1
[General Comment:- My comments have been made in “edit mode” with “Track Changes” activated. Non edit comments such as this one, appear in brackets [] and are preceded by the words “General comment.” Edits appear as additions or strikeouts.
Inconsistent terms have used throughout the document. Consistency in terms should be used, and a global replacement has been selected for various terms.
The original document was disjointed, and not optimally organized; therefore, an attempt should be made to structure the document in a predictable manner. For example the reader begins to read about assessment and sampling in original section 8.1.7 The discussion then moves to remediation and then inexplicably the discussion returns to sampling and assessment. In some cases, such as the original Section 6.4 is titled “Industrial Hygienists” and then in Section 7, we return to “Industrial Hygienists.” Duplicate topics and redundancies should be combined into a single section.
The original document was “unbalanced” meaning in-depth discussions were given to some hazards and topics, while other hazards and equally important topics were entirely missing from the document. There should be an attempt to “balance” the document, such that the greatest amount of discussion is given to the most important aspects and concerns, and ancillary issues are given ink in accordance to the importance of the issue.
The original concept of a “methlab” employed in the original document is not necessary a valid concept today, and in many “methlabs,” no methamphetamine is produced – yet those operations are nevertheless “methlabs.” The language changes I have employed throughout the revisions suggested here reflect the state of the art field observations that are being made.
In this draft, I have made no attempt to address pagination or format rubrics. A rubric system was established early in the document and then not followed throughout the document. Either the rubric system should be adopted and used throughout, or eliminated entirely – one of the other.
I think some photos would be nice. I have thousands of photos that could be used.
AIHA Guideline 8 – 2012
Clandestine Methamphetamine Laboratory Assessment and Remediation Guidance
Approved – March 8, 2007-
American Industrial Hygiene Association
Disclaimer
This document is neither a comprehensive treatment of issues concerning clandestine operations involving methamphetamine laboratory assessment and remediation, nor is it a stand-alone resource. Scientific and practical knowledge in this area is rapidly accumulating and evolving. This guide It is intended to complement policies and procedures put into practice by other authoritative authors and organizationsmunicipalities, counties or states and should be used by the industrial hygienist in conjunction with existing information.
AIHA and the authors disclaim any liability, loss, or risk resulting directly or indirectly from the use of the practices and/or theories discussed in this guideline. Moreover, it is the reader’s responsibility to stay informed of policies adopted specifically in the reader’s location of practice.
Specific mention or manufacturers, membership organizations, and products in this guideline does not represent an endorsement by AIHA.
Stock Number: EMCG07-722
ISBN-13: 978-1-931504-80-5
American Industrial Hygiene Association
2700 Prosperity Avenue, Suite 250
Fairfax, VA 22031
Tel: (703) 849-8888
Fax: (703) 207-3561
E-mail: infonet@
Printed in the United States of America
Table of Contents
Foreword…………………………………………………………………………..
Committee Members……………………………………………………………...
1. Purpose………………………………………………………………………..
2. Scope………………………………………………………………………….
3. Glossary of Terms……………………………………………………….........
4. Methamphetamine Manufacturing……………………………………………
1. What is Methamphetamine?.......................................................................
2. Methamphetamine Manufacturing and its Hazards………………………
5. Exposure Considerations and Health Effects…………………………………
1. Phosphine…………………………………………………………………
2. Iodine……………………………………………………………………..
3. Hydrogen Chloride……………………………………………………….
4. Methamphetamine Exposures……………………………………………
6. Societal Effects……………………………………………………………….
1. Children…………………………………………………………………..
2. Property Owners………………………………………………………….
3. Law Enforcement Personnel……………………………………………..
4. Industrial Hygienists……………………………………………………..
5. Health Departments and Regulators……………………………………..
6. Insurance Companies…………………………………………………….
7. The Industrial Hygienist……………………………………………………..
1. How Industrial Hygienists Get Involved…………………………………
8. Why Decontaminate?…………………………………………………………
1. The Preliminary Assessment Process……………………………………
1. Law Enforcement and Health Department Document Review……..
2. Compliance with Local Regulatory Requirements………………….
3. Entry Considerations……………………………………………….
Personal Protective Equipment…………………………….
Atmospheric Monitoring…………………………………..
Training……………………………………………………
4. Conducting the Site Assessment…………………………………..
5. Manufacturing Method……………………………………………
6. Physical Assessment and Observations…………………………..
7. Sampling for Methamphetamine Residue…………………………
Sampling Theory………………………………………….
Hypothesis Testing………………………………………..
Wipe Sampling Procedures……………………………….
8. Sampling for other Chemical Contamination………………………
2. Remedial Recommendations……………………………………………….
1. Site Type and Characteristics………………………………………
2. Contents of a Property……………………………………………..
3. Structural Considerations…………………………………………
3. Post-Cleanup Assessment…………………………………………………
1. Physical Assessment………………………………………………
2. Post-remedial Sampling for Methamphetamine Residue…………
9. Challenges and Pitfalls………………………………………………………..
10. Web-based Resources for AIHA Members………………………………….
11. References……………………………………………………………………
Committee Members:
Thomas D. Koch, CIH, MEPM
Heather L. McArthur, CIH, MSPH
John W. Martyny, PhD, CIH
Mark S. Cameron, CIH, MS
Andrew Anthony “Tony”Havics, CHMM, CIH, PE
Caoimhiín P. Connell, Park County Colorado Sheriff’s Office
Purpose
The purpose of this guidance document is to provide industrial hygienists, the industrial hygiene (IH) community, and environmental health and safety professionals with information pertaining to clandestine operations involving methamphetamine laboratories and the hazards these laboratories operations present to occupants, first responders, property owners, industrial hygienists, and remediation personnel.
Our nation faces a growing health and safety threat from clandestine methamphetamine use, processing manufacturing and production of dextro-methamphetamine ( “meth”). Clandestine methamphetaminemeth production is also a societal problem that affects many people in many different ways. The methamphetamine “meth” problem presents many challenges:, from unknowing children and other occupants living in undiscovered former methamphetamine laboratories (“meth labs”), to law enforcement personnel inadvertently responding to chemically hazardous locations, lost of property investment by innocent property owners, and regulatory burdens on health department officials. Meth labs and their associated hazards, once thought to be solely a criminal and judicial problem for law enforcement, are now a recognized community problem in both urban and rural areas nationwide. One aspect of methamphetaminemeth production of particular importance is the fact that many common household products are used in methamphetaminemeth manufacturing, often with dangerous and even fatal results. When these common ingredients are mixed in clandestine operations and heated during methamphetaminemeth manufacturing, many of the byproducts used in the “recipes” are known to create a variety of explosive and/or toxic byproducts. These byproducts and the residues left behind may present acute health affects during the “cooking” process, and may result in create chronic adverse health effects to occupants people and property, even for years into the future. This guidance document will assist industrial hygienists and other environmental health and safety professionals in recognizing, assessing, and abating the hazards associated with clandestine methamphetaminemeth laboratorieslabs.
Scope
This document will provide guidance pertaining to recognition, assessment, and remediation of clandestine methamphetaminemeth laboratorieslabs and is intended for use by industrial hygienists, environmental health and safety professionals, health department personnel, and other qualified persons whose responsibilities include recognition, hazard assessment employees, and remediation of clandestine methamphetaminemeth laboratorieslabs.
Industrial hygienists are routinely called upon by property owners to assess and evaluate meth and chemical contamination within and around a property in which a clandestine lab was discovered. This guidance document will address the assessment process for evaluation of contamination associated with meth labs and will provide industrial hygienists with the framework and guidance to conduct preliminary and remedial assessments of meth labs.
Readers of this document will become familiar with the following:
• Introduction of the clandestine methamphetaminemeth lab problem, including exposures to children, occupants, first responders, social service workers, health departments, property owners, industrial hygienists, and remediationl companies.
• The different meth manufacturing processes, including chemical reactions, chemicals and products used, products, byproducts, and waste streams produced.
• Property contamination issues in residential properties, commercial properties, apartments or townhomes, mobile meth labs in automobiles and RVs, national parks or forests or other public property. Meth labs leave a trail of contamination when they are abandoned that can persist for weeks, months, and even years.
• Industrial hygienists are routinely called upon by property owners to assess and evaluate meth and chemical contamination within and around a property in which a clandestine lab was discovered. This guidance document will address the preliminary assessment process for evaluation of contamination associated with meth labs and will provide industrial hygienists with the framework and guidance to conduct preliminary and remedial assessments of meth labs.
• The challenges and pitfalls of the subject matter, including the variety of methamphetaminemeth manufacturing processes and the materials used to processmake meth, the rapidly changing regulatory environment, and the effects on regulations and requirements pertaining to future occupancy of affected properties.
• A list of available resources for the IH community.
In addition to the information contained in this document, the reader should note the following:
• There are many different types methods of methamphetaminemeth processesmanufacturing, some of which are common and well established known and some of which are evolving. It is without question that even as this document is being published, new methods of clandestine methamphetaminemeth “cooking” operations are being tested and developed by criminal elements. “meth cooks.” Each clandestine process method of methamphetamine manufacturing can present hazards unique to that processmethod with respect to chemicals used, byproducts produced, and waste streams generatedproduced. Users of this document are advised to remain current with respect to the laws, regulations, and clandestine process methods of methamphetamine manufacturing as the hazards presented can be a dynamic “moving target.”
• There are similar and parallel issues developing with respect to the clandestine processing manufacture of controlled substancesother illicit and illegal drugs, such as marijuana, ecstasy and LSD, in a clandestine fashion. Users of this document are advised that hazards encountered and presented in other types of clandestine drug manufacturing operations can be very different than those discussed in this documentherein. Readers Users are cautioned to conduct additional research in the event should other controlled substances are involved.forms of drug manufacturing be of concern.
• As of the date of publication of this document, there are no recognized federal laws with respect to identification, cleanup, and remediation of clandestine methamphetaminemeth laboratorieslabs. Many states, counties, and municipalities across the country have enacted legislation and/or regulations pertaining to various aspects of meth lab cleanup. State regulations differ and can address many different issues, from certification and qualification requirements for those involved in assessment and remediation of meth labs, to defining cleanup requirements and clearance criteria for re-occupancy. Users are advised to check with local health department officials for the most current requirements pertaining to clandestine meth labs prior to conducting any work involving meth labs.
Glossary of Terms and Acronyms [GENERAL COMMENT – I recommend moving the glossary to an appendix at the end of the document.]
The following terms and definitions apply as they pertain to this guidance document and clandestine methamphetaminemeth manufacturing operations. AIHA’s Glossary of Occupational Hygiene Terms should be referenced for any terms not defined in this section.
ACGIH – American Conference of Governmental Industrial Hygienists® The ACGIH publishes and owns the copyright and trademarked “Threshold Limit Values” (TLVs)®
Acidic – The condition of any media that contains a sufficient amount of acid substances to lower the pH below 7.0.
[GENERAL COMMENT – since this is a document ostensibly written for a technically oriented audience, technically accurate definitions should be used. In the above definition, water would be “acidic” since diluting a base with sufficient water could reduce the pH to below 7. I have measured household tap water with a pH as low as 5, and neutral buffers could achieve the same. According to the Bronsted model, an acid is a proton donor. NH4+ is an acid since it can donate a proton and NH3 is a base since it can accept a proton. According to the Lewis model, an acid is something that can attach itself to a moiety with an unshared pair of e-. I suggest a technically accurate, yet common definition as follows:]
Acid: Any material that disassociates in water producing free hydrogen ions.
Acidic: Any substance exhibiting the properties of an acid or any aqueous or liquid substance whose pH is less than 7.
Acute Effect – A physiological response within 72 hours to a short-term chemical exposure. Presentation my include that may consist of shortness of breath, cough, chest pain, dizziness, lack of coordination, chemical irritation, and burns to the skin, eyes, mouth and nose, and in severe cases, death.
Acute Exposure – An exposure that occurs over a relatively short period of time (usually seconds, minutes, or hours). An acute exposure to high levels of contaminants found in methamphetamine labs may cause acute effects, which can occur during or shortly after a drug bust. Some of these effects may occur as long as 24 hours following acute exposure.
Background Level – An average or expected amount of a substance in a specific environment, or typical amounts of substances that occur naturally in an environment.
Building – A structure which has the capacity to contain, and is designed for the shelter of, man, animals, or property, or place adapted for overnight accommodations of persons or animals, whether or not a person or animal is actually present. It also includes manufactured homes and mobile homes.
Chemical Storage Area – Any area where chemicals used in the manufacture of methamphetamine are stored or have come to be intentionally or unintentionally located.
Chronic Exposure – An exposure that Ooccurs over an extended period of time, such as months or years, without respect to concentration or dose.
Clandestine Drug Laboratory Operation – (Clan lab) – An unlawful operation involving the processing or disposal of any controlled substance or counterfeit substance, or its precursors, reagents, waste streams, equipment or drug paraphernalia regardless of location. The unlawful manufacture or attempt to manufacture a controlled substance within any area of a structure such as a dwelling, building, motor vehicle, trailer, boat, or other appliance.
Clandestine Drug Lab Site – Any building or vehicle including the ground upon which it is situated and all fixtures and contents thereof wherein a clan lab is or has been located. : Any part(s) of a structure such as a dwelling, building, motor vehicle, trailer, or appliance occupied or affected by conditions and/or chemicals, typically associated with a clandestine drug lab operation.
Cleanup – The proper removal and/or decontamination of substances hazardous to humans and/or the environment to acceptable levels of risk.
Consultant – An independent, third party advisor knowledgeable in industrial hygiene and clandestine drug operations who otherwise has no association with any remediation firm, and as usually represented by the industrial hygiene provider.
Contaminant – A chemical residue that may present an immediate or long-term threat to human health and/or the environment.
Contamination or Contaminated – The presence of a contaminant.chemical residues, which may present an immediate or long-term threat to human health or the environment.
Controlled substance- a drug or other substance, or immediate precursor, included in schedule I, II, III, IV, or V of part B of Title 21 of the United States Code (USC) Controlled Substances Act.
Cook – A slang term for the processing of manufacturing methamphetamine and other illegal controlled substances or the person(s) involved in the processing of responsible for manufacturing methamphetamine or other illegal a controlled substance.
Cooking Area – Any area where methamphetaminemeth manufacturing is occurring or processing has occurred.
Counterfeit substance – any material represented as or intended to be presented as a controlled substance regardless of the actual chemical composition.
Cursory Evaluation – An administrative and/or qualitative screening of site conditions to determine the probability of the presence of a clandestine drug lab operation. A cursory evaluation may or may not involve sampling and testing.
Decision Level – The concentration, relative to the cleanup level, that shall should be used to distinguish between compliant and non-compliant areas.
Decontamination – The process of reducing the level of contamination to meet the Decision Levelthe lowest practical level using currently available methods.
Demolition – The wrecking or taking out of any load-supporting structural member, including any related handling operations.
Disposal – Handling, transportation and ultimate disposition of materials removed from contaminated properties.
Documentation – Preserving a record of an observation through writings, drawings, photographs, or other appropriate means.
DQOs – Data quality objectives - The establishment of a quality assurance – quality control program that becomes part of a larger hypothesis testing or decision making process; the results of sampling and analysis may be the pivotal point upon which decisions are made. The DQOs ensure, through their prescription, that a statistically sufficient number of samples will be collected from statistically representative locations in an acceptable manner by a validated method or method whose uncertainties are sufficiently characterized. DQOs describe the overall level of uncertainty that the Consultant is willing to accept in results derived from sampling and analysis. The uncertainty is used to specify the quality of the measurement data required, usually in terms of objectives for precision, bias, representativeness, comparability and completeness (PARCC parameters). The DQOs should be defined prior to the initiation of any field work.
Drug – any material that enters systemic circulation and is intended to alter homeostasis .
Encapsulation – Applying a surface sealant to create a physical barrier intended to decrease or to eliminate the potential for exposure to residual contaminants that may exist beneath the physical barrier even after decontamination.
Exposure – The qualified or potential presence of a condition that may result in harm.
