Which report does your SBA loan need?

SBA SOP 50 10 8.1 (published September 25, 2026 and effective October 1, 2026; SBA’s September notice applies it to applications received on or after that date), Section A, Chapter 5, Paragraph E “Environmental Policies and Procedures”: Paragraph E.4 (Environmental Investigation Steps), Paragraph E.6 (Special Use Facilities: child-occupied facilities, dry cleaners, gas stations), Appendix 4 (Environmental Questionnaire), Appendix 5 (Reliance Letter), Appendix 6 (NAICS Codes of Environmentally Sensitive Industries) and Appendix 7 (gas stations).

A 3, 4 or 5 digit code on Appendix 6 covers every industry that starts with those digits; a 6 digit code covers only that industry. Both the current use and known prior uses of the property must be checked. Several entries are conditional (for example “Food Manufacturing (if fuel tanks present)”), and the lender documents whether the condition applies. Look up any code with our SBA NAICS lookup.

Not when the match is firm: it means a Phase I whatever the loan amount, and current or past on-site dry cleaning that used, or likely used, chlorinated or petroleum-based solvents means a Phase I followed by a Phase II. Some entries apply only under a condition, and a car wash only facility may start with a Transaction Screen. The $250,000 threshold applies on the no-match path (Environmental Questionnaire up to and including $250,000; Questionnaire plus RSRA above it).

The SBA lender, after at least one site visit and a good-faith attempt to interview the current owner or operator, who must sign it. If they will not sign, the lender must obtain at least a Transaction Screen Assessment.

For a unit in a non-industrial building with 4 or more units, the NAICS check is not required and the lender follows the loan-amount path directly (Paragraph E.4). On our reading, the dry cleaner rule (Paragraph E.6.b) still applies to a unit where dry cleaning that used, or likely used, chlorinated or petroleum-based solvents was ever done, and the Appendix 6 fuel footnote still applies to a unit whose business sells, supplies or dispenses fuel, so the checker shows a Phase I for either.

No. It is a faithful walk through the SOP so you can order the right report quickly. SBA sends policy questions to local SBA counsel (EnvironmentalQuestions@sba.gov) and requests for exceptions to the SBA Environmental Committee (EnvironmentalAppeals@sba.gov).