Former printing shop on the subject property

Historical sources show that a printing shop, or print shop, once operated at the subject property. The standard does not mention printing, and the past use raises the question of a release without answering it. Whether it makes a recognized environmental condition (REC) depends on four things: what the shop used and discarded, how long it ran and when, how its wastes left the building, and what the records and the building show of a release.

What the answer turns on

With no known release, the question falls under the second part of the REC definition: hazardous substances or petroleum products likely present at the subject property owing to a release or a likely release (E1527-21, 3.2.73). The standard's appendixes are nonmandatory. Appendix X4 says the two judgments, likely release and likely presence, go together (E1527-21, X4.1).

What the shop used and discarded. The standard does not say what a printing shop uses. Its definition of a solvent says one may be a hazardous substance in its own right, and names equipment clean-up among the uses of solvents (E1527-21, 3.2.82). Migration, as the standard defines it, includes vapor in the subsurface (E1527-21, 3.2.53): see vapor in a Phase I. A specific past use tells more than a general one (E1527-21, 8.3.7). Establish what the shop printed and with what equipment, which materials it used, stored and discarded, and in what amounts.
How long it ran, and when. The environmental professional considers what releases the historical uses could have led to (E1527-21, 8.3.1). Appendix X4's factors include how long operations ran and in what period, including times when management practices or regulatory oversight may have been lacking. Its note gives petroleum storage and dispensing, dry cleaning, manufacturing and the like, run for a significant period before regulatory controls, as possible examples, if the professional believes a release has likely occurred (E1527-21, X4.1). Establish the first and last years the sources show the shop.
How its wastes left the building. Drains and sumps, wastewater discharged from the subject property, wells including dry wells, and septic systems are site visit features, and interview questions shall try to cover the past ones (E1527-21, 9.4.21, 9.4.26, 9.4.27, 9.4.28, 10.2). Wastewater, as the standard defines it, takes in water used in an industrial or manufacturing process (E1527-21, 3.2.97). Establish whether the shop's drains led to a public sewer, a septic system, a dry well or the ground: see septic system, cesspool or dry well. The body of the standard does not say what any discharge point means for the answer. Under today's federal generator rule (40 CFR part 262), a small or large quantity generator keeps the signed copy of each manifest at least three years, counted from the day the first transporter accepted the waste (40 CFR 262.10(a)(1), 262.40(a)). A shop closed longer ago may have none left to ask for.
What the records and the building show of a release. Appendix X4 lists observations, data, documents and interviews as direct evidence of a release (E1527-21, X4.1). Odors, drums and containers, staining or corrosion of floors, walls and ceilings, and stained soil or pavement are site visit features (E1527-21, 9.4.13, 9.4.15, 9.4.20, 9.4.23). The site visit need not identify conditions under floors or behind walls, and limits on what could be seen are documented (E1527-21, 9.2.4.2, 9.2.6). A known release is looked for on state hazardous waste site and voluntary cleanup lists.

The records that bear on it

Historical sources. Local street directories list the occupants of an address, and fire insurance maps show how properties were used at given dates (E1527-21, 3.2.34, 3.2.49). A use shown only as retail, industrial or manufacturing calls for further standard historical resources when reasonably ascertainable and likely to identify the specific use, short of data failure (E1527-21, 8.3.6, 8.3.7).
Generator records. The federal generator list is a standard source, searched for the subject property and adjoining properties (RCRA generators; E1527-21, 8.2.2, Table 2). The hazardous waste definitions set a generator's category by what it generates in a calendar month; for a very small quantity generator that is no more than "100 kilograms (220 lbs) of non-acute hazardous waste", with separate amounts for acute waste (40 CFR 260.10). Today's generator rule puts its identification number section among the requirements of small and large quantity generators, not those of a very small quantity generator (40 CFR 262.10(a)(1)). So a shop in the smallest category may have no federal number, and a shop absent from the list may still have generated hazardous waste.
Documents and interviews. The owner, key site manager and user are asked whether they know of safety data sheets, hazardous waste generator notices or reports, and environmental permits (E1527-21, 10.8, 10.8.1). Past owners, operators and occupants likely to have material information are interviewed where identified (E1527-21, 10.5.4).

What the federal rule says

Among what the inquiry must seek to identify, the inquiry rule (40 CFR part 312) lists

Current and past uses of hazardous substances;

40 CFR 312.20(e)(1)(ii), edition revised as of July 1, 2025

To the extent needed to meet its objectives, the rule has the inquiry include interviews with one or more of three groups. One of them is

Employees of current and past occupants of the subject property.

40 CFR 312.23(c)(3), edition revised as of July 1, 2025

How it is written up

The report describes the shop with the other identified uses and explains any gaps in the history (E1527-21, 8.3.8). The use becomes a finding when the professional judges it may indicate presence or likely presence at the subject property, and the opinion reasons for or against calling it a REC (E1527-21, 12.5, 12.6).

Where the professional concludes a release occurred or is likely, and presence at the subject property follows, the opinion gives the grounds: what the shop used, for how long and when, where its wastes went, what the records and the building show. Unless judged a de minimis condition or a historical REC, the REC is listed in the Conclusions, and the professional should give an opinion on additional investigation, if any (E1527-21, 3.2.20, 3.2.39, 12.7, 12.8).

Where the professional concludes otherwise, the opinion gives its reasoning on the same four facts (E1527-21, 12.6).

Historical sources may fail to show when the shop began or ended. Required information that good faith efforts could not obtain is a data gap, significant if it affects the ability to identify a REC: named in the Findings with the sources consulted, discussed in the Opinions and listed in the Conclusions (E1527-21, 3.2.19, 3.2.78, 12.5.1, 12.6.2, 12.7).

This page is general reference for environmental professionals. It does not classify any property. ASTM E1527-21 is the standard and is not reproduced here; the judgment of the environmental professional on the facts governs.