Functional Space – A space where the spread of contamination may be expected to occur relatively homogeneously, compared to other functional spaces. The “functional space” may be a single room or a group of rooms, designated by a consultant who, based on professional judgment, considers the space to be separate from adjoining areas with respect to contaminant migration. Other typical examples of functional spaces include a crawl space, an attic, and the space between a dropped ceiling and the floor or roof deck above.
Hazard – A source of potential harm from past, current, or future exposures.
HEPA Filtration – A filtering system capable of trapping and retaining at least 99.97 percent of all mono-dispersed particles 0.3 microns in diameter or larger.
IDLH – “Immediately dangerous to life and health” The concept of IDLH is a philosophical concept that is revised from time to time. Pursuant to 29 CFR 1910.146, IDLH is defined as any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space. Note: Some materials--hydrogen fluoride gas and cadmium vapor, for example--may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim "feels normal" from recovery from transient effects until collapse. Such materials in hazardous quantities are considered to be "immediately dangerous to life or health."
Individual Sewage Disposal System (ISDS) – An absorption system of any size or flow or a system or facility for treating, neutralizing, stabilizing, or disposing of sewage which is not part of or connected to a public owned sewage treatment works.
Laboratory – any facility intended to be used for the specialized handling of chemicals and/or apparatuses to process any chemical compound.
LOAEL – (Also LOEL) – the lowest reported dose of any material capable of altering homeostasis that results in an adverse effect.
Matrix – The physical nature of a material from which a sample is collected (air, liquid, bulk, residue, etc).
Media – The physical material onto which a sample substrate is collected. Media includes cotton gauze, glass fiber filters, MCE membranes, etc.
Methamphetamine – Dextro-methamphetamine, levo- methamphetamine, and unidentified isomers of the same, any racemic mixture of dexto/levo methamphetamine, or any mixture of unidentified isomers of methamphetamine. The term includes derivatives, conjugates, oxides, and reduced forms of the basic structure associated with CAS registration number 537-46-2. [GENERAL COMMENT: when I initially developed this definition, it was for regulatory and law enforcement purposes, and not necessarily appropriate for this guide. I recommend the following:]
A synthetic amine with a molecular weight of 149.2 g/mole. The pure material (sometimes called “base”) is a clear, colorless, liquid (VP 0.163 mmHg at 298°K[1]) with an odor ranging from odorless to that of geranium leaves.[2] The legitimate drug, d-methamphetamine hydrochloride, is white powder with no appreciable odor and no appreciable VP at room temperature.
The illicitly produced street drug, at the point of manufacture, typically exceeds 90% pure methamphetamine hydrochloride and can range from a snowy-white powder to a brownish, reddish, yellowish, granular material.[3] Occasionally refined methamphetamine resembles shards of broken glass. The material sold on the street, is an indeterminate mixture of variable purity and chemical properties.
The pure hydrochloride salt of the d-rotation (see below) has a melting point approximately 170°C[4] (the street product has a melting point of approximately of 175°C[5] but the actual mixture used by the illicit abuser is too variable to categorize, and can be cut with sugar and common table salt[6], n-methylbenzylamine[7] and methylsulfonylmethane (MSM) with or without dimethylsulfone (DMSO2).[8]
The linear formula of C10H15N exhibits various stereoisomer, and rotational configurations. The two most notable rotational configurations are levo and dextro (see below).
[pic] [pic]
Levo-Methamphetamine Dextro-methamphetamine
The rotation of the side linkage determines its toxicology, as well as its regulatory classification. The levo-rotation is a non regulated material present in over the counter products. The dextro-rotation (CASRN: 537-46-2) is a Schedule II controlled substance;. The Schedule II classification includes all d-rotation salts, isomers, and salts of its isomers, (DEA Code #1105; Drug class: Stimulants).[9]
The racemic mixture has 64 official names however, the IUPAC name for the general compound is N-methyl-1-phenylpropan-2-amine.[10] The dextro-rotation has over 121 official synonyms, and well over 100 street names, the two most common official names are d-methamphetamine and Desoxyn®. The IUPAC name for the d-rotation is (2S)-N-methyl-1-phenylpropan-2-amine.[11] The street product is an hydrochloride salt of the basic structure, and can include either or a mixture of both rotations.
Microvacuum Sample or Vacuum Sample – A non-airborne dust sample collected from a surface or material using standard microvacuum sampling techniques.
Negative Air Unit – A portable exhaust system equipped with HEPA filtration and capable of maintaining a constant high velocity airflow out of the contaminated area, resulting in a constant low velocity air flow into the contaminated area from adjacent uncontaminated areas.
NOAEL – (Also NOEL) - the highest reported dose, of any material capable of altering homeostasis, below which no reported adverse effects are seen.
Non-porous – A material that does not contain holes or pores and is typically not subject to internal saturation of a contaminant, usually a hard surface.
Non-volatile – Substances that do not readily evaporate or sublimate at normal temperatures and/or pressures.
OSHA – The Federal Occupational Safety and Health Administration
Owner – Any person, firm, or corporation who owns, in whole or in part, the land and/or structures such as buildings, motor vehicle, trailer, boat or other appliance at a clandestine drug lab site.
Oxidation – Loss of electrons from a chemical entity; increasing the positive valence of a chemical entity.
Paraphernalia – any piece of equipment which in whole or as an essential part of an assembled piece is used for production, use, storage, or any illegal process involving a drug or precursor
PEL – “Permissible Exposure Limit” a regulatory limit established by OSHA. PELs, are defined in Title 29 of the Code of Federal Regulations.
pH – a measure of the concentration of disassociated hydrogen ions. Generally, a pH of less than 7 is considered “acidic” and generally, a pH of greater than 7 is considered caustic.
pH Paper – A qualitative method for determining the acid/base characteristic of asampling media used to test acidity of a solution, powder or residue material.
Photoionization Detector (PID) – A device used for the detection of vVolatile Oorganic Ccompounds (VOC), which utilizes ultraviolet light to ionize gas molecules, and measure the corresponding charges thus generated.
Porous – A material that contains holes or pores that may be subject to saturation by a contaminant.
ppm – “Part Per Million” Parts of a species of interest per one million parts of balance material.
Precursor – . A principal compound used, or produced primarily for use, in the manufacture of a controlled substance. A substance which is chemically altered to form a controlled substancefrom which another substance is formed. For example, in one common methamphetaminemeth production method, the precursors are any compounds or mixtures containing ephedrine and/or pseudoephedrine are chemically reduced (dehydroxylated) to methamphetamine.
Preliminary Assessment – An initial quantitative environmental site assessment to characterize the extant hazards and chemical contamination at that site, including the nature and extent of observable or detectable contamination, chemical storage, disposal and impact on the surroundings. Usually a Preliminary Assessment will include recommendations for remediation if remediation is recommended.
Private, residential property – A single family home, apartment or multiple family unit or dwelling.
Processing – any physical handling or chemical manipulation of a chemical substance.
Property – Anything that may be the subject of ownership or possession, including, but not limited to, land, buildings, structures, vehicles and personal belongings.
Publicly owned treatment works (POTW) – A publicly owned domestic wastewater treatment facility. The term also means the municipality, as defined in 502(4) of the Clean Water Act, 33 U.S.C. § 1362(4), which has jurisdiction over the indirect discharges to and the discharge from such treatment works.
[This was out of alphabetical order and was moved to proper location]Preliminary Assessment – An evaluation of a property to determine the current condition, including the nature and extent of observable or detectable contamination, chemical storage and disposal.
[General comment - This entry was out of alphabetical order and was moved to proper location]Property – Anything that may be the subject of ownership or possession, including, but not limited to, land, buildings, structures, vehicles and personal belongings.
Reagent – a chemical substance used or created in the processing of a material or precursor.
Reduction – Gaining of electrons; a cathodic reaction or other reaction increasing the positive valence of a chemical entity.
Removal – The taking out or stripping of material or surfaces to eliminate the potential for exposure to contaminants on or in the material or surfaces.
RfD – “Reference dose” RfDs are concentrations resulting in doses below which adverse health effects are not likely. A central assumption in the application of an RfD is that a population threshold exists below which adverse effects will not occur. However, such a threshold is not observable and can only be estimated.
Salting – also known as “salting out” any number of processes by which methamphetamine base is converted to methamphetamine hydrochloride.
Semi-volatile – means substances that slowly evaporate or sublimate at normal temperatures and/or pressures.
STEL – Various terms are used for STEL, depending on the reference. However, in general, a STEL is numerical value established to describe a dose, or concentration of exposure over a short amount of time and thus expresses a “Short Term Exposure Limit.”
Substrate – The material on which a contaminant may be presentbeing collected. Substrates may include fabrics, soils, water, painted surfaces, carpet debris, unidentified powders, dust, etc.
TLV®- Threshold Limit Value® a copyrighted exposure index developed and/or published by the ACGIH®
TWA – “Time Weighted Average” A mathematical manipulation whereby an exposure or series of exposures is integrated over any given period of time. TWAs can be expressed in terms of minutes, seconds, or years. Many PELs, TLVs® and STELs are expressed as TWAs.
Waste – Any material discarded at the end of a process.
Waste Disposal Area – Any area where chemicals or equipment used or generated from in a clandestine drug lab operationthe manufacture of methamphetamine are discardeddisposed or have come to be located.
Wipe sample – A surface sample collected by wiping a sample media on the surface in accordance with a recognized procedure.
(Sources: References 1 and 2)
Methamphetamine Manufacturing
This section will introduce meth in general and the most common types of methamphetaminemeth manufacturing and processes and the hazards they present by those activities. Be advised that t
The chemistry described herein is presented to illustrate the commonly encountered reagents, products and byproduct hazards associated with methamphetaminemeth and is not intended to be considered for use in methamphetamine manufacturing.
1. What is Methamphetamine?
Methamphetamine is a synthetic material that is commonly found in two forms; dextro-methamphetamine and levo-methamphetamine. Levo-methamphetamine is not a controlled substance and is found in a variety of over-the-counter consumer products.
The only difference between the over-the-counter- ingredient “levo-methamphetamine” and the more toxic controlled substance called “dextro-methamphetamine” is the rotational position of the side branch (with the amine group) on the molecular structure (See below).
[pic] [pic]
Levo-Methamphetamine Dextro-methamphetamine
For this reason, the most common analysis methods employed for the quantification of “meth” cannot distinguish levo-methamphetamine from dextro-methamphetamine.
Dextro-methamphetamine is the primary material being discussed in this document. Dextro-methamphetamine is a controlled substance. very d-Methamphetamine is an addictive stimulant drug that activates the central nervous system by increasing the release of the neurotransmitter dopamine, and blocking the reuptake dopamine, resulting in high levels in the braincertain systems in the brain. d-Methamphetamine It is chemically related to the amphetamines and other controlled substances such as “ecstasy,” Bbut, at comparable doses, the effects of methamphetaminemeth are much more potent, longer lasting, and more harmful to the central nervous system (CNS). than similar structural analogues.
Currently, it is not within the feasible technical capabilities of the general criminal element to convert the levo-methamphetamine into street meth (dextro-methamphetamine).
Street meth is the hydrochloride salt “methamphetamine hydrochloride” and is referenced by many names, such as "speed," “crystal” and "ice."
The appearance of street meth is variable and may be present as “shards” of clear “glass,” powders that are white, slightly yellow and brown. Contrary to myths in the criminal world, the appearance of street meth is not an indication of the quality or purity of the product.
Methamphetamine is a Schedule II stimulant substance, which means it was “listed” pursuant to Section 812 of the Controlled Substances Act (21 U.S.C. §801 et seq). The full list can be found in Title 21 Code of Federal Regulations, Part 1300 et seq. A “Schedule II” rating means the listed substance exists on the market as a legitimate medical prescription; but has a high potential for abuse and is available only through a prescription. that cannot be refilled. The legitimate d-methamphetamine prescription drug is sold in the US under the trade name “Desoxyn.” Globally, meth may be marketed under other trade names.
Often, a criminal will establish a clandestine drug operation that is entirely incapable of actually producing any methamphetamine or any other controlled substance. The “erroneous” operations still pose the same hazards as an actual production lab even though no methamphetamine may actually be present.
High quality methIt can be readily produced in large scale operations or in an operation so small it can fit in a shoe-box. made in small, illegal laboratories, where its production endangers the people in the labs, neighbors, and the environment. Street methamphetamine is referred to by many names, such as "speed," "meth," and "chalk." Methamphetamine hydrochloride, clear chunky crystals resembling ice, which can be inhaled by smoking, is referred to as "ice," "crystal," "glass," and "tina."
Methamphetamine can be taken orally, intranasally (snorting the powder), by needle injection, trans-rectal absorption, or by vapor inhalation (smoking). Abusers may become addicted quickly, needing higher doses more often. At this time, the most effective treatments for methamphetaminemeth addiction are behavioral therapies such as cognitive behavioral and contingency management interventions.(3)
2. Toxicology
Available literature supports a LOAEL for d-methamphetamine in children in the approximate dosage of 0.2 mg/kg/day with a NOAEL of approximately 0.1 mg/kg/day.[12] The State of California published an RfD of 0.3 mg/kg/day.[13] Some studies indicate that adults may be more susceptible to the adverse effects of methamphetamine than children and have reported LOAELs in the range of 0.08 mg/kg/day to 0.2 mg/kg/day. One author[14] has estimated the NOAEL is achieved when surface concentrations of d-methamphetamine exceed 1.5 µg/100cm2. Therapeutic doses for Desoxyn® (d-methamphetamine hydrochloride) are reported to start at approximately 0.25 mg/kg/day for a child. Illicit use doses typically range from 40 mg to 100 mg per “hit.”[15] An abuser in a “binge cycle” may self-medicate several time per day for several days.
When methamphetamine is “smoked,” approximately 40 to 100 mg is placed into a receptacle and heated – between 80%[16] and half[17] of the substance is released from the user's pipe. Of that material which is inhaled, between 33%[18] and 10%[19] of the nominal dose is not absorbed into the body, but rather exhaled back into the ambient air. Therefore, the majority of material that is placed in a meth pipe is not immediately taken into the body, but rather remains in the environment.
Methamphetamine has a dynamic and complex biotransformation. The literature is generally in agreement that the biotransformation pathway typically results in unchanged methamphetamine (~20%), p-hydroxymethamphetamine (~15%), amphetamines (~7%), p-hydroxyamphetamine (~1%), accounting for between 45 and 53% of the administered mass within two days.
Although the effects of meth are well known on individuals using the drug, the effects of low level exposures to emergency personnel or other associated individuals are not as well known. It is known that meth may cause some teratogenic effects and may change behavior in exposed infants.(18) Prenatal exposure to meth has been shown to cause an increase in pre-term labor, placental abruption, fetal distress, and postpartum hemorrhage.(18) Infants exposed to meth are generally smaller, have feeding difficulties, and are described as “very slow.”(18) Infants born to mothers that have used meth during pregnancy may have abnormal sleep patterns, poor feeding, tremors, and hypertonia. In some reports, subtle neurological abnormalities have also been found.
3. Methamphetamine Processing Manufacturing and its Hazards
One of the difficult and unique aspects of methamphetaminemeth production is the variety of methods or “recipes” that can be used in the for process of making or refining meth. There are several common methods for production, although different recipes are emerging all the timebeing developed and used in clandestine fashions every day.
Often, the process is broken up into independent stand-alone operations that are physically separated from one another. The process is broken up to deter law enforcement detection, and to thwart prosecutorial actions. As such, a clandestine operation, involved in the manufacturing of meth may not actually produce any meth at all.
One site may engage in the operation of pseudoephedrine extraction, and move the intermediate product to another location (thus producing it own unique waste stream). Another lab location may only be involved in precipitating and supplying iodine, or producing anhydrous ammonia for supply to the reduction lab operation. These precursors and reagents may then be supplied to the actual “cook” located elsewhere who produces the methamphetamine oil (called “snot”.) The methamphetamine oil may then be shipped to another location where the oil is converted to a salt.
The hazards and environmental impact of each site should be evaluated within the context of known or suspected operations.
