Minnesota Department of Transportation

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Regulated Materials

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In-House Paint Removal by Abrasive Blasting on-site at MnDOT Facilities

This guidance document is prepared by MnDOT personnel and is intended only for use on MnDOT projects, including partnership projects, and MnDOT Maintenance Operations.

Any optional procedures will be indicated in the document. Any deviation from procedures contained in this document must be discussed with Regulated Materials Unit personnel prior to implementation.

This document should not be construed as a full description of all regulations pertaining to the subject matter. Contact the Regulated Materials Unit in the MnDOT Office of Environmental Stewardship for additional information or legal requirements.


Products used for paint removal by blasting may include sand, coal slag, steel shot, or commercial products such as Blastox. The Minnesota Pollution Control Agency (MPCA) regulates proper containment of particulate blasting activities for lead and non-lead paint removal. The MPCA also regulates proper management of the blasting residue generated by paint removal activities.

General Requirements

  • Air Quality rules state that reasonable measures must be taken to prevent emission of sandblasting particles. A good rule of thumb is to prevent any visible emissions from escaping the containment surrounding the working area. Containment is required for both lead and non-lead paint sandblasting operations.
  • In addition to controlling emissions, work area containment enhances the ability to collect the waste blasting residue for proper disposal.
  • Failing to contain even non-lead paint chips can result in illegal disposal of a waste material. Any visible paint chips or blasting residue that escapes containment area must be collected for proper disposal.
  • Contact your District Safety Administrator and your District Waste Management Coordinator prior to any paint removal operation.

Lead Paint Determination and Disposal Requirements

  • Determine if paint is lead or non-lead.
  • Non-lead paint has lead content less than 0.5% lead by weight. Non-lead blasting residue must be disposed of as an industrial solid waste. Contact and obtain written permission from the industrial landfill before disposing.
  • Lead paint has lead content equal to or greater than 0.5% lead by weight. When blasting lead paint or paint of unknown composition, the blasting residue must be managed as a hazardous waste, unless the particulate used for blasting is the commercial product Blastox.

Blastox has the capability to make the final composition of the blasting residue non-hazardous. When using Blastox as the blasting media, the blasting residue must be analyzed for RCRA metals in accordance with TCLP methodology to confirm the waste is non-hazardous. If TCLP analysis demonstrates the blasting residue is non-hazardous, it can be disposed of as an industrial waste. Contact and obtain written permission from the MPCA permitted Sanitary Landfill or Industrial landfill before disposing.

Containment for Both Lead and Non-Lead Paint Removal

  • Minimum containment may consist of three walls and a roof over a paved surface or ground cover (tarp) that will prevent air emissions from escaping the work area and facilitate collection of the blasting residue.
  • Curtains: Curtains used for containment must be rated by the manufacturer as 100 percent impermeable and be in good condition without holes or tears. If using multiple curtains, adjoining curtains must overlap at least three feet unless the edges are completely joined.
  • Wind Speed Limitation: Do not conduct paint removal whenever wind speeds render the curtains and ground cover ineffective for containment.

Cleanup of Waste Material

  • Collect all visible paint particles and blasting residue containing paint at the end of each workday from the work area. Inspect outside the containment and collect any paint particles or blasting residue that escaped the work area. Collect waste material by manual means or by vacuum. Do not use air pressure or streaming water to assist in waste collection because these activities will disperse the waste material. Methods of handling and storage of waste material must prevent formation of dust or loss of material.

Storage and Disposal

If the blasting residue is an industrial waste, the following is required: Store in a drum that meets US DOT requirements of a 1A2 or 1H2 container.

  • Label drum as “Blasting Residue”.
  • Store drum in designated storage area away from outside elements.
  • Arrange with an MPCA permitted Mixed Municipal Solid Waste Landfill or MPCA permitted Industrial Landfill for disposal.

If the blasting residue is a hazardous waste, the following is required: Store in a drum that meets US DOT requirements of a 1A2 or 1H2 container.

  • Label drum as “Blasting Residue” and “Hazardous Waste”.
  • Write the date on drum.
  • When the drum is full, date and move the drum to the hazardous waste storage area within 3 days.
  • Arrange disposal with MnDOT hazardous waste contractor.

Recordkeeping and Transportation if Nonhazardous

Records shall be kept indicating the name and address of the Landfill, date accepted by the landfill and amount of blasting residue. Manifest, shipping papers, and receipts are all acceptable means of recordkeeping.

When consolidating at one MnDOT facility, if not a hazardous waste, the MnDOT facility receiving the waste must record on a written log (see template) the following information: name and address of the facility shipped to (receiver); name and address of the facility shipped from (generator); quantity shipped; and dates of shipment and delivery. (A copy of the VSQG shipping paper on file can be used in place of a written log.)

Records must be filed on site for a minimum of three years. After three years, the record should be sent to OES for permanent storage.

MnDOT personnel can transport with MnDOT vehicles.

Recordkeeping and Transportation if Hazardous

Records shall be kept indicating the name and address of the receiver, date accepted by the receiver and amount of paint waste. MnDOT must use its hazardous waste contractor for shipping off site using a hazardous waste manifest.

When consolidating at a MnDOT facility (Metro District cannot do) if hazardous, districts can transport waste under the VSQG consolidation program. The receiving and generating facilities must both retain a copy of the VSQG consolidation shipping paper.