The site reconnaissance section of a Phase I report

The site reconnaissance section records the site visit: who made it and when, how the subject property was covered, what was looked for and found or not found, and what limited the view. The standard requires each of these in the report.

What the standard requires

Who and when. The report shall identify the environmental professional and the person or persons who conducted the site reconnaissance, with the date or dates (E1527-21, 12.3). The date of the visual inspection is one of the dates the report shall identify (E1527-21, 4.6.1). Where someone other than the professional made the visit, that person's qualifications go in the report's appendix (E1527-21, 12.15).
The method. A method for observing the subject property shall be established, such as a grid pattern or other systematic approach on a large property, and shall be documented in the report (E1527-21, 9.2.1).
What was observed. Outside: the periphery of the subject property and of every structure on it, with the property also viewed from adjacent public thoroughfares (E1527-21, 9.2.2). Inside: accessible common areas, places where hazardous substances or petroleum products are stored, used, treated, discharged or disposed of, or may have been, repair and maintenance areas, the boiler room and a representative sample of the spaces occupants use (E1527-21, 9.2.3). Adjoining properties and the surrounding area are observed from the subject property, from public thoroughfares and from buildings entered during the visit (E1527-21, 9.2.5).
Each listed feature, found or not. The standard lists features, activities, uses and conditions to look for. Any that is identified shall be described in the report, and any not found shall be documented as such (E1527-21, 9.4). For containers the report shall include the approximate number, the contents, capacity and type, and the storage conditions; a detailed inventory is not required (E1527-21, 9.4.11, 9.4.15, 9.4.16, 9.4.17). A storage tank's description should include its construction, contents, capacity and age (E1527-21, 9.4.12).
The limits. General limitations and the basis of review shall be noted on the visit and written into the report, including obstructions such as adjacent buildings, water or pavement and constraints such as snow, rain or flooding (E1527-21, 9.2.6). The site visit need not identify what cannot be observed, or what lies under floors, above ceilings, behind walls or on rooftops (E1527-21, 9.2.4).
Site plan and photographs. The report shall include a site plan that shows roughly where the features the professional deems relevant are, and photographs of what indicates a recognized environmental condition (REC) or a de minimis condition. Other representative photographs may be included (E1527-21, 12.3).
An earlier assessment. What a prior assessment's site reconnaissance supplied can guide the visit, but is not to be relied on as showing current conditions (E1527-21, 9.3).
Only in the suggested format. The standard's appendixes are nonmandatory. The suggested report format puts the property's general setting, interior and exterior observations, and what was seen of uses and conditions on the subject property and on adjoining properties in this section, and suggests what the site plan and photograph captions should show (E1527-21, X5.4, X5.12.1, X5.12.2).

What the federal rule says

Of the on-site inspection the rule says:

Physical limitations to the visual inspection must be noted.

40 CFR 312.27(a)(1)

Where no on-site inspection can be made, in the unusual case the rule allows, the inquiry must include, among other things:

Documentation of efforts undertaken to obtain access and an explanation of why such efforts were unsuccessful

40 CFR 312.27(c)(2)

How it is written

The section opens with the visit: date, who made it, under whose charge, and the method. It then reports the exterior, the interior and the adjoining properties, and takes the listed features one by one as found or not found. It closes with what could not be observed and why. The section reports what was seen. What an observation means is for the Findings and Opinions. A part of the subject property that could not be observed may be a data gap (E1527-21, 3.2.19, 12.5.1): see data gap or significant data gap.

Example, with the facts in brackets:

[The person], under the responsible charge of [the environmental professional], visited the subject property on [the date]. The property was covered by [the method]. The following could not be observed: [the areas], because [the reason].

Example, with the facts in brackets:

[The feature] was observed at [the location]: [its description]. See photograph [the number] and the site plan. The following listed features were looked for and not found: [the features].

What a reviewer checks

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)?

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.