4.3.1 Synthesis Methods
4.3.1.1 Phenyl-2-Propanone (P-2-P) Process
“Methamphetamine was initially synthesized in circa 1887 early 1900 and was ultimately utilized in prescription and over-the-counter medicines. Prior to the 1990s, the clandestine production of methamphetaminemeth was confined to the Pacific coast states and was commonly controlled by outlaw motorcycle gangs. The motorcycle gangs utilized the phenyl-2-propanone (P-2-P) method of manufacture. This process is a “synthesis” operation that can be very odorous, difficult to conduct and requires knowledge of chemistry. In addition, it produces a lower quality racemic mixture of l-methamphetamine and d-methamphetamine known as “crank” or “prop-dope.” drug with less additive properties as compared to more modern production methods. In December, 1979, the Drug Enforcement Agency placed P2P on its Schedule II list.[20] The Federal Chemical Diversion and Trafficking Act of 1988 placed P-2-P and other chemicals on the controlled substances list, which increased the difficulty of obtaining the precursor chemicals for the P-2-P method.”(4)
As P2P became harder to obtain, clandestine chemists began to utilize production methods using ephedrine or pseudoephedrine. These compounds are structurally very similar to methamphetamine with ephedrine differing only by a single hydroxyl group. In addition, this method of production yields only d-methamphetamine which is more physiologically active. Clandestine laboratories using the ephedrine/pseudoephedrine method of production are currently the most common laboratories found by law enforcement .(5)
Though rare, the P-2-P method is still being used. Many variations from the early methods have been developed using this from this precursor. The most commonly encountered P-2-P method usesd phenyl-2-propanone, mercuric chloride, methylamine and aluminum foil as well as solvents and strong acids; another. One variation uses lead acetate.
The P-2-P method is not restricted to initially using P-2-P per se, and several alternative reaction pathways[21] starting with, for example, benzyl cyanide, benzaldehyde, or phenylacetic acid have been documented. In many of these methods, P-2-P may be one of the early reaction products, that is then manipulated and taken to the final product.
4.3.1.2 Alternative Synthesis Pathways
A multitude of reaction pathways have been identified in the field that do not progress through the P-2-P intermediate at all. Starting compounds have included, safrole, isosafrole, benzene, and vanillin. In these reaction pathways, P-2-P is not used and is not produced as an intermediate, however, the process may nevertheless be categorized as aP-2-P laboratory.
The important thing to remember is that methamphetamine is big business in a technologically advanced population with ready access to highly sophisticated equipment. Highly educated risk-taking entrepreneurs stand ready to make technical advances in new pathways to lucrative products. The investigating professional must maintain an open mind about the possible end-products based on the totality of the findings of any particular site.
4.3.2 Pseudoephedrine Reduction Methods
As P2P became harder to obtain, clandestine chemists began to utilize production methods that reduced readily available ephedrine or pseudoephedrine into d-methamphetamine. These compounds are structurally very similar to meth differing only by a single hydroxyl group. In addition, in this method, if one starts with d-ephedrine or d-pseudoephedrine, this method of production yields only d-methamphetamine. Clandestine labs using the ephedrine/pseudoephedrine method of production are currently the most common labs found by law enforcement .(5)
Effectively, there is little significant difference between pseudoephedrine and ephedrine (see below.)
[pic]
For the purposes of this document, we have used the term “pseudoephedrine” synonymously with ephedrine, since at this time, most of the diverted precursor and almost all of the small scale clandestine labs in residential structures are using pseudoephedrine; however, the reader should understand the term is not exclusive.
As bulk pseudoephedrine became more difficult to obtain, individuals interested in the clandestine manufacture of meth switched to extracting pseudoephedrine from cold tablets purchased or stolen from drug stores. The pseudoephedrine extraction method involves mixing the crushed pills with a polar solvent (water or alcohol) in order to obtain the necessary compounds. The use of alcohol is faster since it evaporates more quickly, but it is much more flammable.
The ephedrine/pseudoephedrine manufacturing processes is not synthesis method, but rather a reduction method – that is, the precursor compound is structurally altered through dehydroxylation. There are four common variations by which dehydroxylation occurs:
1) The “Red P” method (production of hydroiodic acid using red phosphorous and iodine).
2) The “hypo” method (direct addition of hypophosphorous acid)
3) The anhydrous ammonia method (a.k.a the “Nazi,” “Birch” or “Bitch” method).
4) The “One Pot” method
can be classified as three separate methodologies: the red phosphorous or “red P” method, the hypophosphorous acid method, and the Birch reduction method. The Red “P” method uses red phosphorous, while the hypophosphorous method uses hypophosphorous acid in order to provide phosphorous to the reaction. Both methods involve the addition of ephedrine/pseudoephedrine, iodine, water, and phosphorous in order to produce the methamphetamine.
Each of the above reaction pathways Both production methods utilize a involve strong acids, strong bases, a and one or more volatile organic solvents. solvent, and hydrochloric acid to remove the methamphetamine from solution. These methodologies can produce large quantities of relatively high purity methamphetaminemeth.
Following the reduction, the meth base is first separated from the aqueous reaction solution with a strong base, and then extracted into a non-polar solvent. Once soluble in the nonpolar solvent, the meth base is converted to a water soluble salt. During the salt conversion process, the criminal may either employ or produce hydrochloric acid, depending on the individual preferences of the criminal. The production of hydrochloric acid commonly employs sulfuric acid.
4.3.2.1 Red Phosphorous Method
The Red P method is one of the most common reduction methods used in the criminal world. On the street, this method is often called the “Red, White and Blue” method and the “3-2-1” method.
The process is extremely simple, and ingredients are merely added to a container wherein an exothermic reaction occurs producing pressure. The reduction process commonly employs iodine and red phosphorous. In addition to the hazardous compounds employed, acutely toxic intermediate by-products, such as hydroiodic acid and phosphine, are also produced.
4.3.2.2 Hypophosphorous method
In the hypophosphorous method, red phosphorous is not used. Reagents and precursor are combined, and heated. Following reduction, the meth is extracted and converted to a salt.
4.3.2.3 Anhydrous Method
The Birch Rreduction Mmethod, also known as the “Nazi” method, has become very popular in rural agricultural areas since the late 1990’s due to the low cost and high availability of the necessary chemicals which are commonly found in farming communities. In this method, the criminal either steals, or produces anhydrous ammonia. This method combinesuses ephedrine/pseudoephedrine with a reactive metal (sodium or lithium) in the presence of anhydrous ammonia. The need for addition of a strong base for extraction into water is not necessary, since the method produces lithium hydroxide and ammonium hydroxide as a byproduct; but the use of a solvent and hydrochloric acid is still necessary to convert the methamphetamine into a salt. Anhydrous ammonia is easily obtained through theft, especially in rural areas where it is used as a fertilizer or by making it using normal household fertilizer and drain cleaner. Lithium is a reactive metal present within many photographic batteries. The nationwide incidence of clandestine methamphetaminemeth production laboratorieslabs using this method rose from 439/3,015 (14.5%) laboratorieslabs in 1998 to 2,912/6,426 (45.3%) laboratorieslabs in 2000, just a two-year period.
4.3.2.4 One Pot Method
The one-pot method, is an hybrid method between the hypophosphorous method and the anhydrous method. I virtually all the ingredients are combined, as the name would indicate, into one container. The container is a veritable bomb containing strong oxidizers, reduced metals, flammable solids and pryophorics.
Upon completion of the reduction process, the meth is already extracted into a nonpolar solvent, and ready for conversion into a salt.
As pure ephedrine and pseudoephedrine became more and more difficult to obtain, individuals interested in the clandestine manufacture of methamphetamine switched to extracting these compounds from cold tablets purchased or stolen from drug stores. This ephedrine/pseudoephedrine extraction method involves mixing the crushed pills with a light solvent (water or alcohol) in order to obtain the necessary compounds. The use of alcohol is faster since it evaporates more quickly, but it is much more flammable.
5. Exposure Considerations and Health Effects
Exposure to clandestine methamphetaminemeth manufacturing laboratorieslabs continues to result in illness and injury to individuals who come into contact, either knowingly or unknowingly, with these laboratorieslabs.
The injuries are chemically induced as well as physical trauma due to physical burns, anti-personnel explosives (booby-traps), and the hazards of moving through a structure that not only contains significant slip/trip/fall hazards, but may have been heavily modified with trap doors, false walls, and other unexpected anomalies.
5.1 Chemical Hazards
The Centers for Disease Control and Prevention (CDC) reported a number of public health injuries and illnesses in first responders and medical personnel associated with clandestine methamphetaminemeth laboratorieslabs between 1996 and 1999. One hundred and twelve methamphetaminemeth-associated events were reported by five state health departments. These events resulted in injury to 155 persons, of which 79 were first responders and 7 were hospital personnel. Predominant complaints in first responders were respiratory irritation and eye irritation, while hospital personnel complained primarily of nausea/vomiting and dizziness.(6)
The State of Washington reported 91 methamphetaminemeth-related incidents, of which 35 (38%) resulted in injuries to a total of 66 people. Twenty-two (33%) of the individuals injured were classified as members of the general public, but most were either methamphetaminemeth “cookers” or individuals living in homes where methamphetaminemeth was produced. Nineteen individuals were employees of businesses (hotels, refuse pickup, transfer facilities, etc.) where methamphetaminemeth had been produced or byproducts were illegally dumped. Thirty-two (48%) of the 66 total people were hospitalized or taken to the hospital and released. The rest of the individuals were either treated at the scene, by their personal physician, or did not need treatment.(7)
Studies conducted by Dr. Jefferey Burgess investigated symptoms reported by emergency responders during illegal methamphetaminemeth laboratory seizures. Responders predominately reported general irritant symptoms, but at least one case of phosphine gas exposure was reported.(8) In a questionnaire study of emergency responders, 53.8% reported at least one illness while conducting laboratory seizures, with most symptoms appearing to be related to chemical exposure at the laboratory site. The primary symptoms reported were headache and mucous membrane irritation.
Upon repeat pulmonary function testing, a number of responders were found to have an accelerated drop in one second forced expiratory volume (FEV1) that may have been related to work in drug laboratorieslabs.(5) The majority of symptoms reported by officers occurred during the processing phase of the laboratory seizures which is also the phase in which the most time was spent in the laboratory area dismantling the laboratory and collecting evidence. The use of respiratory protection seemed to reduce the incidence of symptoms while investigating these laboratorieslabs. While there has also been anecdotal evidence of exposure to methamphetaminemeth or methamphetaminemeth laboratory byproducts causing permanent lung damage, actual cases have not been reported in the literature.
Based upon sampling results collected at controlled methamphetaminemeth laboratory “cooks” using typical manufacturing protocols, the chemical exposures of greatest concern during manufacture consist of phosphine, iodine, hydrogen chloride, solvents, anhydrous ammonia and the drug or its precursors.(9) During the cooking phase, exposure levels of all of these compounds may meet or exceed current occupational exposure guidelines. This is especially true of exposures to phosphine, iodine, anhydrous ammonia and hydrogen chloride. Each of these compounds may exceed the occupational exposure guidelines as set by the Occupational Safety and Health Administration (OSHA) and by the American Conference of Governmental Industrial Hygienists (ACGIH).
5.1.1 Phosphine
Phosphine is a pyrophoric toxic gas with an unpleasant odor of garlic or fish (depending on the amount of diphosphine in the mixture). The current OSHA Permissible Exposure Limit (PEL) is 0.3 ppm; the ACGIH eight hour TWA TLV® is 0.3 ppm with a STEL of 1.0 ppm;(10) and the IDLH is reported as 50 ppm.
The AIHA has not established an ERPG-1 level (Emergency Response Planning Guidelines) for phosphine. (23) The AIHA ERPG-2 level is 0.5 ppm (most individuals can be exposed for up to one hour without experiencing any irreversible or serious health effects). The ERPG-3 level is given as 5 ppm (most individuals could be exposed for up to one hour and not experience any life threatening health effects).(23)
Phosphine has been measured dDuring these controlled “cooks,”, using the Red P method. phosphine was generated during many red phosphorous methamphetamine cooks. Phosphine was produced at levels ranging from less than 0.12 ppm to 3.68 ppm during the cooking phase of the process. It was produced on all occasions during the cook and not just during an overheating event, as has been suggested in the past.(9) The current ACGIH TLV® for phosphine is 0.30 ppm on an eight-hour time weighted basis with a STEL of 1.0 ppm.(10) The highest level observed was four times the STEL, suggesting that overexposure to phosphine is highly likely.
Actual field measurements with real-time phosphine meters have noted levels up to 23 ppm when opening a cooling 22 liter reaction vessel and over 28 ppm when opening a sealed Kaypak® bag of red phosphorus.
Phosphine, which causes cytotoxic hypoxia, is also a severe pulmonary irritant that may cause dyspnea, headache, paresthesia, diplopia, tremor, jaundice, and pulmonary edema. Death from exposure to phosphine has occurred to persons exposed as it was being used as an insecticide.(11) A laboratory investigator was also reported by Burgess to have developed dizziness, dry cough, headache, and diarrhea, with a delayed onset of cough and dyspnea, after investigating a clandestine laboratory. In the above referenced case, Tthe employee’s exposure was measured at 2.7 ppm phosphine and the duration of exposure was approximately 20–30 minutes.(12) In workers, phosphine exposure has been shown to cause gastrointestinal, respiratory, and central nervous symptoms at concentrations that are less than 10 ppm.(13)
There are a number of reasons why phosphine intoxication may be more common than reported. Phosphine mixtures does have a detectable odor but it may be less readily identified with the presence of the more odorous hydrocarbons present during the cook. In addition, the pulmonary toxicity of phosphine may occur shortly after exposure or it may be delayed for 18 hours or more. These factors may result in fewer reported symptoms, although pulmonary irritation is a common complaint after a clandestine laboratory investigation.(14)
Children and adults that are especially susceptible to pulmonary problems, such as asthmatics, individuals with chronic obstructive pulmonary disease, emphysema, etc, may show significantly greater effects to exposure levels of phosphine that are well below the concentrations allowed in the occupational environment. Unfortunately, at this time, there is no published data regarding acceptable levels of exposure for the general population to phosphine. The effects to these sensitive individuals are, therefore, not known at this time. [General Comment – Is this still accurate?]
Phosphine can be present even in sites where no activities have occurred for extended periods of time. During one of the common process, the reflux heating operation employs a container filled with cat litter known as a “death-bag.” The zeolites and other materials in the cat litter stabilize phosphine which can remain adsorbed onto the cat litter material for extended periods of time. A sudden shock, or bump can release the phosphine back into an atmosphere where cooking operations have long since been abandoned, resulting in exposures to latent phosphine.
5.1.2 Iodine
Iodine occurs as a toxic gas, that is sublimed from solid iodine. The current OSHA PEL is a Ceiling limit of 0.1 ppm; the ACGIH eight hour TWA TLV® is 0.01 and the IDLH is reported as 2 ppm. The AIHA ERPG-1 level is reported as 0.1 ppm (suggesting that most individuals can be exposed to 0.1 ppm for at least one hour without suffering more than mild, transient health effects).(23) The ERPG-2 level is reported as 0.5 ppm, and the ERPG-3 is 5 ppm.
Iodine is a reagent that is added directly to the cook in pseudoephedrine reduction methods as reduced iodine or as hydroiodic acid.
Airborne iodine concentrations during the controlled cooks have ranged from 0.01 ppm to 0.15 ppm.(9) The measured se levels are close to or exceeding the current ACGHIACGIH TLV®. The release of iodine during the red phosphorous cook becomes obvious when the dark brown effluent is observed (especially in the reflux condensation tube of the cooking apparatus). In addition, the walls in many of the cook areas appear to have a brownish yellow stain that may is reactive with spray starch forming a dark blue color indicating the presence of iodine. (The use of spray starch is not a reliable field indicator for the presence of iodine).
