Navigating the EPA’s 2025 S-Code Updates for Hazardous Waste Storage and Transfer

The U.S. Environmental Protection Agency (EPA) recently announced a major update to Management Method Codes for hazardous waste. These changes aim to improve data precision and reporting clarity while replacing the widely used H141 code. Here’s what you need to know about this critical update and how Wastebits can help your organization stay ahead of the curve.

Understanding the Changes

New S-Codes for Storage and Transfer

Effective January 1, 2025, the EPA will introduce new Management Method Codes beginning with the letter “S.” These codes specify how hazardous waste will be managed after temporary storage or transfer, providing clarity for generators and regulators. The changes respond to feedback from the recent Biennial Report Cycle and questions about data entry accuracy.

The new codes are designed to:

• Replace the current H141 code for “Storage and Transfer.”
• Indicate the ultimate disposal or treatment method.
• Streamline the process of filing Biennial Reports and e-Manifests.

While the H141 code will remain valid until January 1, 2027, handlers are encouraged to begin incorporating the new S-codes in their operations as early as possible.

What Are the New S-Codes?

Below is a table of the new S-codes, effective January 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
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 Hazardous Waste Characteristics or to Achieve Delisting Levels
S120	Stored and Transferred for Combination of Chemical, Biological, and/or Physical Treatment
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

These codes correspond to how waste will ultimately be handled at the final receiving facility, ensuring greater transparency and compliance.

Why This Matters

Enhanced Data Precision

The introduction of S-codes eliminates ambiguity about how waste will be managed after storage, helping both generators and regulators make more informed decisions.

Streamlined Reporting

With the updated codes, Biennial Reports and e-Manifests will more accurately reflect waste management practices, reducing errors and simplifying audits.

Future-Proof Compliance

By transitioning early to the new S-codes, your organization can avoid disruptions when H141 is retired in 2027. Generators who adopt the new codes will also gain a head start in aligning with best practices for hazardous waste management.

How Wastebits Can Help

At Wastebits, we’re committed to simplifying waste management for generators, transporters, and receiving facilities. Our software solutions are fully equipped to support these updates, ensuring:

• Seamless Integration: Easily transition to the new S-codes within e-Manifest and reporting workflows.
• Real-Time Updates: Stay compliant with EPA regulations as changes occur.
• Expert Guidance: Our team is available to help your organization implement these changes smoothly.

Next Steps

Now is the time to prepare for these updates. Here’s how you can get started:

1. Review Your Processes: Identify where you currently use the H141 code and plan for the transition to S-codes.
2. Train Your Team: Ensure your staff understands the new codes and their impact on operations.
3. Contact Wastebits: Schedule a demo to see how our software can streamline this transition and enhance your reporting capabilities.

The new S-codes mark a significant step forward in hazardous waste management, offering greater clarity and precision for all stakeholders. Don’t wait until the 2027 deadline—start incorporating these changes today to ensure compliance and efficiency.