As we begin the new year, there are two federal regulatory updates that we want you all to be aware of, a refinement in Management Method Codes (MMC) and clarifications in the Electronic Hazardous Waste Manifest program. Please note the following:
New Management Method Codes:
Management method codes describe the type of hazardous waste management system used to treat, recover, or dispose a hazardous waste and are entered onto Hazardous Waste Manifests by the respective TSDFs as well as being recorded on state and federal waste generator reports including the Biennial report. A common code utilized throughout the years has been H141 which is utilized when the site receiving this waste stored/bulked and transferred the waste with no treatment or recovery (H010-H129), fuel blending (H061), or disposal (H131-H135) at that receiving site (in effect temporary storage) to another facility for ultimate disposition. Late last year the USEPA announced that they will be adding new Management Method Codes by expanding the H141 MMC code. According to USEPA these codes will begin with an S and indicate how waste will be managed after storage and transfer. They are intended to replace the code H141 for Storage and Transfer. The new codes will be available for use on January 1, 2025, for the 2025 Biennial Report Cycle and e-Manifest. The S Codes will be available in e-Manifest in January 2025 and will be allowed in the 2025 Biennial Report, as well as the 2026 Annual Report (in certain states) however H141 may continue to be used in the stead of the new S codes until January 1, 2027. It will be up to the individual TSDFs to begin to use the new S codes during this two-year transition period. The agency is urging the TSDFs and others affected to begin to utilize these new codes as soon as practicable. Generators should begin to look for these new MMC codes for any shipments post January 1, 2025. The Management Method Codes to be added on January 1, 2025 as follows:
Code – Description
S010 – STORED AND TRANSFERRED FOR METALS RECOVERY
S011 – STORED AND TRANSFERRED FOR MERCURY RECOVERY
S015 – STORED AND TRANSFERRED FOR DEPLOYMENT/DEACTIVIATION 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 HW CHARACTERISTICS OR TO ACHIEVE DELISTING LEVELS
S120 – STORED AND TRANSFERRED FOR COMB. OF CHEMICAL, BIOLOGICAL, AND/OR PHYSICAL TRT
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
Electronic Hazardous Waste Manifest Clarifications:
Registration/Manifest Distribution – As mentioned throughout 2023, all LQG and SQG’s must be registered in USEPA’s RCRA info portal (See our November Update for instructions) by January 22, 2025 in order to ensure that they receive the required executed manifest copies. TSDFs will no longer be required to distribute hard copy executed manifest copies to generators as it is expected that they will receive their copies via the e-Manifest portal on their RCRAinfo site. WTS has canvassed all of our TSDF partners and we can report that the following will no longer be returning hard copy manifest copies after January 22: Veolia and Waste Management (Chemical Waste Management). It is expected that the vast majority of the TSDF community will also transition to no hard copy distribution in 2025 as well. WTS will continue to monitor and report on the topic.
New 4-Page form and International shipments:
As we covered in our recent e-Manifest communications (November Update), one of the recent developments in the federal e-Manifest program is the transition of the existing 5-page paper form to a 4-page form. The “Designated Facility Copy” has been removed since it is redundant as the TSDFs are required to scan the top copy and send it electronically to EPA. At issue is that the authorized manifest printers have not yet made the new form widespread commercially available. Therefore, USEPA has announced that they will accept, and the “old” 5-page form can continue to be used until December 1, 2025, with the caveat that they are strongly urging that users transition to the 4-copy manifest as quickly as possible. WTS will transition and provide to the new 4-page form as soon as practically possible based on availability of the new form and depletion of current stock.
- International Shipments: As previously discussed, both import and now export (Beginning on December 1, 2025, domestic exporters must submit export manifests to e-Manifest and pay the requisite user fees.) Hazardous Waste shipments will be part of the e-Manifest program. The new 4-page manifest document has been modified to remove the International Shipment in Section 16. International Shipments will now require the use of a continuation page as they have created a new section #33 on the continuation page for international shipments. The US Exporters EPA ID Number will be required to be entered in section 33a as well as entering import/export Waste Stream Consent Numbers in the new 33b section. This will be effective on January 22, 2025. However, due to the lack of the new 4-page document as well as the new updated continuation sheet being commercially available, the agency will continue to allow the use of the 5-page document as long as the import/export consent numbers are entered in section 14 (per line item) as well as the exporters EPA ID#. This practice will only be allowed until December 1, 2025. Also, effective that date the last transporters must provide the export manifests and continuation sheets to the exporters.
Please note that also on December 1, 2025, all entities must submit Discrepancy, Exception, and Unmanifested Waste Reports to the e-Manifest system.
As always, please do not hesitate to contact your WTS representative if you have any questions on this matter.