Iodine is an halogen with a very high vapor density (approximately 8.8, ref: air=1) Airborne iodine is a very heavy halogen vapor that is considered to be more irritating and corrosive than bromine or chlorine gases [GENERAL COMMENT: Is there a reference so the reader knows by whom I is considered more corrosive than Cl or Br?]. In animal studies, iodine vapor has been found to be intensely irritating to mucous membranes, causing damage in both the upper and lower portions of the respiratory tract. Iodine vapors can be an intense irritant to the eyes, mucous membranes and skin. ItIodine has a steep exposure- effects curve in that concentrations of 0.1 ppm may cause very little effect while levels of 0.5 ppm may cause severe irritation.(15)
Although there have been no known documented cases of over-exposure to iodine vapor in clandestine methamphetaminemeth laboratorieslabs reported in the literature, iodine could be a plausible cause of mucous membrane and eye irritation reported at many of the reportedse investigations. Iodine may persist for some time in the walls, carpeting, draperies, etc. and other surfaces present in many of these of clandestine laboratorieslabs. Because iIodine staining is readily and commonly observed on various surfaces of older clandestine drug labs, the walls, even after months of no cooking, suggestings that it can beis very persistent.
The fact that the iodine is persistent in the environment of a clandestine operation the cook is very important when considering the presence of to children that may be present in the clandestine laboratories in the environment of an active process as well as children who inadvertently become residents in a building previously used as a methamphetaminemeth laboratory. Children crawling on contaminated carpeting may be exposed to toxicologically significant pick up high levels of iodine.(9)
5.1.3 Hydrogen Chloride
Hydrogen chloride is an acrid acid gas with piercing irritating characteristics. The current OSHA PEL is a Ceiling limit of 5 ppm; the ACGIH Ceiling TLV® is 2 ppm and the IDLH is reported as 50 ppm. The AIHA ERPG-1 level is reported as 3 ppm, the ERPG-2 level is reported as 20 ppm, and the ERPG-3 is 150 ppm.
Hydrogen chloride is used directly as a reagent, as well as being intentionally generated during the “salting” process.
In a study conducted by Martyny, et al. National Jewish Medical Center (NJMC) , hydrogen chloride levels were measured during all of the controlled methamphetaminemeth cooks.(9) The levels ranged from less than detectable to a time-weighted average of approximately 10 ppm. Peak levels measured during the controlled cook ranged as high as 155 ppm(16) which exceeds the current IDLH concentration for hydrogen chloride. The most recent change to the current ACGIH TLV® for hydrogen chloride was proposed in 2003 and is a ceiling value of 2.0 ppm, much lower than the levels that have been found during the controlled cooks that have been conducted.(10) In fact, the Immediately Dangerous to Life and Health (IDLH) level for hydrogen chloride is 50 ppm, which is being approached by the levels generated during the salting-out phase conducted during the controlled cooks.(16)
Exposure to high levels of hydrogen chloride have been known to cause both acute and chronic effects. One individual exposed during a swimming pool cleaning effort developed severe bronchospasm and asthma. [General Comment – is this due to hydrogen chloride or was this due to mono/di/trichloramines? Is there a reference citation for this exposure?] Workers exposed to as little as 10 ppm of hydrogen chloride experienced work impairment. Hydrogen chloride is a strong irritant of the eyes, mucous membranes, and skin at levels that are well below the levels that we have been measured during controlled cooks. It would seem likely that individuals exposed to the measured concentrations measured during controlled cook that we have found would have acute symptoms from the exposure. Young persons and individuals with pulmonary problems may show much greater effects from a hydrogen chloride exposure than would an individual with an occupational exposure.(17)
In addition to hydrogen chloride, other acid gases may also be present, most notable sulfuric acid which is used in the production of anhydrous ammonia and in the production of hydrogen chloride.
5.1.4 Methamphetamine Exposures
Methamphetamine contamination ofin buildings where used to cook various processes have occurred methamphetamine is a common finding. in clandestine methamphetamine laboratories. Even labs that had been seized by law enforcement officials (and sometimes sealed or boarded-up) several months after identification still have high levels of methamphetaminemeth contamination on many surfaces within the building.(9) Public domain documents submitted to Governing Bodies in Colorado pursuant to Colorado State Health Department Regulations demonstrate that meth contamination levels can remain profoundly elevated for many years after a seizure and even after repeated attempts to clean the property.
Although the effects of methamphetamine are well known on individuals using the drug, the effects of low level exposures to emergency personnel or other associated individuals are not as well known. It is known that methamphetamine may cause some teratogenic effects and may change behavior in exposed infants.(18) Prenatal exposure to methamphetamine has been shown to cause an increase in pre-term labor, placental abruption, fetal distress, and postpartum hemorrhage.(18) Infants exposed to methamphetamine are generally smaller, have feeding difficulties, and are described as “very slow.”(18) Infants born to mothers that have used methamphetamine during pregnancy may have abnormal sleep patterns, poor feeding, tremors, and hypertonia. In some reports, subtle neurological abnormalities have also been found.
Currently, allowable levels of meth for re-occupancy of a structure or vehicle residence that has been used as a clandestine laboratory range from 0.1 μg /ft2 to 5 μg /ft2.(19) These levels have been set primarily in an arbitrary fashion at the limit of detection for the compound since, at this time, no “safe” level has been established. Since the drug meth appears to settle out or plate out via thermophoresis, on all porous surfaces in the area where it is unlawfully presentin which the cook is conducted, it is difficult to determine the actual dose of individuals working within that environmentatmosphere. It is generally accepted that logical to assume that hand-to-mouth contamination willtransfer will result in oral ingestion,[22] of meth (especially in the case of children), but it is also possible that percutaneous absorption of contaminants may occur in unprotected investigators.may also be possible for the drug to penetrate the skin of adults involved in the investigation.. . The State of California has recently begun to study the possibility of skin absorption and its role in methamphetamine exposure..
It has also been found that police officers handling suspects or children at the scene, for very short periods of time, can become contaminated with methamphetaminemeth. It is possible, therefore, for these individuals to carry this material off the crime scene and to their own families. Since there has not been a no-effect level established for this drug at this time, it would seem prudent to minimize exposure to as low as possible.
5.1.5 Anhydrous Ammonia Exposures
Anhydrous ammonia is a toxic flammable gas that produces is an immediate aversion reflex due to its extremely irritating properties. Anhydrous ammonia compound that poses an inhalation hazard, a dermal hazard, an ingestion hazard, and an ocular and mucous membrane hazard.(20)
The current OSHA PEL is 50 ppm and the ACGIH eight hour TWA TLV® is 25 ppm with a STEL of 35 ppm. The IDLH for anhydrous ammonia is listed as 300 ppm. The AIHA ERPG-1 is 25 ppm, the ERPG-2 is 150 ppm and the ERPG-3 is 750 ppm
The compound has a very pungent and suffocating odor that typically provokes an involuntary reaction drivesing exposed individuals from the area. It is possible, however, that olfactory fatigue can set in quickly allowing increased exposures to individuals. At concentrations exceeding 50 ppm, individuals may experience nose, throat, eye, mucous membrane, and airway irritation.(20) Extended exposure may cause wheezing, shortness of breath, and chest pain as well as tearing and ocular damage.(20)
Exposure to high levels of anhydrous ammonia (levels exceeding 2500 ppm) have been found to cause severe corneal irritation, difficulty breathing, bronchospasm, chest pain and pulmonary edema in otherwise healthy adults. The pulmonary edema associated with these exposures has been fatal in some instances.(21) Repeated exposure to high levels of anhydrous ammonia may cause chronic cough, bronchitis, asthma, vocal cord dysfunction, reactive airways disease, and lung fibrosis. In some cases, a permanent decrement in pulmonary function has occurred due to anhydrous ammonia exposures. Contact with the liquid state may also cause serious eye injury or blindness as well as skin burns.
The current OSHA Permissible Exposure Level (PEL) is 50 ppm and the ACGIH Threshold Limit Value (TLV®) for ammonia is 25 ppm as an eight-hour time-weighted average and 35 ppm as a short-term exposure level (15 minutes or less no more than 4 times per day).(10,22) The AIHA Emergency Response Planning Guidelines (ERPG) suggest that most individuals can be exposed to 25 ppm of ammonia for at least one hour without suffering more than mild, transient health effects (ERPG-1).(23) At 150 ppm, most individuals can be exposed for up to one hour without experiencing any irreversible or serious health effects (ERPG – 2). At an exposure level of less than 750 ppm, most individuals could be exposed for up to one hour and not experience any life threatening health effects.(23) The current NIOSH Immediately Dangerous to Life and Health Level (IDLH) is listed as 300 ppm.
As indicated by the preceding information, anhydrous ammonia poses a significant potential health risk to exposed individuals. The levels of anhydrous ammonia observed during controlled methamphetaminemeth “cooks” have ranged from 130 ppm to over 437 ppm as a time weighted average during the cook.(9) Real-time instrument measurements of anhydrous ammonia have been so high that the instruments were unable to obtain a reliable quantification, however colorimetric tube measurements collected during controlled cooks have routinely approached 2,000 ppm during the initial phases of the cook and may remain at over 500 ppm even in areas distant to the cook. Video documentation from hidden cameras in clandestine labs however indicate that massive exposures approaching saturated atmospheres have been recorded. Based on these exposures, it is likely that individuals using this method of manufacturing methamphetaminemeth will be over-exposed to anhydrous ammonia and that they will suffer some symptoms associated with that exposure. There is also a high likelihood that the exposure will approach or exceed the NIOSH IDLH level by a significant margin.
A large study of the health effects due to methamphetaminemeth lab investigation by federal, state, and local law enforcement from 39 U.S. states was conducted by National Jewish Medical CenterNJMC.(24) In addition to confirming many findings reported in the smaller studies by Burgess, thise NJMC study also provided new information regarding this first responders and law enforcementunder studied occupational group. The NJMC study reported a higher percentage of investigators experiencing at least one symptom in association with methamphetaminemeth lab investigation.(24) Not only did they find an increased risk of irritant type symptoms, as was previously reported, but also an increased risk of a wide array of other symptoms, suggesting that methamphetaminemeth lab investigation may have health effects to multiple organ systems.(24)
In the NJMC is study, over 70% of law enforcement personnel reported experiencing symptoms during or immediately after lab investigation.(24) Most of these symptoms would be expected given the potential exposures to strong acids and bases, solvents, methamphetaminemeth and other toxic materials. Headaches, respiratory symptoms, sore throat, and central nervous system symptoms were the most frequently reported symptoms.(24) Although most respondents had short-lived duration of symptoms, some respondents had symptoms lasting days to months, perhaps implying a more serious medical condition. Medical attention was most frequently sought for physical injury, perhaps because injuries are less easily ignored, whereas symptoms such as cough, headache and sore throat may be easily minimized.
Specific risk factors were found to be associated with individual symptoms and symptom groups.(24) Participation in the entry phase was associated with irritant type symptoms. Although the entry phase was the shortest phase, it had the highest percentage of people performing the duties without a respirator, suggesting that exposures without a respirator during this phase maybe especially problematic.(24) Participation in the processing phase was a significant contributor to the development of one or more symptoms and respiratory symptoms. Although a large percentage of people wore respiratory protection for this phase, processing was a longer task. These findings suggest that despite the use of respirators, the longer duration of the processing phase contributed to the development of symptoms.(24)
The researchers found that investigators performing more than 30 methamphetaminemeth lab investigations had a higher risk of health effects.(24) In addition to the increased exposure due to more labs investigated, other factors may have contributed to the higher risk of symptoms to the more experienced investigator. The more experienced law enforcement officer may investigate labs suspected of having higher hazards such as active “cooks” or larger quantities of chemicals found at the lab site. In addition, a more experienced officer is likely to have been investigating labs before the availability of PPE. In fact, entrance into an active lab was associated with sore throat.
5.1.6 Organic Solvents
Investigators will encounter a wide variety of organic solvents in a clandestine operation. The solvents may pose toxicological threats, flammability threats, or explosive threats; indeed, the threats are not mutually exclusive, and a single material, such as “pet ether” may pose all three threats simultaneously.
Most of the organic solvents found in clandestine operations compounds have relative high vapor pressures, and relatively low flammability limits. Based on experience, the most commonly encountered organic solvents are methanol, acetone, Coleman® fuel (light hydrotreated distillates), toluene, xylenes, propane and petroleum ether.
Some materials such as pet ether, may form peroxides resulting in shock sensitive threats of both detonation, (explosions that travel via supersonic shock waves) as well as deflagration (subsonic explosions through a burning process).
The occupational exposure limits, and signs and symptoms of exposure will be incumbent on the specific compounds and/or mixture of compounds.
Explosivity limits are not dependent on the identification of the specific compounds, and can be determined in the absence of identifying the materials present. Importantly, the use of catalytic pellistor explosivity meters are quickly rendered faulty in atmospheres containing phosphine; the presence of phosphine will suppress the apparent explosive reading of an atmosphere.[23]
Very often the investigator will be engaged in independent sewer systems (septic tanks and leach field operations), wherein explosive vapors may accumulate. Other areas of accumulation can be cellars, basements, crawlspaces, and false (hidden) rooms within a structure.
5.1.7 Bases
The processes involved use large quantities of bases, and most commonly encountered are sodium hydroxide, lithium hydroxide, and ammonium hydroxide. Some of the bases, such as sodium hydroxide, are intentionally used as reagents for pH control; some, such as ammonium hydroxide and lithium hydroxide are inadvertently created.
The bases are found either as aqueous solutions or solids. Airborne exposures to bases, except during accidental aerosolization is not common.
5.1.8 Blood Borne Pathogens and Endotoxins
During assessments and investigations one very commonly encounters unusual situations involving blood, feces and urine. Clandestine drug operations involving meth almost always have a sexual activity component. Often, one can encounter stores of large quantities of human urine (these individuals are known as “tinkle tweekers”) as well as stored human feces. Additionally, clandestine lab operations often involve extreme squalor and it is very common to encounter cat, dog, and human excrement openly present throughout a residence. Endotoxin exposures should be considered as “significant” during all pre-remediation phase of assessment and investigations.
5.1.9 Toxic Molds
Recently, and especially in Canada and England, popular rumors regarding “toxic mold” have evolved. The rumors are not based in science, and there currently is no evidence that molds pose any particular mycotoxic threat in clandestine operations, including those that involve marijuana.[24]
5.2 Physical Hazards
Clandestine drug operations are a patchwork of hazards that often are associated with bizarre and irrational thought processes. Frequently investigators encounter conditions, situations, and equipment that defy rational explanation. Similarly, it is not uncommon to encounter site conditions that have been intentionally developed by the occupant, but which the occupant can no longer recall why they created the situation, or equipment.
5.2.1 Anti-personnel Devices (APDs)
Antipersonnel devices are not passive hazards. The APD is an intentional action designed to hinder movement or harm people in a structure. Antipersonnel practices can include the release of “pet” snakes and/or “pet” spiders within a structure, or the presence of hidden trip wires that activate detonations, firearms, or deflagration episodes.
Antipersonnel devices are commonly encountered and take the form of a wide variety of both sophisticated explosives and apparatuses (involving trip wires and hidden switches) as well as something as simple as dangling small fish-hooks throughout a structure or approach to a property to limit movement.
Passive bombs (booby traps), and active explosives are commonly encountered in clandestine drug operations. The production of a deflagration bomb is as easy as keeping a jar of acetone containing a Brillo® pad or S.O.S.® scouring pad in a microwave oven. Once the oven is activated, the steel wool ignites the acetone resulting in a fire or explosion.
In 2011, first responders arriving at a clandestine drug laboratory[25] encountered the presence of large quantities of the high explosive triacetone triperoxide (TATP). The clandestine lab was operated by an otherwise unremarkable high school student in his bedroom. The individual was engaged in the co-production of methamphetamine and TATP.
Indicators of iodine at a site should immediately alert the investigator to the potential presence of various allotropes of phosphorous and most notably red and white.
A generally good rule in initial response investigations is to bring one’s own light source, and avoid activating or deactivating any electrical switches. Prior to opening devices such as refrigerators and microwaves, the investigator should get into the practice of unplugging the device. Often in the early stages of the investigation, law enforcement personnel will request the power authority to deactivate the structure. Following preliminary entry, and sweeps, the power can be reactivated.
