SBA environmentally sensitive NAICS codes: Appendix 6 lookup

Short answer: SBA’s environmentally sensitive NAICS codes are the 55 entries in Appendix 6 of SOP 50 10 8.1. If the current or any known prior use of the collateral property matches one, the environmental investigation must begin with a Phase I, whatever the loan amount. With no match, the minimum is an Environmental Questionnaire up to $250,000, or a Questionnaire plus a Records Search with Risk Assessment above that.

SBA’s size standards are a different list. They also use NAICS codes, but they decide whether a business counts as small, and SBA publishes them in its Table of Size Standards.

What Appendix 6 is: SBA’s list of environmentally sensitive industries

SBA requires an environmental investigation of every commercial property pledged for a 7(a) or 504 loan, and says its “type and depth” varies with the risk of contamination (SBA Standard Operating Procedure (SOP) 50 10 8.1, Section A, Chapter 5, Paragraph E.2). Appendix 6, “NAICS Codes of Environmentally Sensitive Industries,” sorts that risk at the first step. NAICS is the North American Industry Classification System, the federal code set for business activities. SBA’s concern is the loan: cleanup costs can impair repayment, cut the collateral’s value and expose the lender or SBA after foreclosure (Paragraph E.1).

The list in SOP 50 10 8.1, effective October 1, 2026, is word for word the list in the 2025 SOP, so a result does not depend on which version governs an application. We last checked it against the SOP file SBA posts at legacy.sba.gov on October 19, 2026.

How a code matches an Appendix 6 entry

Entries have 3, 4, 5 or 6 digits. In SBA’s words, “A 3 digit NAICS code includes all industries beginning with those 3 digits,” and likewise for 4 and 5 digits, while “A 6 digit NAICS code includes only that industry under that industrial code.” So 8111, Automotive Repair and Maintenance, covers every code from 811111 General Automotive Repair to 811198, car washes included. Entry 713990 covers one industry, and under its condition only “indoor and outdoor shooting ranges.” The same logic explains 812921, Photofinishing Laboratories “(except one hour)”: one-hour labs have their own code, 812922, which a 6-digit entry never reaches.

Compare codes, not titles, because some SBA titles differ from the Census titles. SBA calls 713990 “Other Recreational Industries,” for example, while Census calls it “All Other Amusement and Recreation Industries.” And enter all 6 digits: a shorter code can span listed and unlisted industries. Code 3121 holds distilleries, which match, and breweries, which are excluded.

Conditions, exclusions and carve-outs

28 of the 55 entries carry a condition, an exclusion or a carve-out. The SOP does not define “service bays,” “assembly only” or “finishing,” so the answer depends on what happens at the property. Record the facts behind the decision in the loan file.

• Car washes. Car washes (811192) sit in 8111 beside oil change shops (811191). A car wash only site may start with a Transaction Screen; if the Environmental Professional (EP) finds more investigation is warranted, a Phase I follows (Paragraph E.4.d). A lube bay or repair work ends the carve-out.
• Laundromats and dry cleaners. 8123 covers laundromats and self-service dry cleaning (812310), dry cleaning and laundry services including drop-off stores (812320), and linen and industrial laundries (Census 2022 NAICS descriptions). It matches only if dry cleaning ever took place on the property. If that dry cleaning used, or likely used, chlorinated or petroleum-based solvents, Paragraph E.6.b requires a Phase I followed by a Phase II that addresses soil, groundwater and soil vapor, conducted by an independent EP who holds a current Professional Engineer (PE) or Professional Geologist (PG) license and has the equivalent of 3 years of full-time relevant experience.
• Breweries. 312120 is excluded; wineries, distilleries, and soft drink, bottled water and ice plants still match. Census codes a brewpub as a bar (722410) or a restaurant (722511), and neither is on the list.
• Propane and firewood. Delivery dealers of propane, heating oil, coal and firewood all share 457210 (Census 2022 NAICS index), so the carve-out turns on what the dealer sells, not on the code, and Paragraph E.4.a’s own 457 rule points the other way (see the fuel section below). Propane wholesalers (424710 and 424720) fall under 4247, which has no carve-out.

