The records review section of a Phase I report

The records review section shows which records were checked, how far each search reached, and what each listing means for the subject property. The standard requires every source checked to be documented, findings or none, well enough that another environmental professional could reconstruct the work.

What the standard requires

Every source checked. The report shall document each source checked, even one that revealed no findings. The documentation is to be sufficient and to include the source's name, the date the request for information was filled, the date the source last updated the information and, where it came through another party, the date the original source last updated it (E1527-21, 8.1.9). Supporting documentation shall be in the report or adequately referenced, so that another professional could reconstruct the assessment (E1527-21, 8.1.9, 12.2).
Search distances, and any change to them. Distance is measured from the subject property's nearest boundary (E1527-21, 8.1.2). Where the professional adjusts a distance, the report shall explain the justification for each adjustment and the distance actually used for that record (E1527-21, 8.1.2.1). The distances for the federal Superfund list and for federal treatment, storage and disposal facilities may not be reduced, and a search set at the subject property only may not be reduced unless the record is not reasonably ascertainable (E1527-21, 8.1.2.1, 8.2.2). The distances are on how far each database search reaches.
The significance of each listing. Where a source lists the subject property, or another site inside the search distance, the report shall give the professional's judgment of what the listing signifies for the analysis of recognized environmental conditions (RECs). One statement may cover several sites (E1527-21, 8.1.10).
Agency file reviews. For a listed subject property or adjoining property the file should be reviewed. If the professional's opinion is that a review is not warranted, the report must explain the justification (E1527-21, 8.2.3.1). Where a file or another source is reviewed, a summary of what was obtained shall be in the report, with the professional's opinion on whether it is sufficient to judge whether a REC, a controlled or historical REC, or a de minimis condition exists (E1527-21, 8.2.3.2).
A source that cannot be had. Records are required only where reasonably ascertainable. An alternative source may be used, and where neither kind can reasonably be had the professional shall attempt to get the information by the practice's other means, such as questions to the owner or occupants (E1527-21, 8.1.4, 8.1.6, 8.1.7).
Physical setting. A topographic map shall be reviewed, and displayed at a scale at which the contour labels can be read (E1527-21, 8.2.1).
History of uses. The report shall set out every use of the subject property that was identified, give the grounds for the earliest date of first developed use, and say why any gap in the history is there. Where aerial photographs, fire insurance maps, street directories or historical topographic maps were not reviewed, the report shall say why (E1527-21, 8.3.8). It shall describe the obvious uses identified for adjoining properties, with the earliest dates (E1527-21, 8.3.9). A data failure shall be documented (E1527-21, 8.3.6). Historical resources shall be referenced well enough for another professional to reconstruct the research (E1527-21, 8.5).
Only in the suggested format. The standard's appendixes are nonmandatory. The suggested report format says this section should be split into physical setting, historical records review and regulatory records review (E1527-21, X5.5).

What the federal rule says

The rule does not say how the report lists its sources. On a changed search distance it says:

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

40 CFR 312.26(d)

How it is written

The section runs from the sources to what they mean: the sources checked, each with its dates; the search distances and any change, with reasons; the listings, each with the professional's judgment of its significance; the file reviews; the physical setting; the history of uses. What a record says is reported as the record says it. The judgment of its significance is marked as the professional's. Whether a listing becomes a finding is for the Findings section.

Example, with the facts in brackets:

The search distance for [the record type] was reduced from [the standard distance] to [the distance used] because [the reason].

Example, with the facts in brackets:

[The listed site], [the distance and direction] from the subject property, appears on [the list], as updated by its source on [the date]. The agency file, reviewed on [the date], shows [what the file shows]; in our opinion that is [sufficient / not sufficient] to evaluate the listing. [Or: the file was not reviewed, because of the reason given.] Our judgment of the listing's significance: [the judgment and its reasons].

What a reviewer checks

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)?

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.