I. Executive Summary

The U.S. Environmental Protection Agency (EPA) has announced a major revision to hazardous-waste reporting under the Resource Conservation and Recovery Act (RCRA). Effective January 1, 2027, EPA will retire Management Method Code H141, historically used for “Storage and Transfer,” and replace it with a suite of new “S-series” codes intended to provide more precise reporting of waste handling activities before final management.

The new S-codes are already active in EPA’s RCRAInfo platform, meaning facilities may begin using them immediately and are strongly encouraged to begin transitioning well before the 2027 deadline.

For IHMM certificants—many of whom routinely interact with RCRA reporting systems, hazardous-waste vendors, program audits, and facility-level compliance operations—this change is material. Facilities will need to update internal procedures, software interfaces, manifests, and personnel training.

II. EPA Sources and Official References

These are the authoritative locations where EPA maintains the new codes and supporting information:

1. RCRAInfo “Nationally-Defined Values – Management Method Codes”

Includes full list of management method codes, including the new S-codes, with definitions:
https://rcrainfo.epa.gov/rcrainfo-help/application/ded/nationallydefinedvalues/biennialreportmodule/ndv-biennialreportmanagementmethod.htm

2. EPA’s Traditional H-Code Listing (Legacy Codes PDF)

Shows historic H-coding system, including H141:
https://www.epa.gov/sites/default/files/2015-06/documents/codes.pdf

3. RCRAInfo Homepage (for account holders, system updates, and release notes)

https://rcrainfo.epa.gov

III. Practical Impact for IHMM Certificants

A. Who Is Affected?

The rule change primarily affects:

  • Commercial TSDFs and transfer facilities

  • Generators who use brokers, consolidators, or third-party waste handlers

  • Facilities reporting under the Hazardous Waste Biennial Report

  • Environmental managers responsible for RCRA compliance and auditing

B. Key Compliance Considerations

  1. Internal Reporting Systems Must Be Updated.
    Facility systems referencing H141 will require re-programming and validation.

  2. Contracted TSDFs May Shift Coding Responsibilities.
    Certificants should confirm when vendors will implement S-codes and whether manifests, e-manifesting, and billing software will be revised.

  3. Training Is Required.
    Both facility staff and contracted compliance personnel will need updated training on S-code applicability.

  4. Data Quality Expectations Will Increase.
    Because S-codes are more granular, EPA will have enhanced visibility into:

    • Waste consolidation practices

    • Off-site transfers

    • Whether waste is ultimately reclaimed, treated, or disposed

IV. Side-by-Side Comparison: Legacy “H” Codes vs. New “S” Codes

The table below summarizes how H141 and related H-codes correspond to the new S-series codes. (Note: Some S-codes are direct functional replacements; others provide more granular distinctions.)

A. Storage / Transfer (Primary Change)
Purpose / ScenarioLegacy Code (H-series)New Code (S-series)
Storage, bulking, or transfer of hazardous waste prior to shipment to final managementH141 — “Storage and Transfer”Replaced by S-codes depending on ultimate management method (see tables below)
B. Transfer for Reclamation / Recovery / Reuse
Final Management MethodLegacy H-codesNew S-codes
Metals recoveryH010, H020, H039S010 — metals recovery
Mercury recovery—S011
Airbag recovery—S015
Solvent recoveryH020, H039S020
Other reclamation / organics recoveryH039S039
Energy recovery (fuel use)H050S050
Fuel blending prior to energy recoveryH061S061
C. Transfer for Treatment (Non-Disposal)
Treatment CategoryLegacy H-codesNew S-codes
Incineration/thermal destruction (non-fuel)H040S040
Open burning / open detonationH041, Subpart XS041
Thermal desorptionH042S042
Chemical treatment (oxidation, reduction, precipitation)H071, H073, H075, H076, H077S070
Biological treatmentH081S081
Polymerization (e.g., to meet LDR)—S090
Physical treatment (adsorption, absorption, separation, stripping, dewatering)H082, H083, H101, H103, H123, H124S100
Stabilization / fixationH111, H112S110, S113
Combined treatment methodsH071 + othersS120
NeutralizationH071S121
EvaporationH122S122
Other treatmentH129S129
D. Transfer for Final Disposal
Final Disposal MethodLegacy H-codesNew S-codes
Land treatment / land applicationH131S131
LandfillH132S132
Surface impoundment (closed as landfill)H130S130
Underground injection / deep-well disposalH134S134
V. Recommended Actions for IHMM Certificants

  1. Review your current RCRA reporting systems for any reliance on H141.

  2. Notify your TSDFs, brokers, and consultants regarding transition timing.

  3. Implement training updates for CHMMs, CHMPs, AHMMs, and facility teams.

  4. Document transition steps for audit trails and biennial reporting preparations.

  5. Use the new codes immediately in RCRAInfo, even before 2027, to avoid last-minute compliance risk.

VI. Conclusion

EPA’s transition from H141 to the more detailed S-code structure represents a fundamental modernization of hazardous-waste reporting. IHMM certificants play a critical role in implementing these changes by ensuring accurate classification, updated facility compliance procedures, and rigorous documentation. Early adoption will significantly reduce the operational risk associated with the January 1, 2027 deadline.