Do sealed VRLA batteries count toward Tier II?

Yes. EPA does not treat lead-acid batteries as exempt articles, so the sulfuric acid and lead count, whether the batteries are flooded or sealed. The acid from every battery at the facility is added together.

What about lithium-ion UPS batteries?

EPA guidance hasn't settled whether lithium-ion batteries are exempt as articles, and companies take different positions. Choose a position, document your reasoning and apply it consistently across your sites.

Does diesel in generator belly tanks count?

Yes. Diesel in belly tanks, day tanks and bulk tanks is combined into a single facility total.

Does the refrigerant inside our chillers count?

Refrigerants are hazardous chemicals under OSHA's standard, and large chiller plants can hold a lot of them. Many facilities count installed charge as well as stored cylinders. Whichever approach you take, document it and apply it the same way every year.

Our fuel and gas suppliers own the tanks and cylinders. Do we still report them?

Tier II is based on what's present at your facility, not who owns it. Vendor-owned tanks and cylinders on your site count toward your inventory.

We're adding a new data hall. What do we need to do?

Check whether the new batteries, fuel or refrigerant push any chemical past its threshold. For extremely hazardous substances like sulfuric acid, crossing the threshold planning quantity triggers a Section 302 notification within 60 days. Other new chemicals above their Tier II thresholds require SDSs or a chemical list to be submitted within three months.

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Data centers

Tier II reporting for data centers, down to the battery jar

Most of the reportable chemicals in a data center aren't on a shelf. They're inside UPS cabinets, generator tanks, chillers and suppression cylinders. NeoTech helps you find them, turn equipment data into reportable quantities, and file accurate Tier II reports for every site you operate.

Talk to us about your sites See the platform

Where the chemicals are in a data center

Your EHS inventory probably doesn't list most of these, but Tier II counts all of them.

Power and backup

UPS battery systems: sulfuric acid and lead in lead-acid and VRLA batteries, or electrolyte in lithium-ion systems
Generator fuel: diesel in belly tanks, day tanks and bulk storage tanks
Generator maintenance stock: engine oil and coolant

Substation and switchgear

When you own it

Transformer oil
SF₆ in gas-insulated switchgear and breakers
DC control batteries for breaker tripping

Cooling

Refrigerant in chillers and CRAC/CRAH units, plus servicing cylinders
Glycol in closed cooling loops
Cooling tower water treatment chemicals

Fire protection

Clean agents, inert gases and CO₂ in suppression cylinder banks

Maintenance and grounds

Welding gases, coatings and solvents during build-outs
Contractor-staged materials
Herbicides and de-icers

Four places data center reports go wrong

The same four mistakes show up across almost every site we look at.

Counting room by room

Tier II compares the facility-wide total of each chemical. Sulfuric acid in the UPS rooms and in the switchgear battery racks is added together, and so is diesel across every tank.

Missing the Section 302 notice

Sulfuric acid is an extremely hazardous substance. When a new battery installation pushes the site past its threshold planning quantity, you owe a notification to your state and local planning committee within 60 days. That deadline arrives long before the next annual Tier II report -- and further updates are owed later if the facility, its emergency coordinator, or the substances present change.

Weighing the container

For cylinders, only the gas inside counts, never the steel. Acetylene is the exception that catches people out: the acetone it's dissolved in counts too.

Losing track during build-out

New halls come online in phases. Inventory reported in March may be out of date by June, and the maximum amount on site during the year is what gets reported.

How NeoTech handles it

One facility per campus, one view across all of them. Set up each site once, then see every facility's status and deadlines together.

State requirements, checked for you. Every state runs Tier II a little differently: submission systems, fees and extra requirements. NeoTech checks each site against its state's rules.

SDS extraction that reads battery sheets. Upload manufacturer SDSs and NeoTech's AI extracts and indexes the hazard data, including the acid and lead content you need for battery calculations.

Quantities calculated and combined by chemical. Inventory entries are combined by CAS number across every product and location at the facility, then compared against the right threshold, including the lower thresholds for extremely hazardous substances.

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

Reports in the format your state takes. Generate submission-ready files, including .t2s packages for Tier2 Submit and E-Plan exports.

Or let us file for you. NeoTech can submit on your behalf to the SERC, LEPC and fire department, so a filing is finished, not just prepared.

Minnesota data centers: we'll walk the site with you

NeoTech is based in Minneapolis. For Minnesota facilities, our team can collect your chemical inventory on site, including battery rooms, generator yards, cooling plants and suppression systems, and load it straight into the platform.

Schedule an on-site inventory

State rules

Tier II requirements differ by state. See our state guides below, or browse every state we cover.

See every state's Tier II requirements →

Frequently asked questions

Do sealed VRLA batteries count toward Tier II?: Yes. EPA does not treat lead-acid batteries as exempt articles, so the sulfuric acid and lead count, whether the batteries are flooded or sealed. The acid from every battery at the facility is added together.
What about lithium-ion UPS batteries?: EPA guidance hasn't settled whether lithium-ion batteries are exempt as articles, and companies take different positions. Choose a position, document your reasoning and apply it consistently across your sites.
Does diesel in generator belly tanks count?: Yes. Diesel in belly tanks, day tanks and bulk tanks is combined into a single facility total.
Does the refrigerant inside our chillers count?: Refrigerants are hazardous chemicals under OSHA's standard, and large chiller plants can hold a lot of them. Many facilities count installed charge as well as stored cylinders. Whichever approach you take, document it and apply it the same way every year.
Our fuel and gas suppliers own the tanks and cylinders. Do we still report them?: Tier II is based on what's present at your facility, not who owns it. Vendor-owned tanks and cylinders on your site count toward your inventory.
We're adding a new data hall. What do we need to do?: Check whether the new batteries, fuel or refrigerant push any chemical past its threshold. For extremely hazardous substances like sulfuric acid, crossing the threshold planning quantity triggers a Section 302 notification within 60 days. Other new chemicals above their Tier II thresholds require SDSs or a chemical list to be submitted within three months.

Know what's on every site before the deadline does

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

Talk to us about your sites