Phase I Environmental Site Assessments
ASTM’s Proposed Definition of CREC May Jeopardize Landowner Liability Protections Under CERCLA
JD Supra by Amy EdwardsInternational – ASTM has proposed redefining a Controlled Recognized Environmental Condition (CREC). The ASTM’s definition, as drafted, confuses risk-based decision-making with the implementation of institutional controls, undermining 20 years’ worth of other ASTM and U.S. Environmental Protection Agency (EPA) work on institutional controls. The proposed CREC definition raises significant questions as to…
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