5.2.2 Electrical Hazards
Unlawful and dangerous electrical modifications are very common in clandestine operations. Hazardous live wiring within a structure is extremely common. Often, to avoid detection, the operator of a site will e stealing electricity directly from the grid, circumventing the electrical meter for the structure.
5.2.3 Hazardous Personnel
Industrial Hygiene consultants are generally not trained to deal with dangerous individuals who, in many cases, may now be their client. The reality is that the occupants are criminals, successful prosecution notwithstanding. The criminal element is necessarily an over-riding factor in the consideration of clandestine drug lab operations.
Violent personnel, guns and knives (either concealed, displayed or actively wielded), become hazards the professional Industrial Hygienist has not traditionally had to address. In the assessment of clandestine drug operations, these issues become very real problems, even for laboratories that may be seized, closed, and unoccupied for years.
One notable Industrial Hygiene firm has written SOPs requiring at least one member of the assessment team to be armed at all times. Two-person teams should be considered for all assessments, regardless of the phase of the assessment. The concept and practice of “protective sweeps” should be considered by consultants involved in clandestine drug lab operations. Armed protective sweeps should be considered as a possible normal practice.
For pre-remediation assessments, once the protective sweep has been completed and the assessment team enter the structure, the doors should be secured from the inside. All team members should maintain communications with reliable field walkie-talkies.
It is not uncommon for law enforcement to be dispatched to a former meth lab, with guns drawn, and encounter an Industrial Hygienist innocently going about their business. To avoid such encounters, prior to entering a site for an investigation and assessment, the assessing team should contact the local law enforcement agency with jurisdiction and advise them of the presence of the assessment team and the objectives of the site presence. The assessing team should provide local law enforcement the following information:
1. The purpose of the notification
2. Number of members on the assessment team
3. Team leader name and cell contact information
4. Description of authorized vehicles on site
5. Status of personal protection of team members (armed or unarmed)
6. Time of arrival and estimated time of completion
The assessment team may request periodic “status checks” for the anticipated duration of the on-site team. Once the assessment team leaves the property, they should contact the local law enforcement and “clear” themselves from the site.
For the safety of law enforcement and assessment team personnel, if uninformed law enforcement personnel arrive on scene, assessment personnel should be prepared to be ordered to the ground at gun-point. If this happens, make no attempt to give explanations until asked, and make no attempt to retrieve identification until asked. If any assessment personnel are armed, they should identify themselves immediately as such by simply stating “I am armed” while keeping their hands up and away from their body.
Some states disallow property owners and occupants or other personnel from being on site during assessments. The Industrial Hygienist should inform their civilian client that only preapproved personnel will be admitted during the assessment. If unauthorized personnel arrive at the structure, law enforcement should be immediately notified, even if the individual is the owner of the property. The unauthorized personnel should not, under any circumstances, be granted entry (even if they are the legitimate owner of the property). An authorized personnel should be instructed to leave immediately, and should be informed that law enforcement personnel have been notified and are responding to the site.
5.2.4 Sharps
During field assessments, the assessment personnel should be cognizant of the potential for the presence of sharps hidden throughout the structure. Unlike legitimate syringe use, where the individual maintains good sharps disposal practices, assessment of clandestine drug processes very often involve the presence of syringes hidden and exposures through the structure and in locations that are otherwise inexplicable and irrational.
Assessment team personnel should consider adding patrol style “street gloves” to their PPE ensemble. Street gloves are thin enough to permit normal manipulations but provide added protection against needles, and other puncture hazards. Surgical gloves readily fit directly over street gloves.
If the Industrial Hygienist identifies the presence of sharps, that information should be included in the “pass-on” information to the remediation company.
5.2.5 Slips, Trips and Falls
Clandestine operations, even in normal residential houses, can create unique physical hazards for movement. Structures are frequently extremely cluttered and normal access routes through a structure may be partially blocked by debris and furniture.
Good, proper footwear should be mandatory for all assessment personnel. Sneakers, loafers, sandals, and dress shoes should not be permitted footwear for assessment personnel. If the entry is made in Level C ensembles and higher, protective outer suits should be belted with duct-tape to avoid snagging as one attempts to move through the residence or structure.
Often times, the assessment team will be moving through a fully furnished business, camper, or residence. The furnishings and configuration of the space may be exactly as they were when law enforcement made initial entry. Under such conditions, movement through the residence or structure should be slow, systematic and methodical.
5.2.6 Structural Hazards
Structural modifications are common in building where clandestine drug operations have occurred. Those modification can include hidden rooms, underground vaults, and highly modified spaces.
The work is never performed pursuant to standard construction permitting and can pose unusual hazards in and of themselves. Furthermore, the modifications can hide other hazards, as well as serve as chemical repositories that will required decontamination.
Societal Effects
The effects of methamphetamine clandestine drug operations production and use have far reaching effects beyond those that choose to get involved with the drug culture. Oftentimes there are unknowing children or other occupants of a structureproperty in which methamphetamine clandestine operations are occurringis being or has been produced by clandestine means. The materials and byproducts introduced into the air and/or and spilled residue from solvents and corrosive materials may remain in a property long after the offending occupants meth cooks have left. Hotel rooms, rental properties, and homes for sale on the market could have been former meth labs, and the residue from chemicals used, APDs, syringes, structural and electrical modifications, and the drug itself may remain for weeks, months, or even years.
6.1 Children
There have been many cases across the country in which children have been present during a meth lab discoverybust. Often, these children see their caretakers being taken to jail, but are also commonly subjected to on-site decontamination similar to that conducted during a hazardous material spill. Acute exposures to children to some of the contaminants present byproducts produced during methamphetaminemeth processing production, including solvent vapors and phosphine gas, are very real and can produce harmful effects. It is known that children occupying meth lab properties often test positive for methamphetaminemeth in urine and blood samples by simply living in the home.(25)
6.2 Property Owners
Property owners are also greatly affected by meth labs on their properties. This includes rental home owners, apartment and townhome/condominium complexes, hotels and motels, rural farms and ranches, governmental agencies, and even storage locker facilities. Once a meth lab is left behind or discovered busted by authorities, a trail of contamination is often left behind. Waste containers and glassware with potentially volatile and toxic compounds can be left behind or the waste generated is dumped in sanitary or storm sewers or poured onto the ground, affecting soils and groundwater. The assessment and cleanup of these properties can be quite costly and present a huge problem for property owners. Not only is cleanup often required prior to re-occupancy depending upon jurisdiction, rental and re-sale values may be greatly affected. Many states are beginning to require disclosure of former meth labs on real estate transaction documents. Obviously, the problems presented to property owners are wide-ranging and can be very expensive.
6.3 Law Enforcement Personnel
Law enforcement personnel are affected by methamphetaminemeth laboratorieslabs far beyond just tracking the perpetrators and making arrests. Law enforcement personnel frequently respond to properties for issues not related to drug activities and are entirely unaware of the environment in which they may be performing other enforcement actions. Local health department and social services personnel can also be affected when visiting properties unaware it is a meth lab.
The Law Enforcement Personnel are often engaged in called upon to conduct meth lab raidsbusts during active cooking operations and they can be exposed to the associated chemical hazards at the peakmaximum levels occurring during production. Local health department and social services personnel can also be affected when paying visits to properties they may not know house a meth lab.
Ten years ago, Llaw enforcement personnel, social workers, and local health departments were are now being trained extensively in the proper use of personal protective equipment and chemical hazard recognition in clandestine operations, however that funding and subsequent training has now been significantly reducedto previous unseen levels.(26) As a result, most patrol officers in the US are not sufficiently trained to recognize the indicators of a clandestine drug operation during a service call.First responders and local health department personnel alike can now routinely be expected to receive training in chemical recognition and hazard awareness similar to training received by hazardous material workers. Suffice it to say, iI Industrial hygienists can provide a key role in assisting first responders and local health department workers with regards to safe handling of methamphetaminemeth labs.
6.4 Industrial Hygienists [General Comment – This is a duplicated section. This language should be combined with “Section 7 Industrial Hygienists” below.
Industrial hygienists are often called upon to provide assistance in assessment of contamination and remediation of meth lab-contaminated properties. Industrial hygienists' unique training in chemical hazard recognition and control can play a key role in the characterization and
remediation process. Industrial hygienists can provide assistance in hazard recognition to first responders during entry and are increasingly more involved in exposure assessment strategies for law enforcement and first responders. Industrial hygienists also work with remediation contractors in assessing site-specific hazards and provide training for contractor personnel in the unique hazards associated with meth labs. Industrial hygienists can provide guidance for property owners and remediation contractors from initial assessment stages through post-cleanup and re-occupancy evaluations. Industrial hygienists perform a critical function in clandestine meth lab cleanup. Some state regulations have recognized this expertise by requiring the involvement of trained and, in some cases, Certified Industrial Hygienists in preliminary and post-cleanup
assessments as well as health and safety oversight during the remediation process.[General Comment – there is no reference number 27… to what does this refer?](27)
6.5 Health Departments and Regulators
Health departments and regulators are faced with developing and enforcing public health standards pertaining to meth lab recognition and cleanup, an often difficult task considering the rapidly changing environment and dynamic characteristics of meth lab contamination. Regulators must not only deal with property contamination issues, but also property and real estate transaction laws. The lack of federal requirements or standards for meth lab cleanup makes it difficult for state, county, and local jurisdictions to develop their own technical regulations. Urban and rural regulators alike are often ill-equipped technically or financially to address this rapidly growing community problem.
6.6 Insurance Companies
Insurance companies are becoming involved in property damage claims with a form of loss they have never had to address in the past. Property owners are often unaware of drug activity on their properties, caused either by tenants or unwanted visitors (e.g. rural farm or ranch properties). The majority of property owners may not recognize the signs of a meth lab until it’s too late; at the time when they are faced with the discovery and cleanup costs. Meth lab cleanup may or may not be addressed specifically in insurance policy language, making the claim process often difficult to interpret. It is understood that insurance companies already have, or are in the process of, specifically addressing meth lab contamination on properties that they insure.
In addition to addressing the criminal aspects of illegal methamphetaminemeth labs, the U.S. court system is also forced to deal with property contamination and transfer issues related to meth labs. The courts are already hearing meting out lawsuits arising from property contamination and cleanup issues as well as litigation related to health effects caused by residing in a former meth lab.
Clandestine methamphetaminemeth manufacturing affects many facets of society, many of which can be assisted by trained industrial hygienists.
The Industrial Hygienist [General Comment – this is a duplicated section. Should be combined with Section 6.4 Industrial Hygienists]
From assisting first responders in identifying real-time hazards during entry to helping property owners with contamination and remediation issues, industrial hygienists are called upon in many ways. Industrial hygienists have also played a role in many states in helping formulate regulations pertaining to meth lab cleanup.
Residual or substantial contamination of a property can occur ias a result of the meth cooking process, meth distribution and sales, smoking or use, and the waste stream produced. Contamination can persist until the lab or property is remediated. Contamination may consists of residual methamphetaminemeth itself as well as chemical contamination from the reagents used in the process and intermediate products and byproducts used andas well as the waste stream produced. Residual meth or other chemical residues can migrate throughout permeate an entire property via several mechanisms: through passive airborne distribution, through HVAC systems, via tracking throughout a property by meth cooks and consumers, and via dumping of waste within a property’s plumbing system, septic system, and/or on the exterior grounds of a property. Contamination can also affect adjacent properties or other adjacent units, in the case of motel rooms, apartments, and condominium complexes.
1 How Industrial Hygienists Get Involved
As noted above, industrial hygienists may beare involved in the initial stages of meth lab production when by assisting law enforcement personnel during the bust of a meth lab raid. This is often when human exposures to physical hazards and chemical contamination contamination most significantand airborne toxins may be at their worst. Industrial hygienists working with law enforcement and other first responders can help in selection of appropriate respiratory protection as well as other PPE necessary for for use by those enterentrying into a lab. Industrial hygienists can assist with interpretation of air monitoring data at the scene, as well as immediately assessing criteria and adequacy of gross decontamination of responding personnel.for removal by law enforcement. In addition, industrial hygienists can work at increasing awareness in occupational at risk front line groups such as child protective services employees, meter readers, code enforcement personnel, and animal control officers who are likely to encounter discover meth labs such as child protective services employees, meter readers, code enforcement personnel, and animal control officers. AwarenessThis training can include recognizing the indicators of a meth lab, the dangers associated with a lab, decontamination of personnel and equipment and appropriate personal protective equipment for entry into meth labs during or following law enforcement efforts.
Industrial hygienists are often involved in assessing contamination of a property and assisting property owners in remediation efforts after a property is known to have been a clandestine meth lab. This document is intended to be a guideline for assisting the reader in becoming familiar with methamphetamine production, assessment, contamination, and decontamination issues. The reader is advised to seek further training (and certification in some states) if intending to become involved in clandestine drug lab cleanup.
8. Why Decontaminatione? [General comment – the topic is split- is this decontamination or is this assessment?]
Following discovery of a clandestine operation, After the cooking process of methamphetamine has stopped, many most of the known hazards can diminish but may persist as in residuesal amounts until adequately decontaminated.they are cleaned up or otherwise removed from the property. As has been stated previously, exposures to even residual amounts of some of these contaminantsbyproducts maycan result in produce harmful effects. Proper removal of the production wastes and bulk chemicals eliminates many of the risks associated with meth labs. Spilled volatile chemicals and solvents such as ammonia, methanol, ether or acetone will quickly evaporatemove into air and will be readily removed from the structure by ventilation. Semi-volatile or non-volatile production chemicals such as acids, bases, precursor chemicals, and products used or created in the manufacturing processes are more persistent. Smoking meth indoors results in contamination will also distribute methamphetamine throughout the structure and the structure’s contents. Handling methamphetaminemeth during production, use, and packaging the drug for distribution may result in spills onto floors and other surfaces. The risk of injury from chemical exposure depends on the chemicals themselves, their distribution, surfaces involved, quantities, and the length and route of exposure.
Cooking methamphetaminemeth by any method will result in the release of ingredient chemicals, the precursor drugs (pseudoephedrine or ephedrine), methamphetamine vapor and particulate, and other known and unknown byproducts. Chemicals may enter the body by inhalation, ingestion, injection (including by a contaminated needle or accidental skin prick), or absorbed by the skin.
Both acute (short term) and chronic (long term) health hazards can result from exposures received while in a clandestine meth operation.the manufacturing of methamphetamine. Acute exposure symptoms such as headaches and dizziness and physical responses hazards including burns and irritation, can occur with come from direct contact with the chemicals involved.product or waste, and inhalation of product or wastes. Burns, tissue irritation and rashes can result from chemical spills and skin contact. Headaches, dizziness, nausea, and other health effects can result from inhalation of vapors.
Chronic exposures can be the result of residual contaminants that have migrated throughout a structure. The residual contaminants may settle out, absorb into, or adsorb onto clothing, and building materials.
9 The Preliminary Assessment Process
The assessment process can be divided into three primary phases:
1. Raid and entry assessment
2. Civil process assessment
3. Post remediation assessment
9.1 Raid and Entry Assessment
Prior to the raid, the Industrial Hygienist may be called upon to assist first responders/first receivers in the development of the operational risk assessment plan. The industrial hygienist’s assessment at this stage will be almost exclusively restricted to reviewing the available intelligence and helping to determine the type of clandestine process that may be occurring, and thus, the chemical hazards that may be anticipated upon entry. For this to occur, the industrial hygienist needs to be knowledgeable on various processes that may be occurring, how to make meth, and the many variations associated with clandestine drug activities.
During this planning phase, law enforcement personnel are focusing their attention on tactical considerations and safety of children. Industrial hygienists may be asked for their input on the appropriateness of the selected PPE and how that may adversely impact tactical considerations.
