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What a Phase II report contains

ASTM E1903-19 requires a written report. It states the objectives, describes the work and the reasoning behind it, documents the information and data gathered, and gives the Phase II Assessor's results and conclusions against the user's questions (E1903-19, 9.1). The standard sets eight minimum parts and one statement of conformance; beyond those it prescribes no form, and a report that covers the parts complies (E1903-19, 9.2 to 9.2.2). The report must document the assessment in enough detail to permit another assessor to carry it out again with consistent results (E1903-19, 6.4.8).

The minimum parts

A report should show good technical writing, a full and accurate account of results and conclusions, and the supporting parts of a scientific report, and at a minimum it must hold these (E1903-19, 9.2):

  1. An introduction stating the objective, meaning the question to be addressed, and setting out the final Statement of Objectives word for word.
  2. Background information, summarized well enough to explain and support the approach.
  3. The work performed and why, with any deviation from the sampling plan and whether it substantially affects meeting the objectives.
  4. The methods used.
  5. The information and data acquired.
  6. An evaluation of that information and data.
  7. An interpretation of the results against the objectives, the questions and the conceptual model.
  8. The Phase II Assessor's signature, together with any professional seal, and the license type and number, where the local jurisdiction or the user requires them.

Tables, figures and appendices should be used as needed to give a clear and complete picture, and a report's detail depends on its setting: how complex the site and the work are, how many separate areas were assessed, and the detail or precision the user needs (E1903-19, 9.2, 9.2.3).

What other sections add

  • Insufficient data. The report must disclose every respect in which the available data fall short of the objectives (E1903-19, 1.3.2).
  • Areas not assessed. If the objectives require investigating only some releases or likely release areas, the report shall make clear that a conclusion ending further inquiry concerns only those investigated (E1903-19, 8.1.4).
  • Objectives not met. If the assessment falls short of the Statement of Objectives, whatever the reason, the results must be read against the objectives, and any gap between the two described and evaluated (E1903-19, 8.1.5).
  • Conclusions. They must answer the questions the assessment set out to address, or state clearly why they cannot be answered and what, if anything, can still be concluded (E1903-19, 6.4.7). Results must be interpreted, and conclusions stated, in light of the sampling rationale actually followed (E1903-19, 7.5).
  • Limits on the work. The Statement of Objectives must describe any schedule, cost or budget limits, so the word-for-word Statement in the introduction carries them into the report (E1903-19, 5.1.2, 9.2).
  • Laboratory problems. The Phase II Assessor should identify, in reports to the user, problems the laboratory reported (E1903-19, 4.2.1.3).

The statement of conformance

Where every element of the standard is followed, the report shall include a statement naming the property's address, saying a Phase II was performed there in conformance with E1903 within its scope and limitations, and listing the objectives from the Statement of Objectives (E1903-19, 9.2.1).

What is left to the user

The standard offers no way to drop one of the eight parts; they are what every report must include (E1903-19, 9.2). Its nonmandatory appendixes leave the user some choices:

  • Recommendations. The report formats appendix lets the user decide whether the report recommends further work, consistent with the objectives (E1903-19, X3.2.9). The contracting appendix suggests the agreement consider whether recommendations should be given apart from the report (E1903-19, X2.1.1).
  • Documentation and review. The contracting appendix suggests agreeing on what documentation will be produced, considering attorney-client, work product and self-evaluation privileges, and defining any user review before the report becomes final (E1903-19, X2.1.1).
  • Executive summary. The report formats appendix makes it optional in its fuller format, and says it should be a short overview of objectives and findings, not a copy of the conclusions, with nothing the body lacks (E1903-19, X3.2.2).

The two optional formats

Appendix X3 is nonmandatory; it says a report in any format complies if it carries the minimum parts (E1903-19, X3 introduction).

  • Option A in the appendix, usually a letter and so without a table of contents, carries the Statement of Objectives with brief background; the scope of work with the conceptual model and the reasons for the work; the sampling activities and locations; the analytical data; an interpretation against the model leading to conclusions; figures and tables as needed; and the signature (E1903-19, X3.1.1 to X3.1.8).
  • Option B in the appendix is a fuller report: transmittal letter, title page and contents page; an optional executive summary; introduction, background, work performed and rationale, results, interpretation and conclusions, and recommendations at the user's option; then references, tables, figures and appendices, with an example table of contents (E1903-19, X3.2 to X3.4).

For Option B, the appendix asks that:

  • the introduction name items a reader might have expected in scope but that were left out, such as likely release areas not addressed, and why (E1903-19, X3.2.4);
  • standard methods be cited where they apply, and others described well enough for another Phase II Assessor to repeat them (E1903-19, X3.2.6.1);
  • the physical features found be reconciled with the model's assumptions, and the substances detected with those predicted (E1903-19, X3.2.7.1, X3.2.7.3);
  • tables of analytical data show any numerical criteria that bear on the objectives (E1903-19, X3.3.1.1);
  • the conclusions state clearly whether the objectives were met, and explain deviations and limits and their effect on the confidence in, or completeness of, the conclusions (E1903-19, X3.2.8.3);
  • appendices contain any boring logs, laboratory reports and associated validation package generated during the assessment (E1903-19, X3.3.2).

Related

This page is general reference for environmental professionals. It does not assess any property. ASTM E1903-19 is the standard and is not reproduced here; the judgment of the Phase II Assessor on the facts governs.

Maintained by Barrow. General reference only, not legal or professional advice. Barrow is not affiliated with any government agency, and neither Barrow nor the information as presented here is endorsed by any state or government agency. See how Barrow drafts the report