On October 13, 2017, the Small Business Administration (SBA) released a revision to its Standard Operating Procedure (SOP) 50 10 5(J), Lender and Development Company Loan Programs. This revision made several amendments to the SBA environmental policies which became effective on January 1, 2018.

This photo shows an example of an Oil Spill and Contaminated Soil Identified During Phase 1 Environmental Inspection

Oil Spill and Contaminated Soil Identified During Phase 1 Environmental Inspection

Some of the key changes are:
Appendix 2 – Definitions – SBA has updated the following definitions:

  • Environmental Questionnaire,
  • Phase I Environmental Site Assessment (Phase I ESA),
  • Records Search with Risk Assessment,
  • Reliance Letter, and
  • SBA Environmental Indemnification Agreement.

Appendix 3 – Reliance Letter – SBA has revised the language in the Reliance Letter to conform to the updates to the environmental policies made in Subparts B and C.

Appendix 4 – NAICS Codes of Environmentally Sensitive Industries
1. Updated the following NAICS codes:
316 – Leather & Allied Product Manufacturing,
326 – Plastics & Rubber Products Manufacturing,
332 – Fabricated Metal Product Manufacturing,
8122 – Death Care Services, and
56171 – Exterminating & Pest Control.
2. Added the following NAICS Codes:
484 – Trucking (if service bays, truck washing, or fuel tanks present and
713990 Other Recreational Industries (indoor and outdoor shooting ranges only).

Appendix 5 – Requirements Pertaining to Gas Station Loans – SBA updated this appendix for clarity.

 

Caltha LLP | Your Environmental Site Assessment and Remediation Partner

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