Review checklist for a Phase I report

A reviewer reading a draft Phase I report can test it against the standard one part at a time. Each question below is a requirement of ASTM E1527-21 or of the federal inquiry rule, or something the standard or its nonmandatory appendix says should be done, turned into a question to put to the report or, for a record the standard says is kept, to the file behind it.

The questions are grouped by the part of the report they belong to. Each group comes from this handbook's page on that part, which explains what stands behind every question. Where a group rests on the appendix and not on a requirement, the group says so. REC stands for recognized environmental condition, CREC and HREC for a controlled and a historical one, and AUL for activity and use limitation.

The list tests whether the report holds what the standard and the rule ask of it. It does not test whether the environmental professional's judgment on the facts is right, and it does not cover what a client, a lender or a state program adds to the standard.

What a Phase I report must contain

Is there a references section that identifies the published sources relied on (E1527-21, 12.12)?
Is each referenced source annotated well enough for another party to retrieve it (E1527-21, 12.12)?
Is there an appendix section that contains the supporting documentation (E1527-21, 12.15)?

The Findings section of a Phase I report

Does the report have a Findings section (E1527-21, 12.5)?
Does the section identify the features, activities, uses and conditions themselves (E1527-21, 12.5)?
Is every significant data gap identified in the Findings, with what was consulted to address it (E1527-21, 12.5.1)?
Is each finding supported by documentation that is in the report or adequately referenced, with a reason given for anything left out (E1527-21, 12.2)?
Are photographs included of what indicates a REC or a de minimis condition, and is there a site plan (E1527-21, 12.3)?
Is each finding covered by an opinion and its rationale (E1527-21, 12.6)?

The Opinions section of a Phase I report

Is every finding covered by an opinion with its supporting rationale (E1527-21, 12.6)?
Is the logic and reasoning discussed, and not only a class named (E1527-21, 12.6)?
For each class a finding pertains to, does the opinion say why the finding does or does not fall in it (E1527-21, 12.6)?
For a CREC, does the reasoning discuss how the release was addressed to the regulatory authority's satisfaction, and identify the limitation relied on and the documentation that provides the control (E1527-21, 12.6.1, 3.2.17.1)?
For an HREC, do the Findings and Opinions give the rationale for calling it one (E1527-21, 3.2.39.1)?
For each significant data gap, does the Opinion section say how the missing information affects the ability to give an opinion (E1527-21, 12.6.2)?
Is there an opinion on additional appropriate investigation, if any (E1527-21, 12.8)?

The Conclusions section of a Phase I report

Does the report have a Conclusions section (E1527-21, 12.7)?
Does the section list every REC and CREC the Opinions name, and every significant data gap the Findings identify (E1527-21, 12.7)?
Does the report carry one of the standard's two closing statements, or one substantially similar (E1527-21, 12.7)?
Does the statement identify the subject property by address or legal description, and name the section that describes exceptions and deletions (E1527-21, 12.7.1, 12.7.2)?
Is each listed item supported by documentation, with its rationale in the Opinions (E1527-21, 12.2, 12.6)?

Recommendations in a Phase I report

Does the report give the professional's opinion on additional appropriate investigation, if any (E1527-21, 12.8)?
If the report holds recommendations, does it show that the terms of engagement specify them (E1527-21, 12.10)?
Are all additions listed (E1527-21, 12.11)?
For each significant data gap, does the report discuss whether more information would likely help (E1527-21, 12.6.2)?

Limiting conditions and deviations in a Phase I report

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)?

The environmental professional's statement and signature

Is the report signed by the environmental professional or professionals responsible for the assessment (E1527-21, 12.13)?
Does it carry both statements the federal rule requires (E1527-21, 12.14; 40 CFR 312.21(d))?
Does it identify the environmental professional and the persons who conducted the site visit and the interviews, with the dates (E1527-21, 12.3)?
Is the date of the declaration identified (E1527-21, 4.6.1)?
Does an appendix hold the qualifications of the environmental professional, and of others who conducted the site visit and interviews (E1527-21, 12.15)?

