What is the difference between an environmental audit and a Phase I Environmental Site Assessment?

The main difference between an environmental audit and a Phase I Environmental Site Assessment (ESA) is that “environmental audit” is a more generic term that may cover a wide variety of issues while the Phase I ESA is strictly defined by the American Society for Testing and Materials (ASTM) so that it complies with the “All Appropriate Inquiries Rule” codified by EPA.

Environmental audits are intended to determine whether or not a company or site is in compliance with applicable environmental rules and determine how well a company is managing issues related to compliance. Such audits may be either “multimedia” (identifying and auditing all environmental media, such as air, water, waste, etc.) or “programmatic” (limited to specific pre-identified regulatory areas, such as air). Some companies seek to obtain certification by an independent certification body by conforming to a voluntary international standard for environmental management systems (EMS) known as ISO 14001. (ISO = International Organization for Standardization.) Such certification does not directly reflect compliance with legal requirements, although it demands that the organization evaluate its compliance status.

Since each company/organization is unique, there is no standard protocol or checklist for such audits; however, many standard checklists have been developed and can be modified by the auditor or by the company to fit the site being audited.

In contrast, ESAs are generally done in relation to mergers, acquisitions, and/or refinancing of properties. They are intended to identify potential sources of contamination that could present a financial liability under US law and do not necessarily determine whether a site is in compliance with applicable rules. More details regarding ESAs will be provided in the next blogpost.

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