Do federal and military facilities file Tier II?

Federal facilities have been covered through a series of executive orders rather than the statute itself, going back to EO 12856 in 1993, and agency policy generally continues to require Tier II reporting even as those orders have been revoked and replaced over time -- confirm your agency's current directive rather than assuming a specific order governs. A contractor-operated facility can also be independently covered as its own non-federal facility. If you're unsure who files for a shared site, settle it before the deadline.

Can we keep storage locations confidential?

Yes. Tier II lets you mark storage location information confidential so it's withheld from public release. Classified information follows its own rules, so coordinate with your security officer.

Do chemicals in plating and etch baths count?

Yes. The chemicals in working solutions count toward facility totals. Calculate them from bath volume and concentration.

Does jet fuel in storage tanks count?

Yes. Jet fuel and aviation gasoline in storage count toward the facility total for each product.

Why are some chemicals reportable at such small amounts?

Extremely hazardous substances have a reporting threshold of 500 lb or their threshold planning quantity, whichever is lower. Hydrofluoric acid, for example, is reportable at 100 lb.

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Aerospace and defence

Tier II reporting for aerospace and defense, precise where it matters

Aerospace and defense facilities use some of the most specialized chemicals in industry: surface treatment acids, specialty coatings, fuels, propellants and high-purity gases. Several of them are extremely hazardous substances with very low thresholds. NeoTech keeps the inventory accurate and the sensitive details protected.

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Where the chemicals are in aerospace and defense facilities

Surface treatment and finishing

Anodizing, plating and etching baths, including chromic, nitric, sulfuric and hydrofluoric acids
Chemical milling solutions
Degreasing solvents

Coatings and composites

Primers, topcoats and sealants in paint hangars and booths
Epoxy resins and curing agents for composite layup

Fuels, fluids and propellants

Jet fuel and aviation gasoline in storage tanks
Hydraulic fluids
De-icing and anti-icing fluids
Propellants such as hydrazine at test and space facilities
Energetic materials

Gases and support

Nitrogen, helium, oxygen, argon and hydrogen, including cryogenic storage
Non-destructive testing chemicals
Emergency generator fuel and lead-acid batteries

Four places aerospace and defense reports go wrong

Underestimating low thresholds

Hydrofluoric acid, nitric acid and hydrazine are extremely hazardous substances. Hydrofluoric acid's threshold is 100 lb, so a single etch line can cross it.

Missing process tanks

Plating and etch baths are working solutions, not stored product, but the chemicals in them count toward facility totals.

Leaving out contractor and tenant areas

Chemicals present at the facility count, whether they belong to a prime contractor, a subcontractor or a government tenant.

Over-sharing locations

Tier II lets you keep storage locations out of public release. Facilities that don't use that option publish more than they need to.

How NeoTech handles it

Every facility in one place. Manufacturing sites, hangars and test facilities, each set up once and tracked together.

State requirements, checked for you. NeoTech checks each site against its state's Tier II rules and submission system.

SDS extraction for specialty chemicals. NeoTech's AI extracts and indexes hazard data from supplier SDSs, including multi-component coatings and fluids.

Totals combined by chemical. Inventory is combined by CAS number across every product and process tank, then compared against the correct threshold, including extremely hazardous substance thresholds.

Deadlines on the calendar. Reminders for Section 302 notifications, Section 311 SDS submissions and the March 1 Tier II deadline.

Reports in your state's format. Submission-ready .t2s packages for Tier2 Submit, E-Plan exports and more.

Or let us file for you. NeoTech can submit on your behalf to the SERC, LEPC and fire department.

Minnesota facilities: we'll walk the site with you

NeoTech is based in Minneapolis. For Minnesota facilities, our team can collect your chemical inventory on site and load it straight into the platform.

Schedule an on-site inventory

State rules

Tier II requirements differ by state, so browse every state we cover.

See every state's Tier II requirements →

Frequently asked questions

Do federal and military facilities file Tier II?: Federal facilities have been covered through a series of executive orders rather than the statute itself, going back to EO 12856 in 1993, and agency policy generally continues to require Tier II reporting even as those orders have been revoked and replaced over time -- confirm your agency's current directive rather than assuming a specific order governs. A contractor-operated facility can also be independently covered as its own non-federal facility. If you're unsure who files for a shared site, settle it before the deadline.
Can we keep storage locations confidential?: Yes. Tier II lets you mark storage location information confidential so it's withheld from public release. Classified information follows its own rules, so coordinate with your security officer.
Do chemicals in plating and etch baths count?: Yes. The chemicals in working solutions count toward facility totals. Calculate them from bath volume and concentration.
Does jet fuel in storage tanks count?: Yes. Jet fuel and aviation gasoline in storage count toward the facility total for each product.
Why are some chemicals reportable at such small amounts?: Extremely hazardous substances have a reporting threshold of 500 lb or their threshold planning quantity, whichever is lower. Hydrofluoric acid, for example, is reportable at 100 lb.

Specialized chemistry, handled precisely

Tell us about your facilities and we'll show you how NeoTech takes each site from inventory to filed report.

Talk to us about your facilities