Check every current and known prior use

Paragraph E.4.a requires a “Good Faith effort to determine the NAICS code(s) for the Property’s current and known prior uses.” That wording has 3 consequences.

• The property’s history counts, not just the borrower’s business. A dental office going into a former gas station has a 457 prior use, so the investigation starts with a Phase I.
• Every tenant counts when the whole building is collateral, such as a strip center that once had a dry cleaning plant.
• “Known” depends on asking. The lender’s Environmental Questionnaire must cover past and present uses of the property and adjoining properties, “with particular attention paid to those uses by environmentally sensitive industries” (Appendix 4). Sellers, earlier reports, city directories and fire insurance maps fill the gaps.

The SOP sets no look-back period for this step, but the historical sources in a Records Search with Risk Assessment (RSRA) should reach the property’s first developed use or 1940, whichever is earlier (Appendix 4). If they reveal a former gas station or dry cleaning plant, plan on a Phase I: that is now a known prior use that matches Appendix 6 (Paragraph E.4.a), and an RSRA rated anything other than “low risk” requires one in any case (Paragraph E.4.c). Adjoining uses are not compared with Appendix 6, though the Questionnaire and the RSRA both look at them.

Fuel sales, gas stations and Appendix 7

A footnote reaches past the list: “A Phase I should always be obtained if the business sells, supplies or dispenses fuel, gasoline, heating oil, even if the NAICS code for the business is not identified on this list of environmentally sensitive industries.” A supermarket that runs fuel pumps may carry a grocery code; the footnote applies either way. SBA wrote “should,” not “must,” so plan on a Phase I; a lender that decides otherwise should record why in the loan file.

The SOP leaves one question open. Appendix 6 says the 457 entry is “not required for propane or firewood dealers,” but Paragraph E.4.a says that when a NAICS code “begins with 457” the investigation “must begin with a Phase I,” and the footnote reaches any business that “sells, supplies or dispenses fuel.” The SOP does not say which controls. It directs questions on its environmental policy to “local SBA counsel for the area where the Property is located” (Paragraph E.9). Before ordering less than a Phase I for a propane or firewood dealer, get the lender’s position in writing; the lender can take the question to SBA counsel.

For gas stations, Paragraph E.4.a is direct: a code that begins with 457 means the investigation must begin with a Phase I, and the lender must also “refer to and, if applicable, comply with” Appendix 7. Appendix 7 covers loans secured by real property or station equipment “currently used to operate a gas station or commercial fueling facility.” It adds an independent EP for the Phase I, a review of all relevant records including the seller’s, documented compliance with tank and equipment testing rules, an independent EP with a current PE or PG license and the equivalent of 3 years of full-time relevant experience for any Phase II, and no disbursement until the equipment fully complies.

The 2022 NAICS revision moved gas stations and fuel dealers into a new 457 subsector (see the Census 2022 to 2017 concordance), so a list or report that still shows 447 uses pre-2022 codes, and a 2017 code needs translating before you compare it:

We checked all 1,150 rows of the concordance. Apart from these 3 codes, the only 2022 change that touches Appendix 6 moved some online and direct-selling vehicle, parts and tire retailers (parts of 2017 codes 454110 and 454390) into 441, which is listed only if service bays are present.

Units in a multi-unit building

A “Multi-Unit Building” is “any non-industrial, multi-unit building that is comprised of four or more individual units” (Appendix 4). For a unit in one, such as an office condo, the NAICS check is not required and the loan-amount steps apply (Paragraph E.4.a). The shortcut covers a unit, not a whole building. And because Paragraph E.6.b reaches “any Property with on-site dry cleaning facilities,” current or historical, a unit that housed a dry cleaning plant using, or likely using, chlorinated or petroleum-based solvents still needs a Phase I and a Phase II, on our reading of the SOP. The fuel footnote is not part of the NAICS check either, so a unit whose business sells, supplies or dispenses fuel should still start with a Phase I.

