Mandatory transition date: January 1, 2027
EPA has added a new series of RCRA Management Method Codes, beginning with the letter “S,” for hazardous waste received by a storage or transfer facility and then sent onward for final recycling, recovery, treatment, or disposal. These codes are intended to replace H141, the current “Storage and Transfer” code, which indicates that the receiving facility stored, bulked, and transferred the waste without performing reclamation, recovery, destruction, treatment, or disposal at that site.
This change does not revise hazardous waste determinations, generator status, or accumulation requirements. It does affect how off-site hazardous waste management is documented in e-Manifest, Biennial Reports, and certain state annual reports. Generators should understand the change because the codes may appear on manifests and describe the ultimate management pathway for waste that first moves through a storage, bulking, or transfer facility.
Why This Matters
- H141 may continue to be used during the transition period, but EPA recommends incorporating the new S-codes before January 1, 2027.
- The S-codes provide more detail than H141 by identifying how the waste will ultimately be managed after storage or transfer.
- Facilities that rely on waste vendors, brokers, consolidators, or transfer facilities may need to update manifest review procedures, waste tracking logs, and reporting workflows.
- Generators should coordinate with their TSDFs and waste vendors now to confirm when the vendor will begin using S-codes and how common waste streams will be mapped.
The change is most likely to affect facilities whose hazardous waste manifests currently show H141; facilities that ship waste through a transfer facility before final management; large-quantity generators preparing Biennial Reports; and facilities in states that require annual hazardous waste reporting. Small quantity generators may also see these codes on manifests and should verify vendor practices, even when a Biennial Report is not required federally.
What’s Changing?
Instead of using H141 as a general storage-and-transfer code, the receiving facility will use an S-code that reflects the expected final management method after storage or transfer. For example, waste stored and transferred for later metals recovery would use S010, while waste stored and transferred for landfill disposal would use S132. The following table summarizes the new S Codes by general waste management category. The codes are used when hazardous waste is stored and transferred before the final management activity listed below.
| Category | Codes | Management Method |
|---|---|---|
| Reclamation / Recovery | S010, S011, S015, S020, S039, S050, S061 | Metals recovery; mercury recovery; airbag deployment/deactivation followed by metals recovery; solvent recovery; other recovery/reclamation for reuse; energy recovery; or fuel blending prior to energy recovery. |
| Destruction / Treatment Prior to Disposal | S040, S041, S042, S070, S081, S090, S100, S110, S113, S120, S121, S122, S129 | Incineration or thermal destruction; open burning/open detonation; thermal desorption; chemical, biological, physical, stabilization, neutralization, evaporation, polymerization, or other treatment prior to disposal. |
| Disposal | S130, S131, S132, S134 | Surface impoundment to be closed as a landfill; land treatment/application; landfill disposal; or deepwell/underground injection. |
| Storage / Rejection | S151 | Storage for rejection. Manifest only; not used for Biennial Report or state annual reporting. |
How To Prepare
- Review recent manifests and reports. Identify waste streams and vendors where H141 has been used during 2025 and 2026.
- Coordinate with your waste vendors. Ask TSDFs, brokers, and transfer facilities to confirm their transition schedule and S-code mapping for recurring waste streams.
- Update internal procedures. Revise manifest review procedures, waste shipment logs, waste profile review checklists, and Biennial or annual reporting workflows to recognize the new S-codes.
- Train affected personnel. Brief EHS staff, shipping coordinators, and anyone responsible for reviewing manifests or compiling hazardous waste reports.
- Confirm state-specific expectations. Some states may incorporate the new codes into annual reporting systems on different timelines. Facilities should verify state-specific reporting instructions before submitting annual or Biennial Report data.
How Can EDGE Help?
EDGE can support the transition by reviewing manifests for H141 usage, coordinating with waste vendors, mapping recurring waste streams to the appropriate S-codes, updating waste management procedures, and supporting Biennial or state annual hazardous waste reporting. Early review can help reduce reporting corrections and improve the accuracy of waste management records before the January 1, 2027 transition date.