For example, if based on the intelligence, the industrial hygienist determines that the lab is a exclusively a pill pull operation, the appropriate PPE ensemble may be downgraded to patrol clothing. If the industrial hygienist identifies intelligence that is suggestive of coproduction of LSD or fentanyl, the perceived risk should be immediately communicated as “extreme” and entry should be attempted, if possible, only when the building is unoccupied, and then only in a Level A ensemble.
The industrial hygienist should be prepared for a nontraditional response to their recommendations. Law enforcement command personnel may determine exigent circumstances or tactical considerations warrant an immediate response without any traditional PPE or monitoring. The risk assessment process in law enforcement will appear to be very foreign to the industrial hygienist who has traditionally provided health and safety consultation on civil projects such as hazardous waste clean-up operations.
Immediately following the raid, the risk assessment equation may change dramatically, and command staff may consult with the industrial hygienist to determine the most appropriate PPE and monitoring considerations during evidence collection and stabilization.
During the pre raid assessment, the industrial hygienist should be prepared to communicate with first receivers. The industrial hygienist can provide pertinent toxicological and exposure expectations, as well as determine if local first receivers are capable of handling anticipated exposures.
During the pre raid assessment, the industrial hygienist can communicate with fire and on-scene medical and provide pertinent toxicological and exposure expectations, as well as help define appropriate personnel decontamination procedures.
9.2 Civil Process Assessments
The industrial hygienist may be called to perform an assessment of a property in two non-law enforcement scenarios:
1) A cursory evaluation to determine if there is evidence of contamination that warrants further investigation
2) A preliminary assessment to characterize site conditions of a discovered clandestine operation.
9.2.1 Cursory evaluation
During a cursory evaluation, there is no information from a cognizant authority indicating a problem exists. In a cursory evaluation, the industrial hygienist is not attempting to characterize a site, but rather, attempting to determine if evidence of a meth lab exists, and determine if further investigation is warranted.
The evaluation may be requested by a Real Estate agent, or a prospective home-buyer, who merely wants to know if the property is potentially contaminated or was a former meth lab. The evaluation may be requested by a school, health and human services or child protective services who need to determine if there is evidence of a meth lab in an home. The evaluation may be requested by a landlord prior to renting a space or following a tenancy of a space. The evaluation may be requested by an insurance agency who is handling a claim on a stolen car, or box-van that is returned to the owner, wherein drug paraphernalia or production equipment was recovered.
In each case, the data quality objectives (DQOs) are not stringent environmental standards, but rather, the industrial hygienist is called upon to determine if further investigation is needed. In general, where this is the case, the industrial hygienist may develop an inexpensive sampling plan to test an hypothesis of contamination with a low probability of false negatives. Usually under such circumstances the industrial hygienist will rely on authoritative biased judgmental sampling theory and collect a limited number of indicator samples.
The purpose of a cursory evaluation is not to determine the extent, distribution, or even degree of contamination within a structure or property, but rather determine if objective evidence of probable contamination exists.
For example, for a 1,500 square foot single family residence, the industrial hygienist may opt for compositing ten wipe samples from the structure into two quantitative analyses for meth and establish an a priori reportable limit as a decision threshold above which further investigation will be deemed appropriate. In a cursory evaluation, the industrial hygienist will rely on professional judgment and pertinent regulatory environment to help the client make an informed decision.
9.2.2 Preliminary Assessment
In a preliminary assessment, information exists from a cognizant authority that a meth lab does or has existed at that location. The preliminary assessment is a site characterization.
The confirmatory information from a cognizant authority may be law enforcement documentation, or it may be a real estate disclosure from a home seller that they once used the property as a meth lab, or it may be from the results of one’s own cursory evaluation.
Depending on the site specific conditions, if the discovery is from a law enforcement action, Typically, most of the bulk quantities of chemicals, byproducts, and glassware, and other evidence of clandestine drug production aremay have been removed from the propertyies by authorities prior to athe preliminary assessment. However, recently, funding from the US DEA to local jurisdictions for bulk removal and stabilization has been withdrawn, and in many jurisdictions the industrial hygienist may be entering the property in conditions that were virtually identical to those that existed at the time of the law enforcement closure. Remarkably, in some circumstances, the property may not only be still occupied by the criminals, but they may yet have in their possession much of the manufacturing equipment.
Law enforcement agencies generally discourage their field personnel from seizing equipment and bulk materials, since the agency then becomes the waste generator, with liability for disposal. More typically, field investigators will merely photograph equipment and containers, and they will collect samples of reagents, and solutions. Very often, field personnel will irreparably damage and dismantle equipment but otherwise leave the equipment on scene for proper disposal. With the exception of actively growing marijuana, law enforcement personnel will seize all known quantities of illicit controlled substances, regardless of the quantity.
Products and containers found seized during a law enforcement action bust are catalogued by authorities for use as evidence. and eventually destroyed. After cataloguing the evidence, law enforcement authorities often contract with private Hazardous Materials companies to package and transport the waste stream. What is left behind can be a toxic mixture of bulk materials, residual chemicals and drug residue, and smashed equipment, both inside and outside of the property, that will undoubtedly affect future occupants if not corrected.
Some states or other jurisdictions have regulations pertaining to contamination assessment and remediation of former meth labs.(27) [General comments – there is no reference 27] The process of an industrial hygienist conducting a contamination evaluation of a property is typically called a Preliminary Assessment, which is how it will be referred to in this document. Where present, those regulations will dictate minimum elements to be included in the assessment. Where the jurisdiction does not have regulations, the industrial hygienist should develop and follow a written assessment plan, with standardized field assessment forms. Examples of some standardized forms may be found in Appendix ? of this document.
The pPreliminary Aassessment Pprocess typically involves the following elements, some of which will be discussed in detail and some of which may have jurisdiction-specific statutory or regulatory requirements that will be briefly addressed. The reader is advised to consult with local regulatory authorities to ensure compliance with applicable regulations pertaining to clandestine drug lab assessment and cleanup.
• Document Review
• Physical Assessment
• Wipe sampling for methamphetaminemeth residue
• Sampling for other chemical contamination
• Remedial recommendations
• Decision criteria Clearance for rRe-occupancy without remediation
The information presented in this guidance document relies on an remediation assessment process rather than achievement of a clearance criteria that may or may not be based on health-based scientific evidence. It remains the responsibility of the industrial hygienist to either ensure compliance with local regulations, or in the absence of regulatory mandates, to use sound science, and professional standards to develop a risk based clearance process.
Some states have enacted legislation and regulatory requirements for assessment and cleanup of former meth labs. There may also be county or city ordinances pertaining to meth lab cleanup, depending upon the reader’s location within the U.S. The reader is advised to consult with local regulatory authorities to ensure compliance with applicable regulations pertaining to clandestine drug lab assessment and cleanup prior to performing these functions.
9.2.2.1 Law Enforcement and Health Department Document Review
It is important to learn as much about the property prior to even visiting a former meth lab site. The initial phases of a preliminary assessment should involve reviewing law enforcement and regulatory enforcement documentation related to the property. This documentation often reveals what chemicals were seized and in what quantities, what type of process was occurringmeth manufacturing was being used, and the actual location(s) of the lab within the property. Law enforcement authorities in many states complete a “National Clandestine Drug Lab Seizure Report” (often referred to as an EPIC form) that are available for the evaluator to review when considering cleanup issues. These documents can provide very valuable information to the IHindustrial hygienist when developing assessment and cleanup strategies for a property. These reports must be requested ordered from the local law enforcement jurisdiction that handled the crime scene.
As part of this process, the industrial hygienist may also gain considerable insight by interviewing law enforcement personnel as well as interviewing the occupants of the structure that were engaged in the illegal activity. Industrial hygienists should not shy away from attempting to interview the criminals but should develop protocols that ensure their safety – such as telephone interviews. Interviewing meth addicts face-to-face involves unique hazards and requires a skill set not possessed by most industrial hygienists.
2 [General Comments – this section has been moved for continuity, and edited.] Compliance with Local Regulatory Requirements
Some states have enacted legislation and regulatory requirements for assessment and cleanup of former meth labs, although many states have no remedial requirements. There may also be county or city ordinances pertaining to meth lab cleanup, depending upon the reader’s location within the U.S. The reader is advised to consult with local regulatory authorities to ensure compliance with applicable regulations pertaining to clandestine drug lab assessment and cleanup prior to performing these functions.
9.2.2.2 Physical Assessment
A physical assessment to the site is imperative. In general, most site assessments will fall under the scope of 29 CFR §1910.120 Hazardous waste operations and emergency response.
Entry Considerations
Prior to conducting a preliminary site assessment for methamphetaminemeth contamination, industrial hygienists must be aware of associated considerations related to safety and personal protection. It may be advisable to coordinate entry into a contaminated property with local law enforcement authorities, if possible. Based on the inherent inclusion of a criminal element, it may be appropriate in some cases to request law enforcement participation or protection (e.g. drive-by surveillance, etc.) while the assessment is being conducted. Personal protection from chemical hazards encountered during the assessment is also of the utmost importance as is atmospheric monitoring for the presence of toxic or explosive vapors. The length of time between methamphetaminemeth processing manufactureoperations and when the site assessment are performed are important considerations when choosing personal protective equipment (PPE) and atmospheric sampling strategies, as airborne and surface contamination levels of volatile and semivolatile contaminants can be expected to decrease over time.
Personal Protective Equipment [General comment – formatting and style in the following sections is not consistent and should be “cleaned-up”]
PPE considerations should be consistent with 29 CFR 1910.120 considerations and consider the preliminary information presented above. The PPE selection should , includeing the type of clandestine processmanufacture that occurred, the type and quantities of chemicals anticipatedencountered, the length of time between ceassatione of contamination-generation and the Ppreliminary Aassessment, etc. Law enforcement authorities and first responders often use Level A or Level B protection when entering a meth lab. While airborne vapors can be expected to diminished over time, residual airborne drug contaminants can still persist as can surface contamination of drug residue, corrosive, and organic residues.
PPE should include, at a minimum, the following:
• Tyvek® or other appropriate chemical-protective coveralls
• Surgical Two layers of nitrile gloves over street gloves
• Proper foot protection to prevent needle sticks, etc.
• When entering a known contaminated meth lab, full-face negative pressure respirator with dual organic vapor cartridge and P-100 cartridge (Note: respiratory protection is completely dependent upon site circumstances, measured airborne contaminant levels, length of time after seizure if any, etc. Users are cautioned to select respiratory protection based solely on individual site considerations.)
• Increase PPE level as necessary depending upon contamination levels and site conditions
Atmospheric Monitoring
Atmospheric sampling should be conducted upon entry of a former drug lab to determine explosive vapor or toxic contaminant levels, similar to entry into a confined space. Atmospheric sampling data should be recorded on a Ppreliminary Aassessment site log or other form of documentation. In some cases, the assessment process can occur months or even years after initial discovery the bust of a former meth lab, when airborne vapor levels can be expected to be diminish to minimal. Readers are advised to consider these factors when choosing atmospheric sampling strategies.
Training
Industrial hygienists and other personnel conducting site assessments should have training specific to drug lab assessment and cleanup in addition to formal training in the field of industrial hygiene. Training should include familiarity with the methamphetaminemeth production processes, chemicals used, byproducts produced, appropriate PPE, and sampling methods and compliance issues specific to state or other regulatory requirements. Certification of personnel conducting preliminary assessments and remediation is required in some states., with other states considering or enacting drug lab cleanup requirements.
4 Conducting the Site Assessment
The site assessment involves conducting an evaluation of chemical contamination and other hazards and residue aton the property grounds. This evaluation involves physical observations both within structures on the property and in adjacent spaces and external grounds. Assessment of a clandestine drug lab site should consider the following:
• Accessibility of residues, and frequency of direct contact: The likely or anticipated future use of a contaminated area is an important factor in estimating frequency of contact. For example, residues in a kitchen or bathroom of a house will likely be contacted more frequently than residues in an attic or crawlspace non-residential outbuilding.
• Characteristics of the inhabitants or users of the structure: The characteristics and types of present and future occupants of a meth lab property are important factors in determining the extent and accessibility of contamination. For example, toddlers who crawl on carpet or floors have more likelihood of high frequency skin contact with toxic residues over a considerable area of skin, and an higher probability of ingesting contaminants as a result of this skin contact.[26] Some These residues may directly irritate the skin, and some may also be absorbed into the body through the skin. If hand-to-mouth behavior occurs when hands have been in contact with toxic chemicals, these will be ingested into the body. Hand to eye behavior will introduce toxic materials to the eyes. The toxicity of meth lab residues will depend upon the amount of the residue, and the chemicals in the residue. The amount of residues will depend upon the type and size of the meth lab, the length of time it operated, methods of chemical storage and disposal, occurrence of chemical spills, as well as on the physical characteristics of the structure in which the meth lab occurred. In short, the chemicals in the residue will vary with the method of methamphetaminemeth manufacture. In most cases, it is best to begin a preliminary assessments based on the presumption that all rooms or “functional spaces” within a structure and all structures on an identified meth manufacturer’s property are considered potentially contaminated.
5 Manufacturing Method
The method of methamphetaminemeth manufacturing or knowledge of the type of process occurring at the property will always provide valuable information pertaining to the types and quantities of chemicals used in the cooking process. The manufacturing method, be it the Red P, P-2-P, Birch Reduction, or other method, is often identified on law enforcement documentation or other preliminary documentation. As presented earlier, there are many different chemical contamination sources used in clandestine drug manufacture and it is possible to encounter any or all types of associated residual chemical contamination in a meth lab.
It is also quite possible that the manufacturing method is unknown. In these cases, the industrial hygienist must use site observations and characteristics and previous experience in determining potential chemical contamination. When the manufacturing method cannot be determined, it may be necessary to conduct extensive sampling or remediation activities than those described herein or resort to more extreme remedial activities, such as complete tear-out or interior walls, ceilings, and HVAC system.
6 Physical Assessment and Observations
Caution: It is recommended that the “Buddy System” (i.e. at least two personnel on Site) be employed when conducting a physical preliminary assessment. Readers are advised that there are many types of hazards that can be encountered in clandestine drug labs that are not commonly seen in other hazmat environments. Examples of such hazards include encounters with armed criminals, discovery of anti-personnel devices such as fragmentation bombs, grenades, booby-traps (explosive devices, secondary incendiary devices, hidden electrical triggers, refrigerator bombs, trip wires), razors, needles, and biological hazards. Other hazards commonly encountered are broken glassware and drug-use paraphernalia such as syringes or glass pipes and cookware. There have even been reports of poisonous spiders and snakes running loose in abandoned drug labs.! Readers are advised to consider these types of hazards when conducting preliminary assessments and to remember that unlike other environmental work, clandestine drug lab assessment and cleanup involves some form of criminal element.
The physical assessment of the property is one of the most important aspects of developing a Ppreliminary aAssessment. Site observations can be valuable in determining cooking areas, waste-disposal areas, and other areas of chemical contamination. Stains on floors or carpeting, burn marks on walls and floors, and evidence of chemical dumping in sinks and floor drains can assist in determining manufacturing methods. Garages, attics, outbuildings, crawlspaces, and even hidden rooms, should be inspected as these functional spaces are often the locations of methamphetaminemeth production, storage, use, or distribution. The presence of other chemicals or waste containers within or on the grounds of a property can also provide insight into the extent of contamination.
A physical assessment must include an evaluation of the exterior grounds of a property. Waste chemicals are often dumped by the cooks outside of a structure and can often contaminate soils, groundwater, or septic systems. Evidence of such dumping could include multi-colored liquids, powders, or residues on soils and waste or product (e.g. paint thinner, etc.) containers used in meth manufacturing disposed of on the property. Dead vegetation in isolated areas can be another sign of waste dumping on a property.
When present, Individual Sewage Disposal Systems, (ISDS or septic system) may also need to be evaluated depending on interior evidence of dumping in sinks, toilets, and bathtubs of properties with septic tanks. As can be imagined, dumpingtanks. Dumping a mixture of incompatible chemicals into a septic system can present explosion hazards, as well significant vadose zone migration problemsreal hazards and problems.
