SBA environmentally sensitive industries

Appendix 6 of the Small Business Administration's (SBA) Standard Operating Procedure (SOP) 50 10 8.1 lists the North American Industry Classification System (NAICS) codes of industries SBA treats as environmentally sensitive. A match for a current or known prior use of the Property means the Environmental Investigation on a 7(a) or 504 loan begins with a Phase I Environmental Site Assessment (ESA), whatever the loan amount. This page rests on SOP 50 10 8.1 with Technical Policy Updates, effective October 1, 2026. SBA's lists of procedural and information notices, read October 16, 2026, show none issued after it whose title touches its environmental policies.

Who the rule binds

The lender checks. Except where the Property is one unit of a Multi-Unit Building, a lender must start with a Good Faith effort to find the NAICS code of each current and known prior use and compare it with the list (SOP 50 10 8.1, Section A, Ch. 5, Para. E, Environmental Investigation Steps).
Units. For one unit of a Multi-Unit Building, a non-industrial building of four or more individual units, the lender may skip the check and go to the steps set by loan amount (SOP 50 10 8.1, Appendix 4; Section A, Ch. 5, Para. E).

What it asks

A match. The investigation must begin with a Phase I, whatever the loan amount. A code that begins 457, for gas stations with or without a convenience store, also sends the lender to Appendix 7, to follow where it applies (SBA gas station loan requirements) (SOP 50 10 8.1, Section A, Ch. 5, Para. E).
Reach of a code. A 3, 4 or 5 digit code takes in every industry whose code begins with those digits; a 6 digit code, only that one industry (SOP 50 10 8.1, Appendix 6).
Fuel. SBA adds that a Phase I should always be obtained for a business that sells, supplies or dispenses fuel, gasoline or heating oil, even if its own code is not listed (SOP 50 10 8.1, Appendix 6).
Car washes and dry cleaners. Under 8111, a car wash only facility may start with a Transaction Screen. Under 8123, the test is dry cleaning on site at any time, and Para. E has its own dry cleaner rule.

The entries, with each condition after its colon (SOP 50 10 8.1, Appendix 6):

211 Oil & Gas Extraction
212 Mining (Except Oil & Gas)
213 Support Activities for Mining
237 Heavy & Civil Engineering Construction
311 Food Manufacturing: if fuel tanks present
312 Beverage & Tobacco Product Manufacturing: except breweries, 31212
313 Textile Mills: not required if sewing, weaving, or hemming only
314 Textile Product Mills: not required if sewing, weaving, or hemming only
316 Leather & Allied Product Manufacturing: not required if assembly only
321 Wood Product Manufacturing: if finishing occurs on site
322 Paper Manufacturing
323 Printing & Related Support Activities
324 Petroleum & Coal Products Manufacturing
325 Chemical Manufacturing
326 Plastics & Rubber Products Manufacturing: not required if assembly only
327 Nonmetallic Mineral Products Manufacturing
331 Primary Metal Manufacturing
332 Fabricated Metal Product Manufacturing: not required if assembly only
333 Machinery Manufacturing: not required if assembly only
334 Computer & Electronic Product Manufacturing: not required if assembly only
335 Electrical Equipment, Appliance & Component Manufacturing: not required if assembly only
336 Transportation Equipment Manufacturing
337 Furniture & Related Manufacturing: if finishing occurs on site
339 Miscellaneous Manufacturing: only required if hazardous materials are involved
42311 Automobile & Other Motor Vehicle Merchant Wholesalers: if service bays present
42314 Motor Vehicle Parts (Used) Merchant Wholesalers
4235 Metal & Mineral Merchant Wholesalers
42393 Recyclable Material Merchant Wholesalers
4246 Chemical & Allied Products Merchant Wholesalers
4247 Petroleum & Petroleum Products Merchant Wholesalers
441 Motor Vehicle & Parts Dealers: if service bays present
457 Gasoline Stations & Fuel Vendors: not required for propane or firewood dealers
481 Air Transportation
482 Rail Transportation
484 Trucking: if service bays, truck washing, or fuel tanks present
486 Pipeline Transportation
488 Support Activities for Transportation: if fuel tanks are present or if repairs or maintenance is performed on site
53212 Truck, Utility Trailer, and RV (Recreational Vehicle) Rental & Leasing: if repairs, maintenance, or vehicle washing are performed onsite
53241 Construction, Transportation, Mining & Forestry Machinery & Equipment Rental & Leasing: if repairs, maintenance, or vehicle washing are performed onsite
53249 Other Commercial & Industrial Machinery & Equipment Rental & Leasing: if repairs, maintenance, or vehicle washing are performed onsite
54138 Testing Laboratories & Services
56171 Exterminating & Pest Control Services
562 Waste Management & Remediation Services
6221 General Medical & Surgical Hospitals: if fuel tanks are present
713990 Other Recreational Industries: indoor and outdoor shooting ranges only
71391 Golf Courses & Country Clubs
71392 Skiing Facilities
71393 Marinas
7212 RV (Recreational Vehicles) Parks & Recreational Camps: if fuel tanks are present or if vehicle repairs or maintenance is performed onsite
8111 Automotive Repair & Maintenance: except for car wash only facilities, for which a Transaction Screen is an acceptable starting point
8112 Electronic & Precision Equipment Repair & Maintenance: not required if assembly only
8113 Commercial & Industrial Machinery & Equipment Repair & Maintenance
8122 Death Care Services: unless no embalming or cremation at the Property
8123 Laundry & Dry Cleaning Services: if dry cleaning operations have ever existed on site
812921 Photofinishing Laboratories: except one hour

What it means for the Phase I and the consultant

What a match turns on. The code of each use and, for conditioned entries, a fact at the Property: fuel tanks, service bays, finishing, assembly only, repairs, maintenance or washing on site, embalming or cremation, past dry cleaning, hazardous materials. Appendix 4 defines none of them, and Appendix 6 says only that a complete list of industries and their NAICS codes is available.
Which edition. The list here is SOP 50 10 8.1's. Part 120 makes the requirements in effect when a lender acts govern that action, as quoted below.
Where a Phase I holds such facts. Its history traces uses back to first developed use or 1940, whichever is earlier (E1527-21, 8.3.8), and its site visit looks for storage tanks and for hazardous substances and petroleum products in use (E1527-21, 9.4.11, 9.4.12). The standard assigns no industry codes; the SOP's code check comes before any Phase I.

What the rule says

Loan Program Requirements in effect at the time that an SBA Lender or Intermediary takes an action in connection with a particular loan govern that specific action.

13 CFR 120.180, edition revised as of January 1, 2025

This page is general reference for environmental professionals. It does not review any loan or project. The regulation and SBA's Standard Operating Procedure are the authority, and the determinations of SBA, or of the lender acting under the authority SBA delegates, govern.