Daniels Training Services

Q&A: Must entries on the uniform hazardous waste manifest be made from “most hazardous” to “less hazardous”?

Q&A: Must entries on the uniform hazardous waste manifest be made from “most hazardous” to “less hazardous”?

A question from a previous customer (I encourage my past customers to contact me anytime with questions that I gladly answer at no charge):

Hi Dan,

I hope all is well! I have a quick question regarding manifest line item ordering. I seem to remember we talked about this when you did the training here some time back. But it’s come up again and I think old thinking may have crept in.

My transportation folks are telling me that when ordering the line items on a manifest, not only must the hazardous (RCRA) come BEFORE the nonDOT (nonRCRA) [which I agree with, unless one is using one of the other methods of making it stand out as described in 49 CFR]…. But they are also telling me that we must further order them in order by hazard class (more hazardous coming before less hazardous classes). I can find this nowhere in our training, in 49 CFR 172.201, in any of the PSHMA interpretation letters or when I try searching various terms in a general Google search.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.




Can you confirm for me? Is there such are a requirement to list line items in order of DOT hazard class or is it simply that one should put RCRA waste first, nonRCRA next and non haz last. But the order of various RCRA wastes do not have to be specifically ordered by hazard class?

I would be forever in your debt (as always).

My reply that same day:

You are correct.  While USDOT/PHMSA requires the shipper to make the HazMat distinct and separate from the non-HazMat on the shipping paper (read: How to distinguish HazMat from non-HazMat on the shipping paper) there is no requirement to list hazardous materials in any particular order.  The suggestion of your last paragraph will suffice.

Also, the hazard classes used by USDOT/PHMSA to characterize hazardous materials are not a reflection of how hazardous they are.  In other words, a compressed gas of hazard class 2 is not more dangerous than a flammable liquid of hazard class 3.  The best indication of the degree of danger of a HazMat is indicated by its Packing Group, but even this can not be applied in this manner as some HazMat do not have a Packing Group and for those that do the it solely indicates the degree of danger within the hazard class and is not to be used for comparison between hazard classes.  In short:  It is impossible to rank hazardous materials from more hazardous to less hazardous.

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