How to find the right NAICS code

The Census Bureau says “There is no central government agency with the role of assigning, monitoring, or approving NAICS codes for establishments” (Census NAICS FAQs). Various agencies assign codes for their own purposes. For its own statistics, Census gives each establishment one code for its primary activity, generally the one with the most revenue.

1. Search the Census 2022 NAICS list by keyword and choose the code closest to the main activity at the property.
2. Check the code against what happens on site. A code describes the main activity, not the facts that decide a conditional entry. Census includes in 441110 New Car Dealers those that sell cars “in combination with activities, such as repair services,” but the 441 entry turns on whether service bays are present. A convenience store with fuel pumps belongs in 457110, which matches, not in 445131 Convenience Retailers, which Census limits to stores “except those operating fuel pumps.” The conditions and the fuel footnote exist for these facts.
3. Treat a tax-return code as a lead. IRS business activity codes “are based on” NAICS, and a corporation enters one on Form 1120, Schedule K, line 2a (IRS Instructions for Form 1120). Some are broader than the Census codes, and compared literally these 6 miss Appendix 6 entries:

Use 2022 codes, the current edition and the one Appendix 6 is written in: the 457 subsector exists only in 2022 NAICS.

Worked examples

Each row assumes no other current or known prior use matches and the business does not sell fuel.

What to order after the lookup

If a use matches: order a Phase I Environmental Site Assessment (ESA) to ASTM E1527-21, performed by an EP who meets 40 CFR 312.10 and delivered with the SBA Appendix 5 reliance letter (Paragraph E.3). Add the Phase II for a dry cleaning plant covered by Paragraph E.6.b, or the Appendix 7 work for an operating gas station; a car wash only site may start with a Transaction Screen instead. Record the facts behind any condition in the loan file.

If nothing matches and the business does not sell fuel: up to and including $250,000, the investigation may begin with an Environmental Questionnaire, which the lender completes or reviews after a site visit and the current owner or operator signs. Above $250,000, the minimum is a Questionnaire plus an RSRA. At either loan size, a Questionnaire the current owner or operator will not sign cannot be used, and the lender must obtain at least a Transaction Screen (Appendix 4); the SOP does not say whether that screen also stands in for the RSRA on a loan over $250,000, so ask the lender. A Questionnaire that shows a concern leads to at least an RSRA, and an RSRA rated anything other than “low risk” leads to a Phase I.

These are SBA’s minimums. A lender’s own policy can require more, and every report must be dated within one year of the date the SBA loan number is issued (Paragraphs E.2 and E.3). The SBA environmental requirements guide walks through each path, the SOP 50 10 8.1 environmental requirements explainer covers what the new SOP did and did not change, and the SBA environmental requirement checker gives a result for a specific loan.

We prepare the third-party reports on both paths (the lender completes or reviews the Questionnaire): a Phase I ESA for $1,495 flat on standard-scope properties in 5 business days, with a fixed quote within 1 business hour for sites with manufacturing or heavy industrial use; an SBA RSRA for $695 in 2 business days that starts with a NAICS check against Appendix 6; and a Transaction Screen for $795 in 4 business days. The full $695 RSRA fee is credited toward a Phase I on the same property ordered within 30 days.

Sources

1. SOP 50 10 8.1, Lender and Development Company Loan Programs with Technical Policy Updates, U.S. Small Business Administration (published September 25, 2026, effective October 1, 2026; Section A, Chapter 5, Paragraph E and Appendices 4, 5, 6 and 7), accessed October 2026.
2. Table of Size Standards, U.S. Small Business Administration, accessed October 2026.
3. North American Industry Classification System: 2022 NAICS Search and FAQs, U.S. Census Bureau, accessed October 2026.
4. 2022 NAICS Descriptions, U.S. Census Bureau, accessed October 2026.
5. 2022 NAICS Index File, U.S. Census Bureau, accessed October 2026.
6. 2022 NAICS to 2017 NAICS Concordance, U.S. Census Bureau, accessed October 2026.
7. Instructions for Form 1120 (2025), Principal Business Activity Codes, Internal Revenue Service, accessed October 2026.