The interviews section of a Phase I report

The interviews section records who was asked, when, by whom and about what, and what came back, including nothing. For most interviews the standard requires a reasonable attempt, and it says what keeps unanswered questions from leaving the section incomplete.

What the standard requires

Who and when. The report shall identify the person or persons who conducted the interviews and the date or dates (E1527-21, 4.6.1, 12.3). It shall identify the occupants interviewed and how long each has occupied the subject property (E1527-21, 10.5.2.4).
The key site manager. The owner shall be asked, ahead of the site visit, to identify someone who knows the subject property's uses and physical characteristics well. At least one reasonable attempt shall be made to arrange the visit for a time when that person can be there, and if it succeeds the key site manager shall be interviewed with the visit (E1527-21, 10.5.1).
Occupants and past owners. The duty is a reasonable attempt at interviewing a reasonable number of occupants: each one where there are five or fewer, and otherwise the major occupants and those whose operations are likely to point to recognized environmental conditions (E1527-21, 10.5.2, 10.5.2.2). Past owners, operators and occupants likely to have material information shall be interviewed so far as they have been identified and would add to what is already known (E1527-21, 10.5.4).
Officials. The duty is a reasonable attempt at interviewing a staff member of at least one of the four kinds of state or local agency the standard names, the local fire department and a health agency among them (E1527-21, 11.5.1).
What is asked. Questions to owners, operators and occupants shall try to cover the features on the site visit list, the helpful documents and any proceedings (E1527-21, 10.2). Before the site visit the owner, the key site manager and the user shall be asked whether the listed documents exist and whether copies will be provided, and whether they know of litigation, administrative proceedings or government notices about hazardous substances or petroleum products on the property (E1527-21, 10.8, 10.9).
When no answer comes. The person asking has a duty to ask; those asked often have no duty to answer. Where a person other than the user gives no answer or a partial one, the section is not thereby incomplete, provided records were kept of who was asked and what was said, and the request was reasonably followed up at least once (E1527-21, 10.7, 10.7.2). For officials the condition is that the questions were asked, or attempted, in person or by telephone, with written records kept (E1527-21, 11.8). A user who is interviewed is obliged to answer in good faith as far as the user actually knows, or to put forward a key site manager who will (E1527-21, 10.7.1).
An interview that could not be held. The standard's own examples of a data gap include being unable to interview the key site manager or regulatory officials (E1527-21, 3.2.19).

What the federal rule says

The rule names two interviews outright:

The inquiry of the environmental professional must include interviewing the current owner and occupant of the subject property.

40 CFR 312.23(b)

For occupants the standard words its duty as a reasonable attempt (E1527-21, 10.5.2). The rule says the standard's procedures may be used to comply with its sections 312.23 through 312.31 (40 CFR 312.11). The rule does not say what the report records when a question goes unanswered; its paragraphs on data gaps are the nearest (40 CFR 312.20(g), 312.21(c)(2)).

How it is written

The section takes each person in turn: name and role, tie to the subject property and for how long, the date and medium, who asked, what was asked, what was said, and which documents were asked for and received. Attempts that failed are written the same way, with the dates of the request and the follow-up. What a person said is reported as said. What the professional makes of it is for the Findings and Opinions.

Example, with the facts in brackets:

[The person], [the role], who has [owned / occupied / managed] the subject property since [the date], was interviewed by [the interviewer] on [the date] by [the medium]. Asked about [the subjects], [the person] said [the answers]. Asked for the documents listed in this section, [the person] provided [the documents] and said [the others] did not exist or were not available.

Example, with the facts in brackets:

We asked [the person], [the role], for an interview on [the date] by [the medium] and followed up on [the date]. [The person] [did not respond / declined / answered in part]. A record of the request and of the response is in [the appendix]. [What the missing answers mean for the assessment, in the professional's judgment.]

What a reviewer checks

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)?

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.