Limiting conditions and deviations in a Phase I report

A Phase I report says what was done, what limited the work, and where the work departed from the standard. The standard requires a description of the services performed, an individual and detailed list of limiting conditions, deletions and deviations, and a list of additions.

What the standard requires

Scope of services. Every service performed shall be described, in detail enough that another party could reconstruct the work (E1527-21, 12.4).
Limiting conditions, deletions and deviations. Where there are any, the report shall list each one individually and in detail, constraints imposed by the user among them (E1527-21, 12.11). The standard's definitions do not include any of the three terms.
Additions. All additions shall be listed (E1527-21, 12.11).
Additional services. Services the user and the environmental professional contract for on top of the practice, a broader scope of assessment for one, are beyond its scope. The standard says they should be in the report only if the terms of engagement specify it (E1527-21, 12.10). Whether to look into non-scope considerations should be agreed between the user and the professional, as additional services, before the assessment starts (E1527-21, 1.4).
Limits of the site visit. General limitations and the basis of review shall be noted on the site visit and then documented in the report. The standard counts limits set by physical obstructions and by other physical constraints among them (E1527-21, 9.2.6). The method of observation shall be documented in the report too (E1527-21, 9.2.1).
Reasons the standard requires by name. The report shall explain the justification for each adjustment of a search distance and the distance actually used (E1527-21, 8.1.2.1). Where the professional's opinion is that a regulatory file review is not warranted, the professional must explain the justification in the report (E1527-21, 8.2.3.1). Where one of four named historical resources is not reviewed, the professional shall say why in the report, and where data failure is met the report shall document it (E1527-21, 8.3.6, 8.3.8). The report shall give the reasons for leaving documentation out (E1527-21, 12.2).
The pointer in the closing statement. The closing statement required under the Conclusions provision says which section of the report describes exceptions to, and deletions from, the practice (E1527-21, 12.7.1, 12.7.2).
Only in the suggested format. The standard's appendixes are nonmandatory. The suggested report format has an Introduction where contractual details can be discussed, scope of work among them, together with the limiting conditions, the deviations and exceptions, and any significant assumptions or special terms. It has a section for non-scope services, if needed, and it puts deletions with the Findings and Opinions (E1527-21, X5.2, X5.7, X5.8).

What the federal rule says

The rule does not speak of limiting conditions, deletions or deviations. On the site inspection it says:

Physical limitations to the visual inspection must be noted.

40 CFR 312.27(a)(1)

And of a search distance the professional changes:

The rationale for such modifications must be documented by the environmental professional.

40 CFR 312.26(d)

How it is written

The scope of services says what was done in enough detail for the work to be reconstructed (E1527-21, 12.4). The list has one entry for each limiting condition, each deletion and each deviation, with its detail (E1527-21, 12.11). Additions are listed too (E1527-21, 12.11).

The standard gives limiting conditions and significant data gaps separate requirements. The first are listed individually and in detail (E1527-21, 12.11). The second are identified in the Findings, with what was consulted to address them (E1527-21, 12.5.1). Neither provision says that one entry stands in for the other.

Example, with the facts in brackets:

Limiting condition [number]: [what limited the work], on [the date], affecting [the part of the practice, by section]. Imposed by [the user, site conditions or another cause]. [What was done in its place, if anything.]

Example, with the facts in brackets:

Deviation [or deletion] [number]: [the step of the practice, by section] was [not performed / performed differently, and how]. Reason: [the reason]. Addition [number]: [the additional service], provided under [the terms of engagement].

What a reviewer checks

Does the report describe every service performed in enough detail for another party to reconstruct the work (E1527-21, 12.4)?
Are the limiting conditions, deletions and deviations listed one by one and in detail (E1527-21, 12.11)?
Are user-imposed constraints listed among them (E1527-21, 12.11)?
Are the additions listed, and does the report show that the terms of engagement specify each additional service it holds (E1527-21, 12.10, 12.11)?
Are the limits of the site visit documented (E1527-21, 9.2.6)?
Where a search distance was adjusted, a regulatory file review was judged not warranted, or one of the standard's four named historical resources was not reviewed, does the report give the reason (E1527-21, 8.1.2.1, 8.2.3.1, 8.3.8)?
Does the section named in the closing statement describe the exceptions and deletions (E1527-21, 12.7.1, 12.7.2)?

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.