The H141 waste code is an EPA Management Method Code meaning “storage and transfer” — it tells regulators that a receiving facility stored or bulked a hazardous waste shipment and moved it elsewhere without performing any treatment, recovery, or disposal on-site. EPA will retire H141 on January 1, 2027, and replace it with a set of more specific S-series codes that identify what actually happens to the waste downstream.1US EPA. January 2025 EPA Waste Management Updates Newsletter
What H141 Actually Describes
Management Method Codes describe how a facility handles hazardous waste once it arrives. They are separate from waste codes, which describe what the waste itself is. H141 sits in the management-method family and carries one specific meaning: the receiving site stored or bulked the waste and shipped it out, with no reclamation, recovery, destruction, treatment, or disposal happening at that site.2RCRAInfo. Nationally Defined Values – Biennial Report Management Method
In practice, H141 shows up most often at transfer stations, consolidators, and brokers. These are the middle links in the hazardous waste chain: they take material from generators, hold it, sometimes bulk it into larger containers, and then send it on to a facility that will actually treat, recover, or dispose of it.
Where H141 Appears on the Manifest
On the Uniform Hazardous Waste Manifest (EPA Form 8700-22), Management Method Codes go in Item 19, and in Item 36 of the continuation sheet.3US EPA. Uniform Hazardous Waste Manifest – Instructions, Sample Form and Continuation Sheet The designated treatment, storage, or disposal facility enters the code — not the generator. If you’re a generator looking at your returned manifest copy and you see H141 in Item 19, that means the facility that received your waste stored and transferred it rather than doing final management.
H141 also appears in the Hazardous Waste Biennial Report that large quantity generators and TSDFs submit to EPA every two years.
Why EPA Is Retiring the Code
H141 lumped every kind of storage-and-transfer activity into a single code. A facility that bulked waste before metals recovery looked identical on paper to one that consolidated waste headed for landfill disposal. Regulators couldn’t tell from the reporting data what ultimately happened to any given waste stream once it left the first receiving site.
The retirement date is firm: EPA will permanently remove H141 from both e-Manifest and the Biennial Report on January 1, 2027.1US EPA. January 2025 EPA Waste Management Updates Newsletter After that date, the code will not be an option in either system.
The S-Series Codes That Replace H141
The replacement codes have been available in e-Manifest since January 2025. Facilities can start using them right away, and EPA is encouraging the transition well ahead of the deadline.1US EPA. January 2025 EPA Waste Management Updates Newsletter Each S-code combines “stored and transferred” with the waste’s next destination:
- S010 — stored and transferred for metals recovery
- S020 — stored and transferred for solvents recovery
- S039 — stored and transferred for other recovery or reclamation for reuse
- S040 — stored and transferred for incineration
- S070 — stored and transferred for chemical treatment
- S100 — stored and transferred for physical treatment only
- S110 — stored and transferred for stabilization
- S132 — stored and transferred for landfill (with prior treatment or stabilization)
- S134 — stored and transferred for deepwell or underground injection
Additional S-codes cover biological treatment, neutralization, evaporation, thermal desorption, and other management methods. The right code for a given shipment depends on the actual downstream fate of the waste, which the storage-and-transfer facility needs to know from its receiving customer or its own outbound shipping records.
How to Transition Before January 2027
If your facility currently uses H141 on manifests or biennial reports, the practical work is a waste-stream-by-waste-stream review. For each stream you receive and forward, identify where it actually goes next and match it to the S-code that describes that management method. A stream headed for a solvent recycler becomes S020. A stream headed for a stabilization-then-landfill pathway becomes S110 or S132 depending on which step you’re documenting.
Picking the wrong S-code is better than continuing to use H141 past the deadline, but getting the classification right now avoids amended reports later. Facilities with dozens of routine waste streams may find it easier to build a lookup table tying each customer waste code plus outbound destination to a single S-code, rather than deciding case-by-case at the desk.
Don’t Confuse H141 With California Waste Code 141
Because the number “141” appears in both, these codes get mixed up constantly, but they belong to different systems and mean different things. California’s state waste code 141 designates “off-specification, aged, or surplus inorganics” — dry, solid inorganic materials that are hazardous under California law.4Department of Toxic Substances Control. California State Hazardous Waste Codes That is a waste description code (what the material is), not a management method code (what a facility did with it).
On the manifest, California state waste codes go in Item 13 alongside any applicable federal RCRA codes.5Department of Toxic Substances Control. Manifest Regulations – Frequently Asked Questions H141 (soon an S-code) belongs in Item 19 and is entered by the receiving facility. If you see “141” on paperwork, check which item it’s in and which system you’re reading: a California waste code in Item 13 tells you what’s in the drum, while an EPA management method code in Item 19 tells you what the receiving site did with it.
What to Do Now
If you’re a generator, you don’t enter H141 yourself, but you should expect to see S-codes rather than H141 on returned manifests going forward, and your biennial report data will read differently once the transition completes. If you operate a storage-and-transfer facility, the work is on your side of the ledger: map each waste stream to the S-code that reflects its true downstream management, start using those codes in e-Manifest, and phase H141 out of your reporting well before January 1, 2027.