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ASTM E3228-19

(Guide)

Standard Guide for Environmental Knowledge Management

Standard Guide for Environmental Knowledge Management

SIGNIFICANCE AND USE
4.1 Use—This guide is intended for use on a voluntary basis for evaluating data for long term storage as they relate to environmental matters. The user may elect to apply this guide for any or all of these purposes:  
4.1.1 Determining an entity’s document retention policies;  
4.1.2 Designing and implementing a system for cataloging the documents stored under this guide;  
4.1.3 Documenting whether a property is subject to regulatory action;  
4.1.4 Supporting evaluation of whether similar environmental risks (for example, permits, plant, or process expansion) are being recognized at similar points in their lifecycle per Guide E3123;  
4.1.5 Supporting evaluation of whether similar environmental risks and liabilities are being managed to similar outcomes per Guide E3123;  
4.1.6 Supporting the determination of liability values per Guide E2137;  
4.1.7 Supporting due diligence analysis for proposed mergers, acquisitions, or spinoffs;  
4.1.8 Documenting key decisions on environmental liability provisions, reserves, budgets, and cash flow forecasts, including recognition benchmarks and obligating events (see Guide E3123);  
4.1.9 Providing documentation to support the identification and analysis of liabilities associated with:  
4.1.9.1 Certain remedial alternatives;
4.1.9.2 Future land uses, property transfer, and redevelopment decisions;
4.1.9.3 Land use alternatives for former landfills and chemically impacted sites; and
4.1.9.4 Meeting regulatory requirements;  
4.1.10 Designing and implementing project and program controls;  
4.1.11 Defending against third-party lawsuits;  
4.1.12 Calculating insurance premiums;  
4.1.13 Making and settling insurance claims;  
4.1.14 Making purchase accounting adjustments;  
4.1.15 Preparing an audit defense; and  
4.1.16 Completing financial and investment analysis.  
4.2 Needs Regarding Document Formats—Preserve data across time, eliminate duplicate file collection, and maintain data and files in contem...
SCOPE
1.1 This guide describes good commercial and customary practice in documenting environmental risks, project, and program knowledge.  
1.2 Considering that management of environmental liabilities can span very long timeframes, users of this guide understand that preserving key findings, decisions, obligations, commitments, and guarantees for coming generations of project teams is essential to efficient management of associated assets and liabilities.  
1.3 Units—The values stated in inch-pound units are to be regarded as standard. The values given in parentheses are mathematical conversions to SI units that are provided for information only and are not considered standard.  
1.4 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.  
1.5 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

General Information

Status
Published
Publication Date
14-Oct-2019
ICS
13.020.10 - Environmental management
Technical Committee
E50 - Environmental Assessment, Risk Management and Corrective Action
Drafting Committee
E50.05 - Environmental Risk Management
Current Stage
Ref Project

Relations

Refers
ASTM E3123-17 - Standard Guide for Recognition and Derecognition of Environmental Liabilities
Effective Date
15-Oct-2017
Refers
ASTM E3123-18 - Standard Guide for Recognition and Derecognition of Environmental Liabilities
Effective Date
01-Feb-2018
Refers
ASTM E2091-17 - Standard Guide for Use of Activity and Use Limitations, Including Institutional and Engineering Controls
Effective Date
01-Nov-2017
Refers
ASTM E2790-20 - Standard Guide for Identifying and Complying With Continuing Obligations
Effective Date
01-Jan-2020
Referred By
ASTM E2173-22 - Standard Guide for Disclosure of Environmental Liabilities
Effective Date
15-Oct-2019
Referred By
ASTM E2137-22 - Standard Guide for Estimating Monetary Costs and Liabilities for Environmental Matters
Effective Date
15-Oct-2019
Referred By
ASTM E2107-20 - Standard Practice for Environmental Regulatory Compliance Audits
Effective Date
15-Oct-2019

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ASTM E3228-19 - Standard Guide for Environmental Knowledge Management
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Standards Content (Sample)

