Lead-acid batteries Tier II reporting threshold
Yes — once you hold 500 pounds or more of sulfuric acid, the acid inside lead-acid batteries, at any one time during the year. Count the acid itself, not the whole liquid. That is roughly 136 gallons of 35% battery acid (500 lb ÷ 0.35 ÷ 10.5 lb/gal), or about 35 gallons of 93% acid (500 lb ÷ 0.93 ÷ 15.3 lb/gal).
The number that counts is the most you had on site at one time, not the total you bought over the year, and not what is there today.
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- Extremely hazardous substance?
- Yes — the sulfuric acid inside is one, so its own lower limit applies.
- Threshold planning quantity
- 1,000 pounds
- CAS number
- 7664-93-9 (sulfuric acid)
- Why this one counts
- Batteries count as the sulfuric acid inside them — the acid is on the EPA list as extremely hazardous, so the threshold is 500 lb of acid, not 10,000 lb. Enter the acid: gallons of electrolyte (about a third of a battery’s weight), or pounds. Forklifts, UPS units, emergency generators and fire pumps all have them, and those count. Car-type batteries in the same package the public buys are left out, whether they are in use or on the shelf for sale. Spent batteries waiting to go back for recycling are a separate question: EPA says hazardous waste is outside this filing, so it turns on how the waste rules treat yours. Lithium-ion is a different entry — search for it by name.
- Weight to volume
- 10.5 pounds per gallon. battery-strength sulfuric acid, about 35% — specific gravity 1.26⚠️ A representative figure — section 9 of your own safety data sheet beats it.
40 CFR 370.10 — 500 pounds or the threshold planning quantity, whichever is lower · 40 CFR 370.14(c) — count the chemical by its weight percent · 40 CFR 370.45(a) — filed on or before 1 March each year
Your state may set a lower limit
7 of the states we have read set the threshold itself below the federal one: OR, CA, VT, LA, AK, DE, OH.
5 more are strict in a different way — NC, MO, NV, NJ, RI keep the federal numbers but add a separate filing or cover more chemicals. Those are not the same thing, and we do not call them the same thing.
Where we have not read a state’s own code, we say so rather than guess.
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lead-acid batteries is one chemical. The filing counts everything you keep, added up across every place you keep it. The checker works that out and shows the rule behind each number.
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