Do forklift batteries count toward Tier II?

Yes. EPA does not treat lead-acid batteries as exempt articles, so the sulfuric acid and lead count. Add up every battery at the facility, including spares and batteries on chargers.

How are mixtures counted?

Each hazardous component is counted across every product that contains it, so a chemical present in several products is combined into one facility total. You can also report a mixture as a whole; either way, be consistent.

Does our ammonia refrigeration system need to be reported?

Anhydrous ammonia is an extremely hazardous substance with a 500 lb threshold, so most industrial ammonia refrigeration systems are reportable. Crossing its threshold planning quantity also triggers a Section 302 notification, due within 60 days.

Is Tier II the same as TRI reporting?

No. Tier II (EPCRA Section 312) covers the chemicals you have on hand. TRI (Section 313) covers releases and waste management of listed chemicals at facilities in covered industries. Many manufacturers file both, on different deadlines.

Do small containers in the maintenance shop matter?

They can. Small containers of the same chemical add up across the facility, so they belong in the inventory even if no single container is large.

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Chemical manufacturing

Tier II reporting for manufacturers, from the tank farm to the forklift charger

A plant's reportable chemicals are spread across process lines, maintenance shops, utilities and the warehouse. Some of the largest quantities sit in places nobody thinks of as chemical storage. NeoTech brings it all into one inventory, calculates facility totals by chemical, and gets your Tier II report filed.

Talk to us about your plants See the platform

Where the chemicals are in a manufacturing plant

Production

Process acids, caustics and solvents in bulk tanks, totes and drums
Metal finishing and plating baths
Paints, coatings and adhesives in mixing rooms and spray booths
Resins, catalysts and raw materials

Material handling

Lead-acid forklift batteries and charging rooms
Propane cylinders for forklifts

Utilities

Anhydrous ammonia refrigeration systems (common in food and beverage plants)
Boiler fuel and boiler water treatment
Cooling tower treatment chemicals
Wastewater pretreatment chemicals
Emergency generator fuel

Maintenance

Lubricants, hydraulic oil and coolants
Welding and cutting gases
Compressed and cryogenic gases (nitrogen, argon, oxygen, CO₂)

Four places manufacturing reports go wrong

Overlooking the forklift fleet

Each lead-acid forklift battery holds a meaningful amount of sulfuric acid, and the acid across every battery in the fleet, plus spares on the charger, is added together.

Missing chemicals inside mixtures

A hazardous component counts across every product that contains it. Xylene in five different coatings, or sulfuric acid in a cleaner and a battery, adds up to one facility total.

Treating extremely hazardous substances like everything else

Ammonia, sulfuric acid and several plating chemicals have much lower thresholds, and crossing a threshold planning quantity triggers a separate Section 302 notification.

Reporting a quiet day instead of the peak

Tier II asks for the maximum amount on site during the year. A delivery that arrives before inventory is drawn down sets that maximum.

How NeoTech handles it

Every plant in one place. Set up each facility once and see status and deadlines across all of them.

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

SDS extraction at scale. Upload supplier SDSs and NeoTech's AI extracts and indexes the hazard classes and components, including complex mixtures and petroleum products.

Totals combined by chemical. Inventory is combined by CAS number across every product and location, then compared against the correct threshold, including lower thresholds for extremely hazardous substances.

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 manufacturers: we'll walk the plant with you

NeoTech is based in Minneapolis. For Minnesota facilities, our team can collect your chemical inventory on site, from process areas and maintenance shops to battery rooms and utility plants, 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 forklift batteries count toward Tier II?: Yes. EPA does not treat lead-acid batteries as exempt articles, so the sulfuric acid and lead count. Add up every battery at the facility, including spares and batteries on chargers.
How are mixtures counted?: Each hazardous component is counted across every product that contains it, so a chemical present in several products is combined into one facility total. You can also report a mixture as a whole; either way, be consistent.
Does our ammonia refrigeration system need to be reported?: Anhydrous ammonia is an extremely hazardous substance with a 500 lb threshold, so most industrial ammonia refrigeration systems are reportable. Crossing its threshold planning quantity also triggers a Section 302 notification, due within 60 days.
Is Tier II the same as TRI reporting?: No. Tier II (EPCRA Section 312) covers the chemicals you have on hand. TRI (Section 313) covers releases and waste management of listed chemicals at facilities in covered industries. Many manufacturers file both, on different deadlines.
Do small containers in the maintenance shop matter?: They can. Small containers of the same chemical add up across the facility, so they belong in the inventory even if no single container is large.

Every plant, every chemical, one filing process

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

Talk to us about your plants