User-provided information in a Phase I report

Does the report state whether the user reported information under the user's responsibilities (E1527-21, 7.3.2, 12.3)?
Does it say whether the professional received the results of the lien and AUL search, and whether the user identified any (E1527-21, 6.2.3.2)?
Where the user named no purpose, does the report state the purpose assumed (E1527-21, 6.8)?
Where the user did not provide the information, does the report show the professional considered what its absence means (E1527-21, 6.1)?
Where the professional made the lien search for the user, is its date in the report (E1527-21, 4.6.1)?

The records review section of a Phase I report

Is every source checked documented, including those with no findings, with its name and dates (E1527-21, 8.1.9, 12.2)?
Is the supporting documentation included or referenced so that another professional could reconstruct the review (E1527-21, 8.1.9, 12.2)?
For each changed search distance, are the justification and the distance used stated (E1527-21, 8.1.2.1; 40 CFR 312.26(d))?
Does each listing of the subject property, or of a site within its search distance, carry the professional's judgment on its significance (E1527-21, 8.1.10)?
For each listed subject property or adjoining property, is there a file review summary with a sufficiency opinion, or the justification for no review (E1527-21, 8.2.3.1, 8.2.3.2)?
Are the identified uses described, the earliest date justified, gaps explained, and a reason given for any of the standard's four named historical resources not reviewed (E1527-21, 8.3.8)?

The site reconnaissance section of a Phase I report

Does the report name who made the site visit and give its date (E1527-21, 4.6.1, 12.3)?
Is the method of observation documented (E1527-21, 9.2.1)?
Is each feature the standard lists either described or documented as not found (E1527-21, 9.4)?
Are the limitations on the visit documented (E1527-21, 9.2.6; 40 CFR 312.27(a)(1))?
Is there a site plan, and are there photographs of what indicates a REC or a de minimis condition (E1527-21, 12.3)?
Where the visit was made by someone other than the professional, are that person's qualifications in the appendix (E1527-21, 12.15)?
Where an earlier assessment's site reconnaissance is drawn on, is it used for guidance only (E1527-21, 9.3)?

The interviews section of a Phase I report

Are the persons who conducted the interviews, and the dates, identified (E1527-21, 4.6.1, 12.3)?
Are the occupants interviewed identified, with how long each has been in occupancy (E1527-21, 10.5.2.4)?
Does the report show the owner was asked to identify a key site manager, and the attempt to interview that person (E1527-21, 10.5.1)?
Were the owner, the key site manager and the user asked for the documents the standard lists and about proceedings (E1527-21, 10.8, 10.9)?
Where a person other than the user gave no answer or a partial one, is there a record of who was asked and what was said, and of a follow-up (E1527-21, 10.7.2)?
Was an attempt made to interview an official of one of the four kinds of agency the standard names (E1527-21, 11.5.1)?

The executive summary of a Phase I report

The first four checks rest on what the nonmandatory appendix says a summary should do; none is a requirement of the standard. The last two rest on its body.

Is everything in the summary also found elsewhere in the report (E1527-21, X5.1.3)?
Does the summary give the key evidence for each class and each significant data gap it names (E1527-21, X5.1)?
If it has a summary table, is the basis of the findings explained beside it (E1527-21, X5.1.1)?
Is it, in general, no more than two pages (E1527-21, X5.1.1)?
Does the report still carry its Findings, Opinions and Conclusions sections and the professional's statement (E1527-21, 12.5, 12.6, 12.7, 12.14)?
Does the report show that the terms of engagement specify any recommendations it holds (E1527-21, 12.9, 12.10)?

Dates in a Phase I report

Are the dates of the interviews, the government records review, the visual inspections and the declaration identified in the report (E1527-21, 4.6.1)?
Where the professional made the lien search, is its date identified (E1527-21, 4.6.1)?
Are the dates of the site reconnaissance and the interviews given, with who conducted them (E1527-21, 12.3)?
Does each source checked show the date the request was filled and the date the source last updated its information (E1527-21, 8.1.9)?
Does the report keep its date out of any 180-day or one-year test (E1527-21, 4.6.3)?
Where an earlier assessment's information is used, does the report show a current investigation of conditions (E1527-21, 4.7.1)?

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.

Review checklist for a Phase I report

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