Does our bulk oxygen tank need to be reported?

Positions differ on whether medical oxygen qualifies for the FDA drug exemption, and many hospitals report their bulk oxygen. Choose a position, document it, and apply it the same way every year.

What does the medical facility exemption cover?

It covers substances used in a hospital or medical facility under the direct supervision of a technically qualified individual. Facility infrastructure such as generator fuel, boiler fuel and UPS batteries isn't covered.

Do outpatient clinics file Tier II?

They follow the same test as any facility. Many fall below thresholds, but a clinic with an emergency generator or bulk oxygen may not.

Does formalin in pathology count?

Formaldehyde is an extremely hazardous substance. Formalin is a dilute solution, so calculate the formaldehyde content across all containers, including prefilled specimen containers.

Our oxygen supplier owns the tank. Do we still report it?

Tier II is based on what's present at your facility, not who owns it.

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Healthcare

Tier II reporting for hospitals, from the oxygen tank to the pathology lab

A hospital's biggest reportable chemicals usually aren't in the clinical areas at all. They're in the central plant, the generator yard and the bulk oxygen tank out back. NeoTech helps healthcare facilities find what counts, apply exemptions correctly, and file accurate Tier II reports for every campus.

Talk to us about your facilities See the platform

Where the chemicals are in a hospital

Emergency power and central plant

Diesel for emergency generators
Fuel oil for dual-fuel boilers
Boiler and cooling tower water treatment chemicals
Lead-acid UPS batteries
Refrigerant in chillers

Medical gases

Bulk liquid oxygen tank
Nitrous oxide, nitrogen, carbon dioxide and oxygen cylinders
Liquid helium in MRI magnets

Sterile processing

Ethylene oxide sterilizers
Hydrogen peroxide and peracetic acid sterilants
High-level disinfectants

Laboratory and pathology

Formalin (formaldehyde)
Xylene, alcohols and reagents

Facility and support

Bulk hand sanitizer and disinfectant stock
Welding gases and maintenance chemicals
Clean agent fire suppression in data and telecom rooms

Four places hospital reports go wrong

Overlooking the infrastructure

Generator diesel, boiler fuel and bulk oxygen are often the largest quantities on site, and none of them sit in clinical areas.

Stretching the medical facility exemption

It covers chemicals used under the direct supervision of a technically qualified individual. It doesn't cover generator fuel, boiler fuel or batteries.

Assuming vendor-owned means not ours

Oxygen tanks and gas cylinders are often owned by the supplier, but they count at the facility where they sit.

Missing extremely hazardous substances

Formaldehyde, ethylene oxide and concentrated hydrogen peroxide have lower thresholds and can trigger Section 302 notifications.

How NeoTech handles it

Every campus in one place. Hospitals, clinics and outpatient centers, each set up once and tracked together.

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

SDS extraction. NeoTech's AI extracts and indexes hazard data from SDSs for sterilants, lab chemicals, fuels and gases.

Totals combined by chemical. Inventory is combined by CAS number across every product and location, 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 hospitals: we'll walk the campus with you

NeoTech is based in Minneapolis. For Minnesota facilities, our team can collect your chemical inventory on site, from the central plant and generator yard to sterile processing and the lab, 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

Does our bulk oxygen tank need to be reported?: Positions differ on whether medical oxygen qualifies for the FDA drug exemption, and many hospitals report their bulk oxygen. Choose a position, document it, and apply it the same way every year.
What does the medical facility exemption cover?: It covers substances used in a hospital or medical facility under the direct supervision of a technically qualified individual. Facility infrastructure such as generator fuel, boiler fuel and UPS batteries isn't covered.
Do outpatient clinics file Tier II?: They follow the same test as any facility. Many fall below thresholds, but a clinic with an emergency generator or bulk oxygen may not.
Does formalin in pathology count?: Formaldehyde is an extremely hazardous substance. Formalin is a dilute solution, so calculate the formaldehyde content across all containers, including prefilled specimen containers.
Our oxygen supplier owns the tank. Do we still report it?: Tier II is based on what's present at your facility, not who owns it.

Every campus, reported with care

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

Talk to us about your facilities