Transaction Screen Assessment

Short answer: A transaction screen assessment is limited environmental due diligence under ASTM E1528-22: a two-part questionnaire, a site visit and a records review that flag potential environmental concerns. It does not satisfy All Appropriate Inquiries or give Superfund (CERCLA) liability protection. SBA SOP 50 10 8.1 requires at least a screen when the current owner or operator will not sign the Environmental Questionnaire, and adds an Environmental Professional’s conclusion.

What ASTM E1528-22 requires: questionnaire, site visit and records review

ASTM E1528-22, the Standard Practice for Limited Environmental Due Diligence: Transaction Screen Process, is the 2022 revision of a standard first published in 1993, with a rewritten questionnaire and wording that stresses a screen gives no protection under CERCLA, the federal Superfund law (ASTM, August 2022).

The questionnaire has two parts (ASTM E1528-22, Sections 5.1 and 5.2):

• Part A goes to the current owner, any major occupant (one using at least 40% of the leasable area, or a shopping center’s anchor tenant) or, if there is none, at least 10% of the occupants, and any occupant or operator likely to handle chemicals of concern. The preparer may collect the answers by interview.
• Part B is completed by the preparer, the person conducting the screen: a site visit inside and outside the buildings with a brief look at adjoining properties, interviews, and limited research of certain government records and standard historical sources, where reasonably ascertainable.

The goal is to identify potential environmental concerns: the possible presence of hazardous substances or petroleum products under conditions that suggest an existing, past or threatened release. ASTM states that this scope is not sufficient to identify Recognized Environmental Conditions (RECs), the findings of a Phase I under ASTM E1527-21, and that a screen will not satisfy the All Appropriate Inquiries (AAI) rule at 40 CFR Part 312. Anyone seeking a CERCLA landowner liability protection is directed to a Phase I (ASTM E1528-22, Sections 1.1 and 4.2).

ASTM does not require an Environmental Professional (EP), a person who meets 40 CFR 312.10: the equivalent of 3 years of full-time relevant experience with a qualifying license, 5 with an engineering or science degree, or 10 without either. Under Section 4.3 the user, a lender, broker, appraiser, lawyer or consultant may conduct the screen, and an EP who prepares one need not give opinions. Some government programs add a professional-opinion requirement; the SBA is one.

Properties an environmental transaction screen does not fit

The standard warns that a screen is generally unsuitable where large volumes of chemicals are or were used, stored or disposed of: manufacturing, vehicle fueling, dry cleaning, metal plating and finishing, circuit board manufacturing, junkyards and landfills. Ruling out a concern on those properties normally takes an EP and a Phase I (Note 1). The standard says a screen may be especially appropriate for rural, non-industrial or undeveloped property, or, if the lender’s criteria allow, for a loan on property expected to have few environmental concerns (Section 1.3.2).

The SBA rules point the same way. If the current or a known prior use matches an environmentally sensitive NAICS (North American Industry Classification System) code in Appendix 6, the investigation must begin with a Phase I regardless of loan amount (SOP 50 10 8.1, Section A, Chapter 5, Paragraph E.4.a.i). Appendix 6 adds that a Phase I should always be obtained when the business sells, supplies or dispenses fuel, even without a code match. Current or historical on-site dry cleaning that used or likely used chlorinated or petroleum solvents requires a Phase I followed by a Phase II (Paragraph E.6.b).

What the SBA adds to the ASTM standard

SOP 50 10 8.1, effective October 1, 2026 and posted by SBA only as a Word file, defines a Transaction Screen as one performed under ASTM E1528-22, then adds requirements the standard does not have. Because the definition names ASTM’s most recently adopted practice, a screen prepared to the older 2014 edition does not meet it.

The Appendix 5 letter is a fixed SBA form whose wording may not be modified. It lets the lender and the SBA use and rely on the screen, and it carries the EP’s insurance and impartiality certifications and an acknowledgment of the false-statement penalties under 18 U.S.C. 1001. Its boxes cover a Transaction Screen, a Phase I (or updated Phase I) and a Phase II only. A Records Search with Risk Assessment (RSRA), the SBA’s desk report with an EP risk rating and no site visit, needs no reliance letter, and the form has no box for one.

When the SBA path calls for a Transaction Screen

1. The owner or operator will not sign the Environmental Questionnaire (EQ). The lender completes or reviews the EQ after a site visit, and the current owner or operator must sign it under false-statement language that cites 18 U.S.C. 1001. If they will not sign, the EQ cannot be used and the lender must obtain, at a minimum, a Transaction Screen (Appendix 4). The screen itself still includes an interview with the owner or operator and a visit to the property (Appendix 4, “Transaction Screen”), so plan for site access and an interview even without the signature. Our SBA requirement checker asks about the signature along with the NAICS check and the loan amount.
2. A car-wash-only facility. Automotive repair and maintenance (NAICS 8111) is on Appendix 6, except “car wash only” facilities, for which a Transaction Screen is “an acceptable starting point.” Oil change or repair work on site ends the carve-out, fuel sales call for a Phase I under the Appendix 6 footnote, and because the NAICS check covers known prior uses, a car wash on a former gas station or repair shop site starts with a Phase I too (Paragraph E.4.a).