This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: E3228 − 19
Standard Guide for
1
Environmental Knowledge Management
This standard is issued under the fixed designation E3228; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope 40 CFR, Part 280 Regulations
E2091 Guide for Use of Activity and Use Limitations,
1.1 This guide describes good commercial and customary
Including Institutional and Engineering Controls
practice in documenting environmental risks, project, and
E2137 Guide for Estimating Monetary Costs and Liabilities
program knowledge.
for Environmental Matters
1.2 Considering that management of environmental liabili-
E2173 Guide for Disclosure of Environmental Liabilities
ties can span very long timeframes, users of this guide
E2681 Guide for Environmental Management of Under-
understand that preserving key findings, decisions, obligations,
ground Storage Tank Systems Storing Hazardous Sub-
commitments, and guarantees for coming generations of proj-
stances or Petroleum
ect teams is essential to efficient management of associated
E2790 Guide for Identifying and Complying With Continu-
assets and liabilities.
ing Obligations
E3123 Guide for Recognition and Derecognition of Envi-
1.3 Units—The values stated in inch-pound units are to be
regarded as standard. The values given in parentheses are ronmental Liabilities
3
2.2 U.S. Financial Accounting Standards Board Standards:
mathematical conversions to SI units that are provided for
information only and are not considered standard. ASC Topic 410-20 Asset retirement obligations
ASC Topic 410-30 Other environmental obligations
1.4 This standard does not purport to address all of the
ASC Topic 450 Contingencies
safety concerns, if any, associated with its use. It is the
ASC Topic 460 Guarantees
responsibility of the user of this standard to establish appro-
ASC Topic 820 Fair value measurement
priate safety, health, and environmental practices and deter-
2.3 U.S. Governmental Accounting Standards Board Stan-
mine the applicability of regulatory limitations prior to use.
4
dards:
1.5 This international standard was developed in accor-
Statement 6 Accounting and Financial Reporting for Special
dance with internationally recognized principles on standard-
Assessments
ization established in the Decision on Principles for the
Statement 49 Pollution remediation obligations
Development of International Standards, Guides and Recom-
Statement 72 Fair value measurement and application
mendations issued by the World Trade Organization Technical
Statement 83 Certain asset retirement obligations
Barriers to Trade (TBT) Committee.
2.4 International Accounting Standards Board Standard:
IAS 37 Provisions, contingent liabilities and contingent
2. Referenced Documents
5
2 assets
2.1 ASTM Standards:
6
2.5 Federal Standards:
E1527 Practice for Environmental SiteAssessments: Phase I
40 CFR 261 Identification and Listing of Hazardous Waste
Environmental Site Assessment Process
40 CFR 264 Subpart H Financial Requirements
E1689 Guide for Developing Conceptual Site Models for
40 CFR 265 Interim Status Standards for Owners and
Contaminated Sites
Operators of Hazardous Waste Treatment, Storage, and
E1990 Guide for Performing Evaluations of Underground
Disposal Facilities
Storage Tank Systems for Operational Conformance with
40 CFR 280 Technical Standards and Corrective Action
Requirements for Owners and Operators of Underground
1
ThisguideisunderthejurisdictionofASTMCommitteeE50onEnvironmental Storage Tanks (UST)
Assessment, Risk Management and CorrectiveAction and is the direct responsibil-
ity of Subcommittee E50.05 on Environmental Risk Management.
3
Current edition approved Oct. 15, 2019. Published January 2020. DOI: 10.1520/ Available from the Financial Accounting Standards Board, www. fasb.org.
4
E3228–19 AvailablefromtheGovernmentalAccountingStandardsBoard,www.gasb.org.
2
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
5
contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM Available from the International Accounting Standards Board, www. iasplus-
Standards volume information, refer to the standard’s Document Summary page on .com.
6
the ASTM website. Available from the U.S. Government Publishing Office, www.govinfo.gov.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
1

---------------------- Page: 1 ----------------------
E3228 − 1
...

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4.1 This guide may be used for environmental compliance performance assessment in the United States in a wide variety of applications and is not particularly limited to one type of user. The following groups of users may find the guide particularly helpful:  
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4.1.3 Federal, state or local facilities and regulators, including departments of health and fire departments;  
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4.1.5 Waste managers, including liquid and solid waste haulers, treatment, recycling, disposal and transfer;  
4.1.6 Consultants, auditors, inspectors and compliance assistance personnel;  
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1.1 Overview—This guide is an organized collection of information and series of options for industry, regulators, auditors, consultants and the public, intended to measure compliance with environmental performance standards against established benchmarks. It focuses on compliance with air, water, waste prevention, waste management, and toxic reduction standards for facilities in the United States. While the guide does not recommend a specific course of action, it establishes a tiered framework of essential components, beginning with those standards where a deviation presents the greatest potential public health, environmental, and business risks. In each identified pathway, at each tier or step of analysis, the guide outlines ways to identify compliance options and reduce pollution in iterative steps. The goal in using the guide is to lower environmental, public health and business risks from Tiers 1 and 2 to Tiers 3 and 4, by evaluating the performance standards described in this guide. While this guide provides a simplified framework of explicit steps for users, a qualified professional should conduct detailed, site-specific risk analysis. This guide may act as a starting point for organizations with limited experience in systematic environmental assessment. As facilities develop their specific plan framework, they will find that risk is weighted by more than just a few parameters. For each facility risk is the complex interaction among location, size, history, surrounding community and ecological zones.  
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1.2.4 Illustrate the report formats and content typically used in environmental disclosures.  
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Standard Guide for Representative Sampling for Management of Waste and Contaminated Media

