What's Included in a Phase 1 ESA Report
A compliant Phase 1 ESA report documents records review findings, site visit observations, interviews, and the environmental professional's REC conclusions, plus the photographs and property boundary map ASTM E1527-21 requires.
A Phase 1 ESA report built to ASTM E1527-21 has to document a specific set of investigative steps, not just deliver a conclusion. Understanding what should be in it makes it easier to spot a thin or rushed report before you rely on it.
The records review section documents which federal, state, and local environmental databases were searched (things like the EPA's Superfund and RCRA databases, and state-level contamination and leaking tank registries) and what, if anything, they turned up for the subject property and nearby properties within the standard's specified search radius. Hazardous waste handler and generator records are one of the record classes 40 CFR 312.26(b)(2) names for that review; for EPA's own national data on the RCRA hazardous waste generator program, and how EPA's inspection and enforcement program is tracking, see EPA RCRA generator statistics. Permitted landfills and solid waste management facilities within a half mile are a separate record class 40 CFR 312.26(c)(3)(ii) names for nearby properties; for GAO's national count of RCRA hazardous waste treatment, storage, and disposal facilities (TSDFs), drawn from EPA's RCRAInfo data, and for why EPA says it can't give a definitive national count of landfills generally, see EPA RCRA TSDF and landfill statistics.
Historical sources, site visit, and interviews
Historical research has to include, at minimum, review of aerial photographs, city directories, topographic maps, and fire insurance maps covering the property's past uses, going back as far as the property's development allows or the standard's lookback requirements call for. The site visit section documents what the environmental professional actually observed: staining, odors, storage tanks, drums, wells, vent pipes, or anything else indicating current or past hazardous substance use.
Interview summaries cover conversations with the current owner or operator, past owners where reachable, and relevant government officials (fire marshals, local environmental agencies) who might know something the records don't show.
Photographs, maps, and the REC conclusion
The 2021 update to the standard made two documentation requirements explicit: every report has to include photographs showing major site features and any REC locations, and a map illustrating the property's boundaries. These used to be common practice but weren't formally required; now they are.
Finally, the report closes with the environmental professional's conclusions: whether any Recognized Environmental Conditions, Historical RECs, or Controlled RECs were identified, whether any significant data gaps affected the ability to reach a conclusion, and, if applicable, a recommendation for further investigation like a Phase 2 ESA.
Is this still what a report needs to include?
Checked live in September 2026: ASTM's product page for E1527-21 still shows it "Standard Active," with E1527-13, E1527-05, E1527-00, and E1527-97 listed as earlier versions. EPA's All Appropriate Inquiries (AAI) guidance names ASTM E1527-21, alongside E2247-23 for forestland or rural property, as a standard that can be used to satisfy AAI requirements.
The report requirements described above, including the photographs and boundary map, are the ones E1527-21 sets.
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