Agency adds new temporary hazardous waste storage, transfer codes

The Environmental Protection Agency (EPA) has added new Management Method Codes to describe how hazardous waste will be managed after temporary storage and transfer. The codes are used for Biennial Hazardous Waste Reports and e-Manifests required by the Resource Conservation and Recovery Act (RCRA).

What are the changes?

The new “S Codes” are effective as of January 1, 2025. The S Codes will ultimately replace code H141 for Storage and Transfer for the RCRA Biennial Reports and e-Manifests (to be removed on January 1, 2027).

Hazardous waste handlers will use the S Codes on the Biennial Report Waste Generation and Management (GM) forms. The S Codes indicate that (a) hazardous waste was received to be stored or transferred and (b) the hazardous waste will later be managed by a final receiving facility using a specific method.

What are the new codes?

The new Management Method Codes include the following:

When do the new codes apply?

Handlers may use the new S Codes on the 2025 Biennial Report GM form, on the 2026 Annual Report in some states, and for e-Manifests. While handlers may continue using code H141, EPA recommends shifting to S Codes before January 1, 2027, when code H141 will be removed.

Key to remember: EPA’s new S Codes indicate how the final receiving facility will manage temporarily stored and transferred hazardous waste.