Conducting Interviews with Property Owners and Occupants for a Phase I ESA

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Conducting Interviews with Property Owners and Occupants for a Phase I ESA

Environmental consultant conducting Phase I ESA interview with property owner discussing site history and potential contamination

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Conducting interviews with property owners, occupants, and other knowledgeable parties is a critical component of a Phase I Environmental Site Assessment (ESA). While records review and site reconnaissance provide essential data, interviews often uncover hidden or undocumented environmental risks that would otherwise go undetected.

Under recognized standards such as ASTM E1527-21 and regulatory frameworks like Ontario Regulation 153/04, interviews are considered a standard historical use resource. This means they are not optional—they are a required part of due diligence.

This guide provides a comprehensive, practical framework for conducting, documenting, and leveraging interviews to identify Recognized Environmental Conditions (RECs) and strengthen the overall quality of your Phase I ESA.

Purpose and Objectives of Interviews

The primary purpose of interviews is to gather first-hand knowledge about the property that may not be available through traditional sources such as aerial photographs, fire insurance maps, or regulatory databases.

Why Interviews Matter

Even the most thorough records review can miss:

  • Informal or undocumented activities
  • Historical practices predating regulations
  • Minor spills that were never reported
  • Changes in operations that were not formally recorded

Interviews help bridge these gaps by providing context and nuance.

Key Objectives

The environmental professional (EP) conducts interviews to:

  • Identify past and current uses of the property
  • Detect potential contaminating activities (PCAs)
  • Confirm or challenge findings from records review
  • Identify storage, handling, or disposal of hazardous materials
  • Understand site-specific operational practices
  • Gather insight into adjacent property risks

Ultimately, interviews support the identification of:

  • Recognized Environmental Conditions (RECs)
  • Historical RECs (HRECs)
  • Controlled RECs (CRECs)

Interview Procedure

A structured and well-executed interview process ensures consistency, defensibility, and regulatory compliance.

1. Identify Knowledgeable Parties

The value of an interview depends heavily on who you speak with.

Primary Contacts

  • Current property owner
  • Current occupants or tenants

Secondary Contacts

  • Past owners or operators
  • Facility managers
  • Long-term employees
  • Maintenance personnel

In industrial or commercial settings, long-term staff often provide the most accurate operational history.

2. Timing of Interviews

Interviews should be conducted strategically within the ESA workflow.

Best Practice Timing:

  • After initial records review
  • Before or during site reconnaissance

This allows the EP to:

  • Ask targeted questions
  • Validate historical findings
  • Identify areas requiring closer inspection

3. Preparation

Preparation is essential for effective interviews.

Key Preparation Steps:

  • Develop a standardized questionnaire
  • Review available records beforehand
  • Identify potential areas of concern
  • Tailor questions to property type (industrial, commercial, residential)

Setting Expectations

It is important to clearly communicate that:

  • The interview is part of due diligence
  • The goal is to understand environmental history
  • The process is not about assigning blame or liability

This helps build trust and encourages open communication.

4. Conducting the Interview

Effective interviews are:

  • Structured but conversational
  • Open-ended rather than leading
  • Focused on facts and observations

Tips for Success:

  • Ask follow-up questions
  • Clarify vague answers
  • Cross-check responses with known data
  • Observe non-verbal cues or hesitation

5. Documentation

Proper documentation is essential for compliance and defensibility.

The EP must record:

  • Name of interviewee
  • Role/relationship to the property
  • Date of interview
  • Method (in-person, phone, email)
  • Summary of responses

Incomplete documentation can weaken the credibility of the ESA.

Key Interview Questions

The goal of interview questions is to uncover potential contaminating activities (PCAs) and identify environmental risks.

Below is a structured set of essential questions.

1. Past and Present Uses

Understanding historical land use is fundamental.

Sample Questions:

  • What are the current uses of the property?
  • What were the past uses of the property?
  • Have there been any major changes in operations or ownership?
  • Was the property ever used for industrial or commercial purposes?

2. Hazardous Materials

Identify whether hazardous substances have been handled on-site.

Sample Questions:

  • Are hazardous materials currently used or stored on-site?
  • Were hazardous materials used in the past?
  • How were these materials stored and handled?
  • Were safety or containment measures in place?

3. Storage Tanks (ASTs and USTs)

Storage tanks are a common source of contamination.

Sample Questions:

  • Are there any aboveground storage tanks (ASTs)?
  • Have there been underground storage tanks (USTs)?
  • What substances were stored?
  • What are the tank capacities and ages?
  • Have any leaks or failures occurred?

4. Spills and Releases

Unreported spills are often revealed through interviews.

Sample Questions:

  • Have there been any spills or releases?
  • Were they reported to authorities?
  • What remediation actions were taken?
  • Are there any known residual impacts?

5. Environmental Reports and Regulatory History

Previous studies can provide valuable insight.

Sample Questions:

  • Are you aware of previous environmental site assessments?
  • Have there been remediation projects?
  • Has the property been subject to regulatory orders or inspections?

6. Site Observations

Interviewees may notice conditions others overlook.