SIGNIFICANCE AND USE
4.1 This guide defines the meaning of a representative sample, as well as the attributes the sample(s) needs to have in order to provide a valid inference from the sample data to the population.  
4.2 This guide also provides a process to identify the sources of error (both systematic and random) so that an effort can be made to control or minimize these errors. These sources include sampling error, measurement error, and statistical bias.  
4.3 When the objective is limited to the taking of a representative (physical) sample or a representative set of (physical) samples, only potential sampling errors need to be considered. When the objective is to make an inference from the sample data to the population, additional measurement error and statistical bias need to be considered.  
4.4 This guide does not apply to the cases where the taking of a nonrepresentative sample(s) is prescribed by the study objective. In that case, sampling approaches such as judgment sampling or biased sampling can be taken. These approaches are not within the scope of this guide.  
4.5 Following this guide does not guarantee that representative samples will be obtained. But failure to follow this guide will likely result in obtaining sample data that are either biased or imprecise, or both. Following this guide should increase the level of confidence in making the inference from the sample data to the population.  
4.6 This guide can be used in conjunction with the DQO process (see Practice D5792).  
4.7 This guide is intended for those who manage, design, and implement sampling and analytical plans for waste management and contaminated media.
SCOPE
1.1 This guide covers the definition of representativeness in environmental sampling, identifies sources that can affect representativeness (especially bias), and describes the attributes that a representative sample or a representative set of samples should possess. For convenience, the term “representative sample” is used in this guide to denote both a representative sample and a representative set of samples, unless otherwise qualified in the text.  
1.2 This guide outlines a process by which a representative sample may be obtained from a population. The purpose of the representative sample is to provide information about a statistical parameter(s) (such as mean) of the population regarding some characteristic(s) (such as concentration) of its constituent(s) (such as lead). This process includes the following stages: (1) minimization of sampling bias and optimization of precision while taking the physical samples, (2) minimization of measurement bias and optimization of precision when analyzing the physical samples to obtain data, and (3) minimization of statistical bias when making inferences from the sample data to the population. While both bias and precision are covered in this guide, major emphasis is given to bias reduction.  
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4.1.9 Non-regulatory government agencies, such as the military; and  
4.1.10 Specific industrial sectors such as dry cleaners, printers, photo processors, laboratories, health care, and vehicle fueling, maintenance and delivery.  
4.2 This guide is intended as a first step in crafting simplified management goals for assessing compliance with a wide variety of multimedia environmental performance standards. The framework describes a process by which the user may categorize current waste management, air quality, water, and release prevention practices in order to manage the risks associated with noncompliance. The technique classifies common environmental performance standards into tiers based on relative risks to human health, the environment and business operations. The tier classifications found in this guide reflect the general requirements of State, Federal and local compliance and enforcement programs. These authorities generally classify groups of similar environmental performance standards according to the significance of any noncompliance within each group of standards.
Note 1: Users in the United States are encouraged to review the EPA’s Audit Policy Program: Frequently Asked...
SCOPE
1.1 Overview—This guide is an organized collection of information and series of options for industry, regulators, auditors, consultants and the public, intended to measure compliance with environmental performance standards against established benchmarks. It focuses on compliance with air, water, waste prevention, waste management, and toxic reduction standards for facilities in the United States. While the guide does not recommend a specific course of action, it establishes a tiered framework of essential components, beginning with those standards where a deviation presents the greatest potential public health, environmental, and business risks. In each identified pathway, at each tier or step of analysis, the guide outlines ways to identify compliance options and reduce pollution in iterative steps. The goal in using the guide is to lower environmental, public health and business risks from Tiers 1 and 2 to Tiers 3 and 4, by evaluating the performance standards described in this guide. While this guide provides a simplified framework of explicit steps for users, a qualified professional should conduct detailed, site-specific risk analysis. This guide may act as a starting point for organizations with limited experience in systematic environmental assessment. As facilities develop their specific plan framework, they will find that risk is weighted by more than just a few parameters. For each facility risk is the complex interaction among location, size, history, surrounding community and ecological zones.  
1.2 Differences Among Standards—This guide focuses on compliance with environmental performance standards in the United States. As such it includes a unique, risk-based method to analyze specific groups of legal requirements, as well as risk reduction techniques, sometimes called “pollution prevention.”  
1.2.1 Use of this guide provides a system to evaluate the relative priority of compliance and pollution preven...

