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All Appropriate Inquiries:
Environmental Professional
What are "All Appropriate Inquiries"?
All appropriate inquiries (AAI) is the process of
evaluating a property's environmental conditions and
assessing potential liability for any contamination.
Why did the U.S. Environmental Protection
Agency (EPA) establish standards for
conducting AAI?
The 2002 Brownfields Amendments to the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), also known
as Superfund, required EPA to promulgate regulations
establishing standards and practices for conducting AAI.
The AAI final rule was published in the Federal Register
on November 1, 2005 (70 PR 66070) and went into
effect on November 1, 2006.
Who can perform AAI?
Many AAl-required activities must be conducted by,
or under the supervision or responsible charge of, an
individual who meets the definition of an "environmental
professional." The AAI final rule defines an environmental
professional as someone who possesses the specific
education, training and relevant 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.
Who qualifies as an environmental
professional?
The final AAI rule includes specific educational
and experience requirements for an environmental
professional. The definition applies only to persons
conducting AAI for the specific purposes outlined in the
final rule. An environmental professional is defined as
someone who has one of these qualifications:
•	A state- or tribal-issued certification or license and
three years of relevant, full-time work experience.
•	A bachelor's degree or higher in science or engineering
and five years of relevant, full-time work experience.
•	Ten years of relevant, full-time work experience.
Qualifying as an environmental
professional through certification or
license requirements
For the purpose of AAI investigations, individuals can
qualify as an environmental professional with a state- or
tribal-issued certification or license and the equivalent
of three years of relevant, full-time experience.
The certification and license requirements include and
are limited to:
•	A current professional engineer (PE) license.
•	A current professional geologist (PG) license.
•	A current license or certification from a state, tribe, U.S.
territory or Puerto Rico to perform environmental site
assessments or AAI, as defined in the AAI final rule.

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Individuals who do not have one of these licenses
or certifications can still qualify as an environmental
professional through the educational and experience
requirements outlined below.
Qualifying as an environmental professional
through educational requirements
Individuals who have a bachelor's degree or higher in
engineering or science from an accredited institution
of higher education and who have the equivalent of
five years of relevant, full-time experience qualify as an
environmental professional under the AAI final rule.
Individuals who do not meet the educational requirements
can still qualify as an environmental professional through
the experience requirements outlined below.
Qualifying as an environmental professional
through experience requirements
individuals who do not meet the qualifications for an
environmental professional outlined above can still
qualify as an environmental professional if they have the
equivalent of 10 years of relevant, full-time experience.
What is the definition of relevant
experience?
For the purposes of qualifying as an environmental
professional under the AAI final rule, relevant
experience is:
"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."
Can individuals who do not qualify as
environmental professionals participate In
the conduct of AAI?
Individuals who do not meet the environmental
professional requirements can still participate in the
conduct of AAI, However, they must work under the
supervision or responsible charge of an individual who
does meet the requirements.

Hiring an environmental professional to
perform AAI
When Brownfields decision-makers and grantees
evaluate the capabilities of environmental professionals
for AAI, the following qualifications should be considered:
•	Does the individual who will supervise the AAI meet
the minimum qualifications of an environmental
professional as defined above and in the AAI final
rule, Section 312.10?
•	Does the vendor have experience performing Phase I
and Phase II environmental site assessment activities,
including interviewing owners, operators and
occupants; reviewing historical sources of information
and federal, state, tribai and local government
records; performing visual inspections; conducting
multimedia sampling and analysis; interpreting
geologic, hydrologic, and chemical data; and
preparing site assessment reports?
•	Can the vendor demonstrate experience within the
industry associated with the property being assessed
(e.g., aerospace and defense, chemicals, electronics,
energy, manufacturing, metals/mining, petroleum,
pharmaceuticals, real estate, telecommunications, or
transportation)?
•	Is the vendor knowledgeable about federal,
state, tribal and local environmental laws and
policies, particularly those related to the industry
of the property?
Further information
For more information, visit the EPA Brownfields website at www.epa.gov/brownfields.	EPA-560-F-17-191

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