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What a Phase I does not cover

No. Asbestos, mold, radon, lead-based paint, and lead in drinking water are non-scope considerations under ASTM E1527-21. The Phase I's scope is releases of hazardous substances and petroleum products to the environment. Building-material and indoor-condition hazards are outside it unless the user specifically adds them.

Commonly requested non-scope items:

  • Asbestos-containing materials (pre-1980s buildings especially)
  • Lead-based paint (pre-1978 residential)
  • Radon
  • Mold and moisture
  • Wetlands, regulatory compliance audits, health and safety conditions, and others

Each has its own assessment methodology and often its own standard. When a user engages the consultant for them, the work appears as additional services in the report or as separate deliverables.

Two takeaways for buyers and lenders. First, read the scope. A Phase I that is silent on asbestos has not cleared the building of asbestos; it was never asked. Lenders on older buildings often require an asbestos screen alongside the Phase I, and HUD and agency multifamily programs have their own checklists. Second, contaminants released to the environment remain in scope regardless of source. Asbestos in building materials is non-scope, but asbestos-containing debris buried on the property is a release question.