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ASTM
ASTM E2107-20(Practice)
Standard Practice for Environmental Regulatory Compliance Audits

SIGNIFICANCE AND USE
4.1 Intended Use—This practice is intended for use by parties who wish to perform or direct an audit, or rely upon audit findings or an audit report. Such use includes audits by internal and external auditors.  
4.2 Other Audit Criteria—Other audit criteria may be included in the audit scope if specified in the audit plan. Examples include safety and health requirements, and technical, operational, and management requirements.  
4.3 Related ASTM Standards—This practice is related to Practice E1527, which addresses CERCLA liability, and Practice E1528, which addresses due diligence for commercial real estate. A number of terms and procedures from these practices are similar to terms and procedures associated with this practice but they may not be the same. Guide E2365 addresses environmental compliance assessment and may be an appropriate tool for some environmental regulatory compliance audits. The user is advised that Guide E2365 is not an all-encompassing compliance assessment tool. Guide E3123 addresses the five types of environmental liabilities named in generally-accepted accounting principles (asset retirement obligations, environmental obligations, commitments, contingencies and guarantees).  
4.3.1 Not Interchangeable—Although distantly related to Practices E1527 and E1528, this practice is designed to achieve different results. Therefore, these practices shall not be used interchangeably with, or in place of, this practice.  
4.4 Related ISO Guidelines—The International Organization for Standardization (ISO) has developed guidelines addressing environmental auditing. These are ISO 14001-2015 and 19011-2018. A number of terms and procedures from these guidelines may be similar to terms and procedures associated with this practice but they may not be the same. ISO 14001-2015 added several compliance evaluation criteria, including Section 9.1.2 (Evaluation of Compliance) and Section 9.2 (Internal Audits).  
4.4.1 Not Interchangeable—Although related to IS...
SCOPE
1.1 Purpose—This practice2 identifies minimum requirements for environmental regulatory compliance audits (audits). It also provides information on the terms and procedures associated with audits as practiced in the United States of America (USA) and other jurisdictions subject to the laws thereof. It provides a reference to which interested parties may refer for definition and description of accepted audit terms and procedures.  
1.2 Background:  
1.2.1 Awareness of Benefits Associated with Audits—Various benefits have been attributed to audits. These benefits may include a better understanding of the compliance status of a facility or organization, identification of opportunities for environmental management systems improvements, reduction or elimination of potential legal and financial liabilities when implemented as part of a comprehensive compliance management program, better communications and improved relationships with governmental agencies, communities, and other stakeholders, providing information for development of both short-term and long-term environmental expenditures, and education of employees.  
1.2.2 Awareness of Risks Associated with Audits—It is also important to recognize that certain risks have been associated with audits. These risks may be managed and controlled by giving thoughtful consideration to the audit process before beginning an audit. These risks may include increased potential legal and financial liabilities for the audited entity if audit findings are not corrected in a timely manner, disclosure of confidential business information or trade secrets, inadvertent admissions against interest because of the wording of audit findings, disclosure of audit findings intended to be kept confidential under audit privilege laws or attorney-client privilege or work product doctrine, and inaccurate audit findings.  
1.2.3 Awareness of Legal Issues—A number of important legal issues are associat...

