Regulated Materials

Environmental Stewardship

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Mark Vogel

MnDOT Districts 1, 2, 3, 4 & Metro North and East



Jackie Klein

MnDOT Districts 6, 7, 8 & Metro South and West


Paint removal operations process - MnDOT personnel

View/print complete process for MnDOT personnel (PDF)



Lead and PCB content determination


If bridge paint system, applied in 1980 or prior, tests positive for PCB’s through laboratory analysis, contact your District Safety person and Office of Environmental Stewardship contact to determine proper management concerning type of abrasive and waste management.


Legal definitions of lead, non-lead and PCB paintbridge paint removal


Lead determination methods

Any of the three methods listed below may be used to determine lead content of paint:


PCB determination method



Containment and notification




Waste management


Abrasive blasting waste management

Removing paint by dry blasting with the product Blastox™ should produce a blasting waste that is non-hazardous. Using the product Blastox™ will not affect PCB paint; this waste must be treated as hazardous waste. This greatly reduces cost and requirements in handling, transport and disposal of the waste. Proper management of abrasive blasting waste must meet the following requirements:


Alternative paint removal by hand scraping or power tools

There are fewer regulations when hand scraping or power tools are used to remove paint as compared to abrasive blasting. Sufficient tarps must be used as ground cover and as curtains to contain paint particles within the work area. This containment minimizes impacts to air and soil. Ground cover is not needed over intact paved areas that can be swept to recover paint particles. Paint particles must be cleaned up daily.


Power tools with vacuum systems - Ground cover and curtains are not required if the power tool is equipped with a vacuum to prevent visual air emissions


Transportation and disposal - Consult your District Safety Administrator for proper waste management procedures.
Non-lead paint particles can be brought back to MnDOT District Headquarters in a container with a secured lid (5 gallon bucket with lid) and managed as an industrial waste. This waste can be disposed of at a mixed municipal solid waste landfill or industrial landfill permitted by the Minnesota Pollution Control Agency. The container must be labeled “Non-Lead Paint Chips”.


Lead paint particles can be brought back to MnDOT District Headquarters in a container with a secured lid (5 gallon bucket with lid) and managed as a hazardous waste. This waste can be disposed of with MnDOT hazardous waste contractor. The container must be labeled “Hazardous Waste” and “Lead Paint Chips”.


Documentation - Submit a written record of the following information to the District Safety Administrator:


Following the paint removal operation, the structure is ready for painting. Painting operations typically produce used solvent and oil-based paint sludge that must be managed properly.


For further assistance on reuse and disposal procedures, contact your MnDOT District Safety Administrator or visit MnDOT's regulated material magement website.





It is recommended that MnDOT Bridge Inspectors receive training on environmental regulations and best management practices associated with abrasive paint removal operations prior to the start of work. This training is provided upon request by contacting Mark Vogel or Jackie Klein.