The environmental professional's statement and signature

The report says who stands behind it. The standard requires the responsible environmental professional to sign the report and to include two statements that the federal rule requires. The rule gives their words, and it is the rule's words that are quoted on this page.

What the standard requires

The signature. The report shall be signed by the environmental professional or professionals responsible for the assessment (E1527-21, 12.13).
Two statements. As the federal rule requires, the report shall include two statements by the professional or professionals responsible for conducting the assessment and preparing the report (E1527-21, 12.14). The first declares that, to the best of their professional knowledge and belief, they meet the rule's definition of an environmental professional. The second declares that their education, training and experience qualify them to assess a property with the subject property's nature, history and setting, and that they developed and performed the inquiry in conformance with the rule (E1527-21, 12.14.1, 12.14.2).
Who did the work, and when. The report shall identify the environmental professional and the person or persons who conducted the site visit and the interviews, with the dates of each (E1527-21, 12.3).
Qualifications. The report shall include, in an appendix section, the qualifications of the environmental professional, and those of whoever conducted the site visit and interviews if that was someone else (E1527-21, 12.15).
The date of the declaration. The declaration is one of the components whose dates shall be identified in the report (E1527-21, 4.6.1). It is also among the components the standard says must be conducted, or updated, inside the 180 days before the date of acquisition or of the transaction (E1527-21, 4.6.2).
Who an environmental professional is. The standard takes the definition from the rule, and says the person may be the user's employee or an independent contractor (E1527-21, 3.2.30). It says the assessment must be conducted by that person, or under that person's supervision or responsible charge, and that the professional shall review and interpret the information behind the findings, opinions and conclusions (E1527-21, 7.5.1).
Only in the suggested format. The standard's appendixes are nonmandatory. The suggested report format gives the statement and signatures a section of their own (E1527-21, X5.10). Sections 12.13 and 12.14 do not say where in the report they go.

What the federal rule says

The rule requires the environmental professional to place two statements in the written report and to sign it (40 CFR 312.21(d)). The first:

[I, We] declare that, to the best of [my, our] professional knowledge and belief, [I, we] meet the definition of Environmental Professional as defined in § 312.10 of this part.

40 CFR 312.21(d)

The second:

[I, We] have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. [I, We] have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312.

40 CFR 312.21(d)

The written report the rule requires also includes the qualifications of the environmental professional or professionals (40 CFR 312.21(c)(3)). And the rule puts "The declaration by the environmental professional" among the components that "must be conducted or updated within 180 days of and prior to the date of acquisition of the subject property" (40 CFR 312.20(b)).

How it is written

The two statements are set out in full, with I or We and my or our chosen to fit the signers. Each responsible environmental professional signs (E1527-21, 12.13, 12.14).

The standard words the two statements itself, at 12.14.1 and 12.14.2, and that wording is not reproduced on this page. Its first statement ends by citing the rule by number where the rule's text says "of this part" (E1527-21, 12.14.1; 40 CFR 312.21(d)). The rule names the standard's procedures as one way to meet its sections 312.23 through 312.31 (40 CFR 312.11); the two statements are in section 312.21. This page does not say which wording a report uses.

With the statements go the facts the standard requires the report to identify: who the environmental professional is, who conducted the site visit and the interviews, the dates of both, and the date of the declaration (E1527-21, 4.6.1, 12.3). Qualifications go in an appendix (E1527-21, 12.15).

Example, with the facts in brackets:

[The two declarations, with I or We chosen.] Signed: [signature of the responsible environmental professional]. Name: [name]. Date of this declaration: [the date]. Site visit conducted by [name] on [the date]; interviews conducted by [name] on [the dates]. Qualifications: see [the appendix].

What a reviewer checks

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)?

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.