A site drawing or layout and photo observation log should be completed as part of the Ppreliminary aAssessment. Photographs should be taken in all affected functional spaces or affected exterior grounds. It is advisable to consider taking field photographs prior to cleanup in the same locations that they will be taken after cleanup to clearly illustrate field conditions before and after remediation. Video recording a property is also a common strategy to illustrate before-cleanup and after-cleanup property conditions.
Information collected during the preliminary assessment should include, but not be limited to, the following:
• Property description including physical address, legal description, number and type of structures present, description of adjacent and/or surrounding properties, and any other observations made.
• Review of available law enforcement reports that provide information regarding the processing method, chemicals present, cooking areas, chemical storage areas, and observed areas of contamination or waste disposal.
• Identification of structural features that may indicate separate functional spaces, such as attics, false ceilings and crawl spaces, basements, closets, and cabinets.
• Identification of manufacturing and processing methods presumed or suspected based on observations and law enforcement reports.
• Identification of chemicals used, based on observations, law enforcement reports, and knowledge of manufacturing method(s).
• Identification and documentation of areas of contamination. This identification may be based on visual observation, law enforcement reports, proximity to chemical storage areas, waste disposal areas, or cooking or processing areas, or based on professional judgment of the consultant; or the consultant may determine that assessment sampling is necessary to verify the presence or absence of contamination.
• Identification and documentation of chemical storage areas.
• Identification and documentation of waste disposal areas.
• Identification and documentation of cooking or other processing areas.
• Identification and documentation of controlled substance usage areas.
• Identification and documentation of signs of contamination such as staining, etching, fire damage, or outdoor areas of dead vegetation.
• Inspection of plumbing system integrity and identification and documentation of potential disposal into the sanitary sewer or an individual sewage disposal system (ISDS). If it is determined that field screening and/or sampling is necessary to determine if lab wastes have been discarded into an ISDS, the field screening and/or sampling should be conducted in accordance with sampling protocols consistent with statutory requirements and those appropriate for determining corrosivity, reactivity, and hazardous waste characteristics of the sludge/liquid in the system.
• Identification of adjacent units and common areas where contamination may have spread or been tracked.
• Identification and documentation of ventilation systems including common ventilation with adjacent units or common areas.
• Photographic documentation of property conditions, including cooking areas, chemical storage areas, waste disposal areas, and areas of obvious contamination.
7 Sampling for Methamphetamine Residue
Sampling for methamphetaminemeth residue is normally part of the preliminary assessment, unless the contents and building component and surfaces are presumed to be contaminated. Wipe sampling of interior surfaces should be conducted using conventional wipe sampling methods for assessing surface contamination. As has been stated previously, some states have enacted legislation or regulatory requirements for assessment and cleanup of clandestine methamphetaminemeth laboratorieslabs, including the procedures for collection and analysis of wipe samples.
Sampling Theory
Selecting the appropriate sampling strategy for clandestine drug labs is a difficult and often tricky process, considering the inherent legal implications regarding future occupancy and property transfer. This document prescribes a scientific approach in conducting the sampling portion of the preliminary assessment. The type of sampling used for stationary structures and vehicles described in this guidance document is a type of sampling recognized as authoritative sampling. Authoritative sampling is a non-statistical sampling design that does not assign an equal probability of being sampled to all portions of the structurepopulation. Individuals using this protocol should have a priori knowledge of the property to be assessed, the manufacturing process used, and possibly even the drug consumption method used (e.g. injection, smoking, etc.). The a priori knowledge, in the hands of a competent professional, permits immediate inclusion/exclusion of sampling areas, based on professional judgment. As such, the weight of validity of the data gathered with authoritative sampling is largely dependent on the knowledge and competency of the individual performing sampling.
There are two methods of authoritative sampling that will be discussed in this document:
• Judgmental Sampling – The goal of judgmental sampling is to use process and site knowledge to choose one or more sampling locations to represent the highest contaminant concentration within the context of the sampling area. Judgmental sampling designs can be extremely useful and cost-effective if the individual choosing the sampling locations has sufficient knowledge of the history of the laboratory under study. It is recognized that this sampling method is not entirely objective since the individual choosing the sampling locations could possibly intentionally or unintentionally distort the sampling by a prejudiced selection, or if their knowledge in the laboratory in question is inadequate. In those cases, judgmental sampling can lead to incorrect results being presented.
• Biased Sampling – Biased sampling is the type of authoritative sampling that intends not to estimate average concentrations or typical properties, but to estimate “worst” or “best” cases. As described in the post-assessment process contained in this document, the aim of the person performing post-decontamination sampling is to demonstrate the worst case scenario in the clandestine laboratory. The term “biased,” as used here, refers to the collection of samples with expected high concentrations. For example, a sample taken at the source of the actual “cook,” known release, process area, use area, spill or storage area could serve as an estimate of the “worst-case” concentration found in that functional space. This information would be useful in identifying the contaminant and estimating the maximum level of contamination likely to be encountered during a cleanup. Biased sampling, while having the ability to cost-effectively generate information, has similar philosophical disadvantages to that of judgmental sampling.
Hypothesis Testing
The foundation for the usefulness of any sampling protocol rests upon the establishment of appropriate data quality objectives (DQO)s. The DQOs are, in turn, driven by a thought process that proceeds from defining the problem, then quantifying the degree of the problem, defining what decisions are to be made based on the resulting data, and the degree of quality needed to ensure that the decision goals can be met. All sampling has error and all analysis has error. No realistic sampling and analysis protocol has a 100% guarantee of definitively characterizing any area or condition. Therefore, a realistic sampling and analysis protocol is one that minimizes error, and optimizes cost effectiveness, while increasing the probability that the DQOs will be met.
The sampling protocol presented herein begins with the end in mind and is based on asking specific questions, and conducting sampling and analysis to answer those questions. The protocol suggested is not intended to be a substitute for professional judgment, but must be utilized by cognizant professionals in the application of their professional skills. This guidance is also not a comprehensive recipe for success that if followed, complete characterization is guaranteed. The evaluation of any specific area must be based on the totality of the circumstances specific to that property.
This sampling guidance will describe two distinct sets of DQOs; one for the preliminary (pre-decontamination sampling) and one for the post-decontamination sampling. The essential difference between the two lies in the hypotheses that are being tested.
• Pre-decontamination sampling – In preliminary assessment sampling, the question being asked: “Is there evidence of the presence of controlled substances in this area?” The assumption (hypothesis) is that the area is clean i.e. “compliant,” and data will be collected to find support for the hypothesis. Samples are collected to “prove” the area is compliant. Sampling, when performed, is conducted in the areas potentially containing the highest possible concentrations of contaminants. Any data that disproves the hypothesis, including police records, visual clues of production, storage, or use or documentation of drug paraphernalia being present, should be considered conclusive, leading to a resultant acceptance that the area is non-compliant with respect to contamination levels. The strength of evidence needed to reject the hypothesis is low, and is only that which would lead a reasonable person, trained in aspects of clandestine laboratorieslabs, to conclude the presence of controlled substances, its precursors as related to processing, or waste products.
• [General comment – this section should be moved and combined with the post decontamination sampling that occurs further in the document] Post Decontamination sampling – In post decontamination assessments, the question being asked is: “Does this area contain contaminants in excess of the decision threshold?” The hypothesis is that the area is non-compliant, and samples are collected to test the hypothesis. In theory, the ability to prove the hypothesis necessarily becomes more difficult as the area becomes cleaner; and virtually impossible to prove in an area that is completely devoid of contamination. The lack of data supporting the hypothesis leads to the conclusion that the area is compliant with respect to contamination. Therefore, the role of post decontamination sampling is not to demonstrate that the area is “clean,” but rather to diligently attempt to prove that the area is not clean through biased sampling.
• Decision Statement: If, based on the totality of the circumstances, the individual performing the assessment finds that insufficient evidence exists to support the hypothesis that any given area is non-compliant, that area shall should be deemed to be “compliant,” and shall should be released. If objective sampling data collected indicates contamination is less than the cleanup level, that data may be used as prima facie evidence meaning that insufficient evidence exists to support the hypothesis that any given area is non-compliant.
Wipe Sampling Procedures
Wipe sampling for methamphetaminemeth residue should be conducted using conventional methods for determining surface contamination concentrations. Some states have adopted enforceable regulations for clandestine drug lab evaluations, including required sampling methods. As of the date of this publication, standards for assessing surface methamphetaminemeth contamination or the presence of other chemical contamination are being considered or developed by several technical entities, including the Occupational Safety and Health Administration (OSHA), the National Institute for Occupational Safety and Health (NIOSH)[27], and the American Society for Testing and Materials (ASTM).
Presented below is a brief description of the recommended sampling protocol(s) for assessing contamination at a property:
Non-Porous Surfaces
Wipe Samples: Wipe sampling should be used to determine the extent of contamination on non-porous surfaces using either discrete (individual) or composite sampling methods.
Sample media may consist of one of the following, although the reader is advised to examine local regulations prior to performing sampling:
• Gauze material, including Johnson & Johnson cotton squares or equivalent, or
• Filter paper, including Whatman 40, 41, 42, 43, 44, 540, 541, Ahlstrom 54, VWR 454, S&S WH Medium, or other filter paper with equivalent performance.
• Pharmaceutical grade, (USP or greater) isopropyl alcohol or methanolUSP (or greater) methanol.
The following procedure is recommended for collecting individual or “discrete” wipe samples from non-porous surfaces:
1. Prepare a rough sketch of the area(s) to be sampled.
2. Attach disposable templates or masking tape to the area(s), or otherwise delineate the boundaries of the surface to be sampled, being careful not the touch the area within the template. The sample area selected shall should not be less than 100 cm2, unless otherwise required by the consultant’s a priori DQOs.
3. The sample media should be wetted with solvent (isopropyl alcohol or methanol) to enhance collection efficiency.
4. Use a new set of clean, non-powdered impervious gloves for each sample study area to avoid contamination of the sample media by previous samples and to prevent contact with the substance.
5. Press the sample media down firmly, but not excessively, with the fingers, being careful not to touch the sample surface with the thumb. Blot rough surfaces uniformly instead of wiping. Wipe smooth surfaces as described below.
6. Wiping may be done by one of the following methods:
a. Square method: Start at the outside edge and progress toward the center of the surface area by wiping in concentric squares of decreasing size.
b. “S” method: Wipe horizontally from side-to-side in an overlapping “S”-like pattern as necessary to completely cover the entire wipe area.
7. Without allowing the sample media to come into contact with any other surface, fold the sample media with the sampled side in.
8. Use the same sample media to repeat the sampling of the same area. If using the “S” method, the second pass should be sampled by wiping with overlapping “S”-like motions in a top-to-bottom direction.
9. Fold the sample media over again so that the sampled side is folded in. Place the sample media in a sample container, cap and number the container, and note the number at the sample location on the sketch. Include notes with the sketch giving any further description of the sample.
10. At least one sample media blank, treated in the same fashion but without wiping, should be submitted for every 10 samples collected.
When collecting composite samples, the procedure outlined above shall should be used with the following exceptions:
1. A single pair of gloves may be used to collect all component samples that will be part of a composite sample.
2. All component samples that make up a composite sample must be placed in one sample container.
Composite samples of personal items may be collected for analysis to determine their ultimate disposition. It is recommended here that composite sampling be conducted on personal effects and belongings in the following manner. Composite samples of personal belongings should be collected from items constructed of like materials that are contained within the same individual functional space (e.g., clothing from a bedroom closet may be sampled as a composite, fabric furniture within a living room may be sampled as a composite, draperies within an individual room may be sampled as a composite, non-porous goods such as wood or metal tables, shelves, cabinets, etc. in the same room may be sampled as a composite, etc.). A composite sample is considered representative of contaminant levels on all personal property of that type material within the same functional space. No more than 5 individual items should be included in any one composite sample. Should analysis of composite samples from multiple items indicate contaminant levels in excess of the cleanup level, all items comprising the composite sample should be considered to be in excess of cleanup levels.
Non-Porous Surfaces
Vacuum Sampling
Vacuum sampling may be used to determine the extent of contamination on porous surfaces, such as carpeting, drapery, upholstery, clothing, and other soft goods. Vacuum samples should shall be collected using standard “microvacuum” techniques that employ the use of battery-operated sampling pumps and appropriate collection media. Investigators Samplers are advised to consult with the chosen analytical laboratory to ensure that media used complies with laboratory analytical methods. Microvacuum samples should be collected in accordance with standard and customary practices for such as recommended by NIOSH, ASTM, or other recognized agency standard
Outdoor Environments
For laboratorieslabs with outdoor components, or laboratorieslabs which are exclusively outdoors, sampling may be necessary to assess the potential for soil contamination. Soil sampling should be conducted at the discretion of the individual conducting the assessment, including sampling depth and volume considerations. Individuals performing sampling should employ existing, industry-accepted soil sampling processes for determining chemical contamination in soils. Investigators Samplers are advised to consult with the chosen analytical laboratory to determine soil sample collection protocols with respect to laboratory analytical methods.
Individual Sewage Disposal Systems (ISDS)
The presence of an ISDS on a property being evaluated can present challenges. The types and quantities of chemicals or waste products that may have been dumped in the system are usually unknown and can create a toxic or explosive mixture inside an ISDS.
The most common types of drug lab wastes that might be expected in an ISDS include:
• Organic, aromatic, nonpolar solvents such as acetone, constituents of nail polish remover, toluene, xylenes, paint thinner, white gas, etc.
• Polar organic solvents such as acetone, ethanol and methanol
• Corrosives (e.g., sulfuric acid, muriatic acid, sodium hydroxide solutions)
• Mixtures with residual ephedrine, methamphetaminemeth, iodine or red phosphorus
• Reactive metals (lithium, sodium, potassium)
• Heavy metals (particularly lead and mercury)
Field screening and sample collection should be conducted to confirm or deny the presence of controlled substance waste, solvents, etc., and to ensure proper disposal of any wastes identified.
Field screening of septic tanks should be conducted if there is evidence that drug lab wastes may have been discarded into an ISDS. Evidence of drug lab waste disposal into an ISDS includes, but is not limited to, the following:
• Witness statements;
• Stained or etched sinks, bathtubs, toilets;
• Chemical odors coming from the ISDS plumbing or tank;
• Visual observations of unusual conditions within the septic tank (“dead tank”); or, stressed or dead vegetation in a leach field.
Initial field screening should consist of the following:
• Monitoring the septic tank for volatile organic compounds (VOCs) using a photoionization detector (PID), flame ionization detector (FID), semiconductor detector or similar type of real-time monitoring instrument for measuring VOCs.
• Testing the pH of liquid in the septic tank.
Additional field screening may be conducted at the discretion of the individual conducting the assessment to further investigate the possible presence of drug lab waste.
Sample Collection
If field screening indicates that the ISDS has been impacted by drug lab wastes, samples shall should be collected from the septic tank to determine if the liquids in the tank contain a hazardous waste. Manufacturer’s instructions for the correct usage of sampling equipment should be followed. Samples should be collected according to the requirements of the analytical method being used and the following protocol:
1. Prior to sampling, the number of chambers in the septic tank should be determined.
2. Samples from single chamber tanks should be collected from the baffle on the outlet end of the tank.
3. Samples from multi-chambered tanks should be collected from the baffle on the outlet end of chamber one.
4. Samples should be representative of the wastes found in the septic tank. Sampling procedures may include the use of drum thieves, sludge judges or equivalent equipment.
5. Remove access cover from the first (or only) chamber and locate outlet baffle.
6. Move any floating surface matter away from the insertion point of the sampling device. Do not collect any floating matter in the sampling device.
7. Insert the sampling device into the tank, lowering it until it hits the bottom.
8. Trap the sample inside the sampling device.
9. Remove the sampling device and fill the laboratory supplied sample containers. The specific volume and type of sample container will be determined based on the type of analysis desired, as well as the types of preservatives (if any) in the sample jars and the recommended storage and transport temperature.
10. Replace access cover at the completion of sample collection.
11. A Chain of Custody Record should be maintained from the time of sample collection until final disposition. Samples should be sealed, labeled, and secured.
