For decades, one management method code has appeared on more hazardous waste reports than any other: H141. If your facility has shipped waste to a TSDF for storage and transfer, you have seen it. The code told EPA that waste arrived at a facility, was stored, bulked, and consolidated, then transferred out. It did not provide end-of-life visibility and say where that waste went next.
That gap is closing. Effective January 1, 2025, EPA introduced a new set of management method codes, known as S-codes, to replace the catch-all H141 code on hazardous waste reporting. The old code remains valid during a transition period, and EPA has set January 1, 2027 as the date it will be fully retired. Generators, TSDFs, and anyone who touches a waste profile, manifest, or biennial report will feel this shift.
These new codes will show up on the documents that drive daily waste management compliance work: the hazardous waste manifest, the biennial hazardous waste report, and the waste profile that determines how a shipment is classified and handled from the moment it leaves a generator’s site. Anyone responsible for completing or reviewing those documents will encounter S-codes as TSDFs bring them online.
Why EPA Made the Change
Under the old system, H141 covered one specific situation: waste received at a TSDF for storage, bulking, and consolidation. Waste destined for recovery, fuel blending, or disposal at the receiving facility was never reported under this code; those activities carried their own specific management codes. What the catch-all code left open was the next step. Once the waste was consolidated and sent out the door, the receiving facility determined its end-of-life disposal path, and the reported code revealed nothing about that final destination. EPA’s national reporting carried the same limitation, since aggregate volumes under a single storage-and-transfer code said little about where that waste was ultimately disposed of.
The new S-codes close that gap by identifying where the waste goes once it leaves the storage and transfer facility. Instead of a single catch-all entry, TSDFs will report the code that matches the waste’s actual final destination, whether that is recovery, thermal treatment, chemical or physical treatment, or a form of land-based disposal.
The New Codes at a Glance
EPA’s S-code system includes 21 management methods, organized loosely by category.
Recovery and reclamation codes cover metals recovery (S010), mercury recovery (S011), airbag waste deployment and deactivation (S015), solvents recovery (S020), and other recovery or reclamation for reuse (S039).
Thermal management codes cover incineration (S040), open burning or open detonation (S041), and thermal desorption (S042).
Treatment codes cover chemical treatment (S070), biological treatment (S081), polymerization (S090), physical treatment only (S100), stabilization (S110), stabilization to remove hazardous characteristics or reach delisting levels (S113), combined chemical, biological, and physical treatment (S120), neutralization only (S121), evaporation (S122), and other treatment methods not otherwise listed (S129).
Land-based and injection disposal codes cover surface impoundment that will later close as a landfill (S130), land treatment or application (S131), landfill disposal with prior treatment or stabilization (S132), and deepwell or underground injection (S134).
Each code narrows the old catch-all into a specific, reportable destination. A waste stream that once arrived and left under a single H141 entry may now be split across several S-codes, depending on where each portion of that stream is ultimately sent for disposal.
What This Means for Generators
Waste profiles, manifests, and biennial reports will begin reflecting these codes as TSDFs adopt them. Generators working with a facility that has strong visibility into its own downstream processes will see reporting that more accurately reflects where their waste is actually sent. That level of detail supports stronger internal recordkeeping and gives EHS, sustainability, and procurement teams a clearer view of waste outcomes across their supply chain.
Cradle-to-grave responsibility already requires this transparency in principle. Even after a TSDF signs the manifest and takes ownership of a shipment, the law obligates the facility to tell generators where their waste ends up. The S-codes give that longstanding obligation a standardized reporting structure, so the disposition a generator learns about is captured in a consistent, comparable code across facilities. TSDF partners that have already mapped their outbound waste streams to the new codes will be positioned to provide that disposition information without delay.
For generators managing waste across multiple states or working with a TSDF network that spans several end disposal facilities, this transition adds a layer of complexity worth planning for early. Multiple waste streams generated at a single site may be routed to different facilities, and each destination facility’s process determines the S-code that applies, meaning waste from one location could carry several different S-codes across its various streams. Generators who understand how their TSDF partner classifies and tracks each waste stream will be better equipped to keep their own reporting accurate as the codes roll out.
“H141 was always the catch-all. Waste came in, we stored it, bulked it, consolidated it, and sent it on. The S-codes finally put a name on that next step, so a generator can see exactly where their waste ends up.” – Wendy Mason
State-by-State Adoption
The S-codes are active at the federal level, and individual states will be rolling out their own adoption of the new reporting requirements on their own schedules. Some states may also layer additional reporting rules on top of the federal codes. Generators operating in multiple states should stay aware of adoption activity in each state where they ship waste, since requirements will phase in unevenly as state programs incorporate the change.
Preparing Your Program Now
Waiting until H141 disappears in 2027 is not a workable approach, since profile updates, recordkeeping changes, and internal training all take time to implement. Generators can start now with a few practical steps: ask current TSDF partners how they track waste from receipt through end-of-life disposal, and brief internal EHS and procurement staff on what these codes mean before the questions start coming from auditors or customers.
The shift from H141 to S-codes is a reporting change on the surface. Underneath, it closes the loop on cradle-to-grave visibility: the volume of hazardous waste moving through the system has always been tracked, and now the reporting shows where that volume ends up. Facilities and generators that treat this transition as a chance to sharpen their own recordkeeping will be ready well before the old code disappears for good.