Sample Questions:

  • Have you observed staining, odors, or unusual conditions?
  • Are there any unidentified pipes or structures?
  • Have there been issues with vegetation or soil conditions?

7. Waste Management Practices

Improper disposal is a key risk factor.

Sample Questions:

  • How is waste handled and disposed of?
  • Were hazardous wastes generated?
  • Were disposal practices compliant with regulations?

8. Adjacent Properties

Contamination can migrate from neighboring sites.

Sample Questions:

  • Are you aware of nearby industrial or commercial activities?
  • Have neighboring properties caused concerns?
  • Are there nearby gas stations, dry cleaners, or factories?

Reporting Requirements

Interview findings must be clearly and thoroughly documented in the Phase I ESA report.

1. Identify Interviewees

The report must include:

  • Names
  • Titles/roles
  • Affiliations

This establishes credibility and traceability.

2. Summarize Information

Provide a clear and concise summary of:

  • Historical uses
  • Hazardous materials
  • Spills or releases
  • Site conditions

Focus on relevant environmental information, not general commentary.

3. Address Data Gaps

If interviews are:

  • Not conducted
  • Incomplete
  • Unavailable

They must be identified as data gaps.

The EP must also assess:

  • How the gap impacts conclusions
  • Whether it limits the ability to identify RECs

4. Integrate Findings

Interview data should not stand alone.

It must be integrated with:

  • Records review
  • Site reconnaissance

Together, these form the basis for identifying RECs.

5. Include Dates

The report must document:

  • When interviews were conducted

This is critical because:

  • Phase I ESAs have a 180-day validity window
  • Interviews are one of the components that must be updated if the report is extended

Best Practices for Effective Interviews

Beyond compliance, high-quality interviews can significantly enhance your ESA.

1. Use Open-Ended Questions

Avoid yes/no questions when possible.

Instead of:

  • “Were there spills?”

Ask:

  • “Can you describe any incidents involving spills or releases?”

2. Corroborate Information

Always cross-check interview responses with:

  • Historical records
  • Regulatory databases
  • Site observations

3. Be Neutral and Professional

Maintain objectivity:

  • Do not suggest answers
  • Avoid leading questions
  • Document facts, not opinions

4. Build Rapport

People are more forthcoming when they feel comfortable.

  • Be transparent about your purpose
  • Listen actively
  • Avoid technical jargon when unnecessary

5. Follow Up

If new information emerges:

  • Conduct follow-up interviews
  • Request supporting documentation

Common Challenges and How to Address Them

1. Limited Knowledge

Some interviewees may lack historical knowledge.

Solution:

  • Seek additional contacts
  • Use multiple sources

2. Reluctance to Share Information

Concerns about liability can limit disclosure.

Solution:

  • Emphasize the purpose is due diligence
  • Maintain a neutral tone

3. Conflicting Information

Different sources may provide inconsistent accounts.

Solution:

  • Document discrepancies
  • Rely on corroborating evidence

4. Unavailable Interviewees

Sometimes key individuals cannot be reached.

Solution:

  • Document attempts
  • Identify as a data gap
  • Supplement with other sources

The Role of Interviews in Identifying RECs

Interviews play a direct role in identifying:

  • Recognized Environmental Conditions (RECs)
  • Historical RECs (HRECs)
  • Controlled RECs (CRECs)

They often:

  • Confirm suspected risks
  • Reveal previously unknown issues
  • Provide context for ambiguous findings

Integrating Interviews into Your ESA Workflow

To maximize effectiveness, interviews should be fully integrated into your workflow:

  1. Conduct records review
  2. Identify potential concerns
  3. Prepare targeted questions
  4. Conduct interviews
  5. Perform site reconnaissance
  6. Correlate findings
  7. Document and report

Practical Example

Consider a commercial property where:

  • Records show limited historical use
  • Site reconnaissance reveals no obvious contamination

However, during an interview:

  • A long-term employee mentions a former underground storage tank removed in the 1980s
  • No documentation exists

This information could:

  • Trigger further investigation
  • Lead to identification of a REC
  • Influence property transaction decisions

Without the interview, this risk may have been missed entirely.

Conclusion

Conducting interviews with property owners and occupants is not just a procedural requirement—it is a critical investigative tool in a Phase I ESA.

By aligning with standards such as ASTM E1527-21 and regulations like Ontario Regulation 153/04, environmental professionals can ensure their assessments are:

  • Thorough
  • Defensible
  • Compliant
  • Insightful

Key Takeaways

  • Interviews are a mandatory and valuable component of Phase I ESAs
  • They uncover information not available through other sources
  • Proper preparation and documentation are essential
  • Findings must be integrated into the overall assessment
  • Data gaps must be clearly identified and addressed

Final Thought

In many cases, the most critical environmental insights don’t come from databases or reports—they come from people with direct knowledge of the site.

A well-conducted interview can be the difference between:

  • Missing a significant environmental risk
  • And identifying a critical issue before it becomes a liability

For environmental professionals, mastering the interview process is not just best practice—it’s essential.

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