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ASTM
ASTM E2637-17(Guide)
Standard Guide for Utilizing the Environmental Cost Element Structure Presented by Classification

SIGNIFICANCE AND USE
5.1 In addition to its cost management and project management functions, the ECES can also be used to support a number of other program and project functions. These functions include:  
5.1.1 Bid solicitation, collection, and evaluation;  
5.1.2 Communicating project data between installations, complexes, agencies, and industry;  
5.1.3 Providing a project checklist;  
5.1.4 Cost and schedule estimating;  
5.1.5 Historical cost/schedule data collection;  
5.1.6 Historical project data collection (for example, technology deployments, project conditions);  
5.1.7 Validating and calibrating cost estimates and software tools; and  
5.1.8 Establishing and disseminating best practices and lessons learned.  
5.2 Several government agencies are already incorporating this structure into existing and future cost estimating models, databases, and other similar software tools and systems.
SCOPE
1.1 The Environmental Cost Element Structure (ECES) covered by Classification E2150 (and Adjunct E2150) provides a consistent and comprehensive structure across all phases of environmental remediation projects and is a tool to improve the cost management of those projects. This guide is intended to facilitate the application of the ECES to any environmental remediation project, without regard to project size.  
1.2 Classification E2150 establishes the broad, top-level framework for environmental remediation projects by providing a hierarchical list of project elements to two levels of detail. Its associated Adjunct E2150 supports the top-level structure by providing more detailed elements and definitions of the ECES to three additional levels of detail. Although it is assumed that the user is familiar with Classification E2150, much of the content of the classification is repeated in this guide to relieve the user of the burden of back-and-forth referencing during use. It is assumed, however, that all users of this guide will have at hand both Classification E2150 and the Adjunct E2150 during project planning.  
1.3 The values stated in SI units are to be regarded as standard. No other units of measurement are included in this standard.  
1.4 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.  
1.5 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

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ASTM
ASTM E2247-16(Practice)
Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property

SIGNIFICANCE AND USE
4.1 Uses—This practice is intended for use on a voluntary basis by parties who wish to assess the environmental condition of forestland or rural property taking into account commonly known and reasonably ascertainable information. While use of this practice is intended to constitute all appropriate inquiries for purposes of the LLPs, it is not intended that its use be limited to that purpose. This practice is intended primarily as an approach to conducting an inquiry designed to identify recognized environmental conditions in connection with a property. No implication is intended that a person must use this practice in order to be deemed to have conducted inquiry in a commercially prudent or reasonable manner in any particular transaction. Nevertheless, this practice is intended to reflect a commercially prudent and reasonable inquiry. (See section 1.6.)  
4.2 Clarifications on Use:  
4.2.1 Use Not Limited to CERCLA—This practice is designed to assist the user in developing information about the environmental condition of a property and as such, has utility for a wide range of persons, including those who may have no actual or potential CERCLA liability and/or may not be seeking the LLPs.  
4.2.2 Residential Occupants/Lessees/Purchasers and Others—No implication is intended that it is currently customary practice for residential occupants/lessees of multifamily residential buildings, occupants/lessees of single-family homes or other residential real estate, or purchasers of dwellings for one's own residential use, to conduct an environmental site assessment in connection with these transactions. Thus, these transactions are not included in the term forestland or rural property transactions, and it is not intended to imply that such persons are obligated to conduct an environmental site assessment in connection with these transactions for purposes of all appropriate inquiries or for any other purpose. In addition, no implication is intended that it is currently c...
SCOPE
1.1 Purpose—The purpose of this practice is to provide an alternative method to ASTM E1527 for good commercial and customary practice in the United States of America for conducting a Phase I Environmental Site Assessment2 of forestland or rural property with respect to the range of contaminants within the scope of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and petroleum products. As such, this practice is intended to permit a user to satisfy one of the requirements to qualify for the innocent landowner, contiguous property  owner, or bona fide prospective purchaser limitations on CERCLA liability (hereinafter, the “landowner liability protections,” or “LLPs”): that is, the practice that constitutes “all appropriate inquiries” into the previous ownership and uses of the property consistent with good commercial or customary practice” as defined at 42 U.S.C. §9601(35)(B). (See Appendix X1 for an outline of CERCLA's liability and defense provisions.) Controlled substances are not included within the scope of this standard. Persons conducting an environmental site assessment as part of an EPA Brownfields Assessment and Characterization Grant awarded under CERCLA 42 U.S.C. §9604(k)(2)(B) must include controlled substances as defined in the Controlled Substances Act (21 U.S.C. §802) within the scope of the assessment investigations to the extent directed in the terms and conditions of the specific grant or cooperative agreement.  
1.1.1 Standard Practice Selection—The methodology included in this practice is an effective and practical process for achieving the objectives of a Phase I Environmental Site Assessment of forestland or rural property when some of the methodologies of ASTM E1527 are deemed to be impractical or unnecessary due to the size or nature of the property. This practice is intended to provide a more practical approach to assess rural and forestland properties that are g...

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