SBA environmental questionnaire

The Environmental Questionnaire is the form a lender uses, under the Small Business Administration's (SBA) Standard Operating Procedure (SOP) 50 10 8.1, to judge how likely it is that Contamination is present at Property pledged for an SBA-guaranteed loan. It is the lender's to complete or review and the current owner's or operator's to sign. On a 7(a) or 504 loan with no match to an environmentally sensitive industry it may be the first step, and sometimes the only one. This page rests on SOP 50 10 8.1 with Technical Policy Updates, effective October 1, 2026. SBA's lists of procedural and information notices, read October 16, 2026, show none issued after it whose title touches its environmental policies.

Who the rule binds

The lender completes or reviews it, after visiting the Property at least once and making a good faith effort to interview its current owner or operator. An Environmental Professional may help with the answers but need not (SOP 50 10 8.1, Appendix 4, Environmental Questionnaire).
The owner or operator signs. Its signer must be the Property's current owner or operator. If they will not sign, the questionnaire cannot be used, and the lender must then obtain at least a Transaction Screen (SOP 50 10 8.1, Appendix 4, Environmental Questionnaire).
When it starts the investigation. Where no current or known prior use matches an environmentally sensitive industry, or the Property is one unit of a Multi-Unit Building, a loan up to and including $250,000 may begin with a questionnaire, and a loan of more than $250,000 must begin, at a minimum, with a questionnaire and a Records Search with Risk Assessment. A match starts with a Phase I instead (SOP 50 10 8.1, Section A, Ch. 5, Para. E, Environmental Investigation Steps).
Who decides. The lender applies the results under the SOP's steps; requests for exceptions to SBA's environmental policies go to its Environmental Committee (SOP 50 10 8.1, Section A, Ch. 5, Para. E).

What it asks

From the definition (SOP 50 10 8.1, Appendix 4, Environmental Questionnaire):

Date. Within one year of the issuance of the SBA loan number.
False statements. It must carry the language the SOP prints for the purpose, in which the signing owners or operators acknowledge and agree that intentional falsification or concealment of a material fact on its subject may, beyond other penalties, lead to prosecution under applicable law, 18 U.S.C. § 1001 included.
Address and areas of inquiry. The property's address, and at a minimum the areas below. The first nine reach both the Property and the Adjoining Properties:
1. past and present uses, especially uses by environmentally sensitive industries;
2. Hazardous Substances identified there, past and present;
3. Hazardous Substances stored, generated, treated, emitted or disposed of;
4. permits that businesses there hold for using, storing, generating, treating, emitting or disposing of Hazardous Substances;
5. evidence of Contamination;
6. potential sources of Contamination;
7. what the Borrower, the seller or the lender knows of past evidence or sources of Contamination;
8. what they know of lawsuits or administrative proceedings, past, threatened or pending, about a Release or threatened Release;
9. regulatory actions by any Governmental Entity over environmental conditions;
10. environmental risk studies or other environmental documents already prepared on the Property, with copies attached;
11. the presence at the Property of asbestos, lead paint or polychlorinated biphenyls (PCBs).
Sources of Contamination. A footnote to the sixth area gives the SOP's open list: damaged or discarded automotive or industrial batteries; pesticides, paints or other chemicals kept in single containers larger than 5 gallons, or 50 gallons in the aggregate; chemicals in industrial drums or sacks; pits, ponds or lagoons used to dispose of or store waste; fill dirt of contaminated or unknown origin; underground or aboveground storage tanks; fill pipes, vent pipes or access ways that suggest a fill pipe rising out of the ground; floor drains or walls inside a facility that are stained by something other than water or give off noxious odors; clarifiers, pits or sumps; and dry wells.
An alternative form. SBA will accept ASTM Questionnaire A, the Transaction Screen's questionnaire (currently ASTM E1528-22), wherever the SOP requires a questionnaire. ASTM licenses the forms, which are available through www.astm.org.

What follows (SOP 50 10 8.1, Section A, Ch. 5, Para. E, Environmental Investigation Steps):

Contamination unlikely and no further investigation warranted: the lender keeps the results in its file.
Further investigation warranted, at any time: the lender must obtain at least a Records Search with Risk Assessment.
Questionnaire with a records search: a clean questionnaire with a low risk rating puts copies of both in the loan file; any other rating requires a Phase I.

What it means for the Phase I and the consultant

What it is and is not. It is the lender's questionnaire, signed by the owner or operator. The SOP lets an Environmental Professional help but does not require one, and its sentence on the Reliance Letter names Transaction Screens, Phase I and Phase II reports; it does not name the questionnaire (SOP 50 10 8.1, Section A, Ch. 5, Para. E). The questionnaire carries no professional's conclusion: where it shows more is warranted, the next step is at least a records search.
Overlap with a Phase I. Its areas run close to what a Phase I asks the user, asks owners and occupants, and looks for on the site visit (E1527-21, 6.1, 9.4, 10.2). Most footnote sources are site visit items in the Phase I standard: tanks with their vent and fill pipes, drums, pits, ponds and lagoons, drains and sumps, stains and odors, fill of unknown origin, and dry wells (E1527-21, 9.4.12 to 9.4.15, 9.4.20 to 9.4.22, 9.4.25, 9.4.27).
Items mostly outside a Phase I. The questionnaire asks about lead paint, asbestos and PCBs at the Property. The Phase I standard lists among its non-scope considerations asbestos-containing building materials and lead-based paint unrelated to releases, and PCB-containing building materials, but its site visit looks for electrical or hydraulic equipment known or likely to contain PCBs (E1527-21, 9.4.18, 13.1.5.1, 13.1.5.9, 13.1.5.12).
Contamination is SBA's term: Hazardous Substances in quantities or conditions that subject the Property, or potentially subject it, to a Governmental Entity's directive or order (SOP 50 10 8.1, Appendix 4, Contamination). It is not the Phase I standard's recognized environmental condition (E1527-21, 3.2.73).

What the rule says

An SBA Lender or Intermediary must maintain sufficient documentation to demonstrate that Loan Program Requirements have been satisfied.

13 CFR 120.180, edition revised as of January 1, 2025

This page is general reference for environmental professionals. It does not review any loan or project. The regulation and SBA's Standard Operating Procedure are the authority, and the determinations of SBA, or of the lender acting under the authority SBA delegates, govern.