The SOP sets minimums, and lender policy may require more (Paragraph E.2). One case it leaves open: for a loan over $250,000 with no NAICS match, the minimum is an EQ plus an RSRA (Paragraph E.4.a.ii.b), and the SOP does not say whether the Transaction Screen replaces only the unsigned EQ or the RSRA as well when the current owner or operator will not sign. The lender can put that question to local SBA counsel, as Paragraph E.9 directs, before ordering. A Phase I goes beyond both minimums.

After the screen, Paragraph E.4.d controls. If the EP concludes that no further investigation is warranted, the lender keeps the screen and its review in the loan file. If the EP concludes that more is warranted, the lender must obtain a Phase I; going straight to a Phase II needs an exception from the SBA Environmental Committee, requested in advance and decided case by case. Our guide to SBA environmental requirements walks through each step.

When to order a Phase I instead of a screen

Our RSRA vs Transaction Screen vs Phase I guide sets the three reports side by side, including when a screen is enough. Order the Phase I when:

• You want CERCLA protection. For most buyers the relevant protection is the bona fide prospective purchaser (BFPP) defense. AAI before acquisition is one of its 8 statutory criteria; a Phase I to ASTM E1527-21 is built to meet it, and a screen cannot (42 U.S.C. 9601(40)). The defense also depends on the buyer’s own inquiries and on continuing obligations after closing. EPA says AAI cannot be performed after the purchase (EPA, 2019). Your attorney should advise on the defense; the Phase I has to be finished before closing.
• The property has a chemical-intensive past or present use, matches Appendix 6, or sells fuel.
• Your lender’s policy names ASTM E1527-21.
• You already expect a problem. On an SBA loan, a screen that finds more investigation is warranted leads to a Phase I anyway (Paragraph E.4.d).

Worked example. A lender orders our $795 Transaction Screen and the EP concludes that further investigation is warranted. The full $795 fee is credited toward a Phase I on the same property ordered within 30 days, so for a standard-scope property the two reports together cost $1,495, the price of the Phase I alone. The cost of starting with the screen is time: 4 business days for the screen plus 5 for the Phase I, or at least 9 in all, against 5 for a Phase I ordered first.

Our Transaction Screen: price, timing and delivery

Our Transaction Screen is $795 flat for the standard scope shown above. Delivery is 4 business days from authorization and confirmed site access, or 3 business days with rush for $250 more. Each screen is signed by an Environmental Professional who meets 40 CFR 312.10, who also supervises the site visit, as Appendix 4 requires. The report attaches the database records and the historical records the screen relied on, such as aerial photographs, city directories, fire insurance maps and topographic maps, and includes the Appendix 5 reliance letter at no added charge.

We can charge $795 and deliver in 4 business days because we built proprietary internal technology that collects and organizes the regulatory and historical records the day an order is authorized, so the EP reviews an organized record instead of assembling one. In October 2026, $795 was below every published Transaction Screen price we found. The few firms that publish one listed $930 (Triad Environmental, whose page also says to contact the office for a price that varies by property location), a starting price of $1,200 (Phase One Report) and about $1,950 (A3 Environmental, on its blog). A3 Environmental gives a typical turnaround of 10 to 15 business days on its order page, as listed on October 19, 2026.

Sources

1. ASTM E1528-22, Standard Practice for Limited Environmental Due Diligence: Transaction Screen Process (Scope and Significance and Use), ASTM International, accessed October 2026.
2. Environmental Due Diligence (E1528 revision news, August 4, 2022), ASTM International, accessed October 2026.
3. SOP 50 10 8.1, Lender and Development Company Loan Programs with Technical Policy Updates (Section A, Chapter 5, Paragraph E; Appendices 4, 5 and 6), U.S. Small Business Administration, accessed October 2026.
4. 40 CFR 312.10, Definitions (Environmental Professional), eCFR, accessed October 2026.
5. 42 U.S.C. 9601(40), Bona fide prospective purchaser, Legal Information Institute, Cornell Law School, accessed October 2026.
6. Enforcement Discretion Guidance Regarding Statutory Criteria for Those Who May Qualify as CERCLA Bona Fide Prospective Purchasers, Contiguous Property Owners, or Innocent Landowners, July 29, 2019, U.S. Environmental Protection Agency, accessed October 2026.
7. What Is a Transaction Screen Assessment (TSA)?, A3 Environmental Consultants, accessed October 2026.
8. Transaction Screen Assessment order page, A3 Environmental Consultants, accessed October 2026.
9. Transaction Screen (ASTM format) (TS), Triad Environmental, accessed October 2026.
10. Environmental Services, Phase One Report, accessed October 2026.