To improve hazardous waste data precision and address recurring data entry questions from the last Biennial Hazardous Waste Report cycle, the U.S. Environmental Protection Agency (EPA) has introduced new Management Method Codes related to the temporary storage and transfer of hazardous waste.
These codes begin with the letter “S” and will replace the code H141 to indicate how the waste will be managed after storage and transfer. For now, this is currently an addition of new codes. No existing management codes are being changed at this time.
Using the correct S code improves clarity to generators and regulators on how waste will be handled. It will help generators when filing their Biennial Report GM forms.
How the S Codes Work
The S codes correspond to how the waste will be managed by the final receiving facility. For example:
If a hazardous waste is sent to storage prior to metals recovery, the manifest and Biennial Report GM form should use S010 - Stored and Transferred for Metals Recovery. The final receiving facility will still report H010 - Metals Recovery.
Effective Dates
Available now:
The new S codes have been available in RCRAInfo since January 1, 2025 for the 2025 Biennial Report Cycle. The S codes are currently available in:
- e-Manifest
- 2025 Biennial Report
- 2026 Annual Report (in certain states).
Future removal of H141 for Storage and Transfer:
H141 will be removed on January 1, 2027 from both e-Manifest and Biennial Reporting.
Transition period:
H141 may still be used until January 1, 2027; however, EPA strongly recommends adopting the S codes now.
What You Should Do Now
- Begin incorporating the appropriate S codes in place of H141.
- Review waste profiles, manifests, and reporting templates.
Management Method Codes added on Jan. 1, 2025:
Code Description
S010 Stored and Transferred for Metals Recovery
S011 Stored and Transferred for Mercury Recovery
S015 Stored and Transferred for Deployment/Deactivation of Airbag Waste
S020 Stored and Transferred for Solvents Recovery
S039 Stored and Transferred for Other Recovery or Reclamation for Reuse
S040 Stored and Transferred for Incineration
S041 Stored and Transferred for Open Burning/Open Detonation
S042 Stored and Transferred for Thermal Desorption
S050 Stored and Transferred for Energy Recovery
S061 Stored and Transferred for Fuel Blending Prior to Energy Recovery
S070 Stored and Transferred for Chemical Treatment
S081 Stored and Transferred for Biological Treatment
S090 Stored and Transferred for Polymerization
S100 Stored and Transferred for Physical Treatment Only
S110 Stored and Transferred for Stabilization
S113 Stored and Transferred for Stabilization to Remove HW Characteristics or to Achieve Delisting Levels
S120 Stored and Transferred for Comb. of Chemical, Biological and /or Physical TRT
S121 Stored and Transferred for Neutralization Only
S122 Stored and Transferred for Evaporation
S129 Stored and Transferred for Other Treatment
S130 Stored and Transferred for Surface Impoundment That Will Be Closed as Landfill
S131 Stored and Transferred for Land Treatment or Application
S132 Stored and Transferred for Landfill - with prior treatment and/or stabilization
S134 Stored and Transferred for Deepwell or Underground Injection
How Enviro-Safe Resource Recovery Can Help
Enviro-Safe Resource Recovery has updated its systems and reporting practices to use the new S codes. If you have questions about which S code applies to your waste streams or how this change affects your reporting obligations, our compliance team is ready to assist you. Contact us by completing your information on our contact page or call us at (262) 790-2500.
