All Appropriate  Inquiries Rule:
                          Definition  Of Environmental Professional
WHAT Is "ALL APPROPRIATE INQUIRIES?"
"All appropriate inquiries" is the process of evaluating a
property's environmental conditions and assessing potential
liability for any contamination.
WHY DID EPA ESTABLISH STANDARDS FOR
CONDUCTING ALL APPROPRIATE INQUIRIES?
The 2002 Brownfields Amendments to CERCLA require
EPA to develop regulations establishing standards and
practices for conducting all appropriate inquiries.


WHEN DID THE RULE Go INTO EFFECT?
The final rule became effective on November 1, 2006—
one year after its publication date in the Federal Register.
Until November 1, 2006, both the standards and practices
included in the final regulation and the interim standard
established by Congress for all appropriate inquiries
(ASTM El527-00) could be used to satisfy the statutory
requirements for the conduct of all appropriate inquiries.


WHO QUALIFIES As AN ENVIRONMENTAL
PROFESSIONAL?
To ensure the quality of all appropriate inquiries, the
final rule includes specific educational and experience
requirements for an environmental professional. The
definition applies only to persons conducting all
appropriate inquiries for the specific purposes outlined in
the final rule.

The final rule defines an environmental professional as
someone who possesses sufficient specific education,
training, and experience necessary to exercise professional
judgment to develop opinions and conclusions regarding
conditions indicative of releases or threatened releases of
hazardous substances on, at, in, or to a property, sufficient
to meet the objectives and performance factors of the rule.
In addition, an environmental professional must have:

• A state or tribal issued certification or license and three
  years of relevant full-time work experience; or
• A Baccalaureate degree or higher in science or
  engineering and five years of relevant full-time work
  experience; or
• Ten years of relevant full-time work experience.


QUALIFYING As AN ENVIRONMENTAL
PROFESSIONAL THROUGH CERTIFICATION OR
LICENSE REQUIREMENTS
Individuals with a state- or tribal-issued license or
certification also must have the equivalent of three years
full-time relevant experience to qualify as an environmental
professional for the purposes of the all appropriate inquiries
rule.

The relevant certification and license requirements include
and are limited to the following categories:

• A current Professional Engineer's (P.E.) License;
• A current Professional Geologist's (P.G.) License;
• Other current license or certification from a state, tribe,
  U.S. territory, or the Commonwealth of Puerto Rico to
  perform environmental site assessments or all appropriate
  inquiries as defined in the final rule.
Individuals who do not hold one of these licenses or
certifications may still qualify as an environmental
professional through educational and experience
requirements, as explained below.


QUALIFYING As AN ENVIRONMENTAL
PROFESSIONAL THROUGH EDUCATIONAL
REQUIREMENTS
Individuals who hold a Baccalaureate or higher degree
in engineering or science from an accredited institution
of higher education and have equivalent of five years
full-time relevant experience qualify as an environmental
professional under the final rule.

Individuals not meeting the educational requirements may
still qualify as an environmental professional through the
relevant experience requirements outlined below.

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QUALIFYING As AN ENVIRONMENTAL
PROFESSIONAL THROUGH EXPERIENCE
REQUIREMENTS
Individuals who do not otherwise meet the qualifications
for an environmental professional outlined above may still
meet the definition of environmental professional as stated
in the final all appropriate inquiries rule if they have the
equivalent often years of full-time relevant experience.


WHAT Is THE DEFINITION OF RELEVANT
EXPERIENCE?
For the purposes of qualifying as an environmental
professional under the final rule for all appropriate
inquiries, "relevant experience" means:

Participation in the performance of environmental site
assessments that may include environmental analyses,
investigations, and remediation which involve the
understanding of surface and subsurface environmental
conditions and the processes used to evaluate these
conditions and for which professional judgment was used to
develop opinions regarding conditions indicative  of releases
of hazardous substances.
   For a more information on the all appropriate inquiries final
   rule see EPA's Fact Sheet on the All Appropriate Inquiries
   Final Rule (EPA 560-F-05-240).


   CONTACT INFORMATION

   Patricia Overmeyer

   U.S. EPA's Office of Brownfields Cleanup and
   Redevelopment

   (202) 566-2774

   Overmeyer.Patricia@epa.gov

   Also see U.S. EPA's website at ww.epa.gov/brownfields
   for additional information.
MAY PERSONS WHO Do NOT QUALIFY As
ENVIRONMENTAL PROFESSIONALS PARTICIPATE
IN THE CONDUCT OF ALL APPROPRIATE
INQUIRIES?
Individuals who do not meet any of the above requirements
may still participate in the conduct of all appropriate
inquiries. However, they must work under the supervision
or responsible charge of an individual who does meet the
requirements for an environmental professional.
Brownfields Fact Sheet
AAI: Definition of Environmental Professional
Solid Waste
and Emergency
Response (5105)
      EPA 560-F-14-005
        February 2014
www.epa.gov/brownfields/

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