non-scope considerations,” especially in states like Michigan and Alaska that have defined the contaminant as hazardous. This will be critical in future years as more states and regulatory agencies pass PFAS regulations, and owners will need to make informed decisions about their risks. 

GeoEngineers is closely tracking PFAS and other emerging contaminants as state legislatures and the EPA move toward increased regulation. Drinking water is likely to be the first regulatory target, and states like Massachusetts have already set a Maximum Contaminant Level (MCL) for PFAS. Local municipalities and other public water resource managers should already be thinking about how to mitigate PFAS risks. The Federal Infrastructure Investment and Jobs Act, signed into law last November, includes $10 billion earmarked for PFAS drinking water issues. PFAS contamination is no longer being treated as a fringe issue. Regulations are coming—it’s not a question of if, but when. 

If you are interested in preparing for this new regulatory framework, contact us. Or reach out directly to Joe Aldridge or myself.

We want you on our team.