12. All sample documents should be retained for the project record.
Analytical methods for the liquid/sludge samples to be submitted will depend upon the type(s) of contamination observed or expected. General analytical methods for ISDS components may include:
• VOCs using EPA Method 8260B
• Ignitability/flash point by any of the following methods: Method 1010 Pensky-Martens Closed Cup Tester, Setaflash Closed Cup Tester etc.
• Corrosivity by EPA Method 9040 or EPA Method 1110
• Reactivity by EPA Method 9014/9034
8 Sampling for Other Chemical Contamination
Sampling for other types of contamination may be required, depending upon the scope of cleanup. Generally speaking, sampling for chemical contamination other than that of methamphetaminemeth means surface sampling for known hazardous ingredients of methamphetaminemeth manufacture, such as leadlithium (Birch Rreduction method), iodine (red phosphorous method), or other characteristic contamination. Often, sampling for these types of contamination is not performed, as surfaces with indicative staining are typically completely removed and discardeddisposed of. When conducting sampling for chemical contamination, one should use industry-accepted, recognized sampling methods such as NIOSH methods, OSHA Methods, and EPA Methods, etc.
8.1.7 Clandestine Drug Laboratory Mimics
Often, industrial hygienists will be asked to respond to a meth lab only to find the site is actually a suicide lab, bomb lab, bioterrorism lab, hydroponics operation, wine or beer making or other type of situation closely resembling a clandestine drug operation. A detailed investigation by a knowledgeable team can quickly discern the nature of the site.
In general, each of the above mimics tend to be better organized, and generally devoid of the profound squalor associated with clandestine drug labs. Suicide labs are very often labeled by the victim.
If an industrial hygienist determines the site is not a clandestine drug lab, and is not a suicide lab, and has ruled out innocent operations such as home made wineries or breweries, the industrial hygienist should consider the possibility of a bioterrorism lab and/or and bomb lab. If bomb labs or bio labs are suspected, very specialized training is needed even for cursory assessments. The industrial hygienist should retreat from the site and immediate contact the FBI/BATF as well as local law enforcement with jurisdiction before proceeding further.
[General comments This section is out of place –the current topic is assessments and the document returns to assessments later]Remedial Recommendations
Remedial activities at clandestine drug labs are borne out of the preliminary assessment process. The industrial hygienist, or other professional performing the Ppreliminary Aassessment, typically generates a scope of work for remediation or “remedial work-plan” designed to accomplished the goals of decontamination of the property. Remedial companies use the scope of work document to conduct and complete decontamination. Remedial recommendations will depend on a number of factors discovered in the pPreliminary Aassessment, such as manufacturing methods, extent of contamination, contents within the property, and local regulatory requirements.
Site Type and Characteristics
The site of the lab, its structural characteristics, and potential future, use must be considered when designing a remediation plan. Lab sites may be loosely categorized as follows:
• Private occupancy structure – e.g., single family home, apartment or multiple dwelling
• Licensed facility (residential or non-residential) – e.g., hotel, motel, manufactured home park, restaurant, grocery store, child or adult foster care facilities, public storage unit, etc.
• Non-occupancy structure – e.g., garage (attached or unattached), barn, pole barn, tool
shed, etc.
• Mobile residence – e.g., motor home, camper or manufactured home
• Other vehicle – e.g., van, bus, automobile, truck, boat, etc.
• Other lab sites that do not fall into any of the previous categories, e.g., tent, campsite, highway rest area, etc.
When evaluatingon multi-tenant properties, such as apartment buildings, townhome/condominium complexes, or public motel/hotel structures, it is extremely important to considerevaluate the potential for fugitive migration of extent of contamination into adjacent spaces. This may include evaluation and sampling of common ventilation systems, hallways, inner wall spaces, common attics and crawlspaces, or other form of shared-air space. Contamination of these spaces may have resulted from common ventilation or simply tracking of residual contamination into shared spaces.
Contents of a Property
One aspect of particular difficulty in developing remedial recommendations for remediation of a former drug lab is the final disposition of personal contents and belongings on the property. Contents including clothes, toys, furniture, appliances, electronics, toys, books, personal records, heirlooms, etc., are considered contaminated once it is confirmed that remediation is required for that space containing those items. Porous items such as clothes, carpeting, and bedding can often be readily decontaminated; porous furniture, beddingmattresses, etc. must often be discarded. Foodstuffs, including canned goods and contents within refrigerators, are typically discarded. As it is extremely difficult to perform sampling and remediation within the motors and circuitry of appliances and electronics, these items are typically discarded as waste. Large appliances such as refrigerators, washing machines, are easily decontaminated, and confirmation sampling is easily performed. Non-porous items, for example wood furniture, cooking ware and silverware, can be sufficiently cleaned through conventional cleaning methods, although wipe sampling of these items for compliance is usually required prior to release. When evaluating decisions regarding alternatives to disposal, it is important to consider the value of the item and the potential for future human contact.
The following table(2) is provided for consideration when making decisions regarding disposition of personal belongings within a meth lab property. [General Comment – if the following has been excerpted verbatim from source, that should be made clear from the outset and the section should be moved to an appendix. As it is, the reader is left confused as to the context and the lack of continuity. Further, the reader does not have any indications when the block quote ends.]
[General Comment – Where is Table 1?] Table 21. Value and Contact Potential Evaluations:
High Value – High Contact Items
Mattresses, carpeting, large upholstered
items should almost always be discarded.
(See exceptions in text.)
High Value – Low Contact Items
In some circumstances, photographs may be
salvaged without cleaning, or large appliances may
be cleaned and saved.
Low Value – High Contact Items
Clothing, plastic toys and toothbrush
should always be discarded.
(See exceptions in text.)
Low Value – Low Contact Items
A screwdriver, garden rake or other metal or
hard material item may be cleaned in some
circumstances.
(Source: Reference 2)
Some Conditions That May Affect Remedial Work Plan Decisions (based on information found in Reference 2)(2) [General comment – this will obviously need to be corrected when the references are finalized]
• Site History – Indications of severity of contamination, e.g., length of occupancy; real (chemicals or equipment) or anecdotal evidence (such as odors twice-weekly) gathered by law enforcement or provided by property owner, neighbors or occupants.
• Site Use and Occupancy – Potential human (particularly child) exposure, e.g., site is a single-family home, hotel/motel, chicken coop, attached garage.
• Sampling Intentions/Evidence – Location and number of samples taken or to be taken will affect ability to plan a modified remediation.
• Proximity to Cooking or Storage Areas – Degree of apparent contamination, as indicated by police evidence, chemical staining, signs of fire or explosion, etc.
Household contents and guidance for their disposition are listed below. The list is not exhaustive. Recommendations for household contents are divided into three categories.(2)
• Always Discard
• Disposal Recommended
• Disposal Strongly Recommended
Table 23. Considerations for Content Disposition
Infants’ and Small Children’s Clothes, Toys and Personal Items:
Always Discard.
Exceptions: Metal or other hard medical devices such as glasses or orthopedic devices
that can be cleaned may be exempted at the discretion of the local authority and in
consultation with the contractor regarding remediation options.(2)
Other Fabric Goods:
Fabric Goods: Washable
Disposal Strongly Recommended.
Exceptions: With approval of the local authority and with reasonable assurance
that the work will be done, adult clothing and small washable fabric items such as
curtains, rugs and linens can be machine-washed twice with hot water and
detergent. After washing contaminated items, the washer should be run empty of
clothing.
Fabric Goods: Non-Washable, Such as Woolens, Rubber-Backed Draperies
Always Discard.(2)
Mattresses
Disposal Strongly Recommended.
Exceptions: When pre-remediation samples show low levels of
meth in the structure, a mattress that is far removed from the area of cooking can be
sampled to avoid disposal. The local authority may have to approve this action.(2)
Carpeting
Always Discard(2).
[General Comment – we have cleared several properties wherein the carpeting has been easily salvaged. If this is to remain, then the entire section should be explicitly stated that this is the requirements for the State of Minnesota]
Kitchen Goods:
Dishes, Flatware, Other Hard Items, Including Glazed Ceramics, Metals and Glass
Disposal Recommended.
Exceptions: With approval of the local authority and with reasonable assurance
that the work will be done, hard (non-porous) household items such as glazed
ceramics, metals and glass may be twice-washed rinsed using detergent and hot
water. Any item that shows evidence of use for meth cooking (e.g. acid etching,
chemical staining) must be discarded.
Small Wooden, All Plastic Kitchen and Household Items
Always Discard.(2).
Furniture:
Large Wooden and other Hard Furniture Items, Including Metal, Glass and Aluminum
Disposal Recommended.
Exceptions: Attempts can be made to wash large, hard furniture items (e.g., nonplastic,
wooden, chrome or aluminum). These items should be thoroughly decontaminated using conventional methods. After cleaning, wipe samples may be required by local authorities or by the remedial workplan itself.
Leather or Fabric Upholstered Furniture
Disposal Strongly Recommended.
Exceptions: Irreplaceable or very high-value items may be stripped of padding and
upholstery and cleaned as hard furniture. After cleaning, wipe sample with methanol
surfaces that will be touched, such as a dresser drawer face or chair seat.
Plastic Furniture and Large Plastic Goods
Always Discard.(2)
Books and Household Paper Items:
Always Discard.
Exceptions: Important legal papers, historical items or personal photographs may be
exempted at the discretion of the local authority and in consultation with the contractor.(2)
Appliances, Tools, and Electronics:
Disposal Recommended.
Exceptions: At the discretion of the local authority, high-value, low-contact appliances,
tools and electronics can be washed twice with a hot detergent solution and clean rinse
water, or cleaned by alcohol wiping with adequate ventilation. Stained items must be
discarded.(2)
(Source: Reference 2)
Structural Considerations
The architectural design, building materials, utilities, and layout of a structure are important when considering cleanup strategies. A building material feature may determine the proper course of remedial action. The porosity of a building material or structural feature plays an important part in considering whether the material may be cleaned or must be discarded. Generally speaking, non-porous painted or coated surfaces, such as drywall, plaster, cement, vinyl or ceramic flooring, or wood surfaces, can be sufficiently cleaned to meet most clearance standards. In some cases, these materials are so severely stained or damaged from the drug production process that they must be discarded. Porous and semi-porous building materials, such as unpainted drywall, ceiling tiles, or wallpaper, is difficult to clean and complete removal may be prudentis usually recommended. The following list of materials and common remedial strategies are provided for guidance purposes. It is important to evaluate each property and the building materials that comprise it when considering and choosing cleanup versus disposal strategies.
• Lay-in ceiling tiles, corkboard, etc. – should be packaged and removed from the property for disposal
• Walls, floors, and ceilings – depending upon the type of wall (e.g. gypsum drywall, plaster, etc.) and the severity of staining, these materials can be either cleaned in place or removed and packaged for disposal. Surfaces with visible staining should be removed from the property and packaged for disposal. Painted and unpainted cement and cinder block walls and brick or stucco surfaces can often be cleaned by power wash or chemical extraction methods, although the porosity of the material will determine the feasibility and extent of decontamination necessary. Financial considerations may also be weighed because removal and replacement of material can sometimes cost less than decontamination and surface sampling. (The reader is advised to consider that many common building materials, including acoustical ceiling texture, decorative wall texture, drywall mud, flooring, etc. may contain asbestos. When considering removal of these building materials, it is strongly recommended that the asbestos content of these materials is determined prior to removal. Additional requirements for asbestos removal will be required prior to removal of these materials. Consult with state regulators regarding asbestos identification and removal requirements prior to recommending these actions.)
• Kitchen counters, kitchen tables, food preparation surfaces – It is recommended that food preparation and consumption areas be packaged and removed from the property for disposal. In mostsome cases, non-porous surfaces, such as ceramic, porcelain, or marble counters can be cleaned and wipe-sampled for re-use purposes.
• Non-porous smooth finishes, such as sinks and bathtubs, can be effectively decontaminated by conventional hazardous materials cleaning methods, although these tubs and sinks may need to be removed if they show signs of chemical staining, corrosion, or etching.
• Plumbing and sanitary sewer system – Sinks, bathtubs and toilets are frequently used for the disposal and dumping of lab chemicals. When corrosive or flammable chemicals have been dumped into a plumbing system, plumbing may contain concentrated chemicals in the traps of sinks and other drains. Visibly contaminated, stained or etched plumbing traps, be they metal or plastic/PVC, and drain systems should be discarded. Undamaged porcelain and stainless steel sinks and drainage plumbing can otherwise be successfully cleaned. Cleaning of plumbing systems involves flushing the system with appropriate amounts of clean, warm water. The local wastewater management municipality or operator should be notified and consulted when planning on flushing wastewater drains from a contaminated property.
• Heating, Ventilation, and Cooling (HVAC) System – For properties heated with gas-force air, complete cleaning of the entire HVAC system, including the furnace, interior ductwork has been shown to be extremely difficult. Contactors in states with tight clearance levels are reluctant to attempt to clean ventilation systems, and usually will not guarantee successful clearance., Decontamination of diffusers, and vent covers, is readily achievedrecommended. In cases of severe contamination or long-term meth production, it may be necessary to completely remove the furnace and associated ductwork and discard. Cleaning of an HVAC system requires a complete and thorough cleaning of the entire system and should include the following:
o Remove and clean, or replace all vent and diffuser covers (consider cost efficiency).
o Remove and package for disposal all filters in the system.
o Completely remove any porous or non-metal ductwork.
o Thoroughly clean the interior of the furnace.
o Thoroughly clean the interior of the ductwork. This will typically require the use of industrial-type vacuum systems or employment of a professional duct cleaning service company. Any companies or personnel conducting HVAC system cleanup must be informed and advised of the nature of the work and the potential hazards involved. Today, many of these professional cleaning companies employ trained personnel and have equipment dedicated for use in clandestine drug lab cleanup.
o Thoroughly clean all supply diffusers and return air plenums or ductwork and the exterior of all ductwork in the structure.
▪ Garages, sheds, and outbuildings – In planning remediation of contamination in non-occupancy structures, consideration should be given to the structure’s use, to potential for human exposure, and to the level of contamination within that structure. For example, a contaminated child’s play house (or a structure used as a child’s play house) should be treated the same as a room in a residential structure or demolished. Meth contamination in a storage shed or other structure not designed for occupancy may pose a lesser hazard to future occupants. The following should be considered when remediating non-occupancy type structures:
• Ventilation of structure before entry and cleaning.
• Evidence of stains and drug lab processproduction materials or waste.
• Discarding porous low value contents.
• In cases of dirt floors, remediation must be based on the preliminary assessment and it may be necessary to scrape and dispose of surficial soil.
• HEPA vacuum raw wood, cement, fiberglass or concrete block or power wash, ensuring to properly manage waste water.
• Contents within outbuildings vary in degree of human contact and the efficiency and economics of decontamination. If a child is not exposed to the item, or if the item is made of metal or other non-porous, hard materials, the item may be able to be cleaned. If the structure is of “low value” demolition may be considered.
• Encapsulation – Encapsulation or “sealing” of appropriate decontaminated surfaces is recommended after decontamination and after achievement of final clearance sampling criteriastandards have been met.. Surfaces appropriate for encapsulation are wood subflooring, interior walls and ceilings (drywall, plaster, etc.) and framing materials. should demolition of interior walls, floors, and ceilings be performed. Other surfaces include framing in attics, crawl spaces, and garages and any outbuilding such as sheds, barns, storage structures, etc. It is recommended that water-based encapsulants, such as latex paints and commercially available aqueous sealants (such as those commonly used in asbestos abatement), be used for safety considerations as chemically-stained or -–etched surfaces are usually removed instead of decontaminated.
It is important to note that local regulations may dictate encapsulation requirements, including prior to or after final clearance standards have been met, types of encapsulants to be used, appropriate materials for encapsulation, etc. Readers of this document are advised to review local regulations with regards to encapsulation requirements pertaining to cleanup of former methamphetaminemeth laboratorieslabs.
Post-Cleanup Assessment
A post-cleanup assessment should be conducted after all remedial activities have been completed. The post-cleanup assessment should include a physical assessment of the property, similar to the assessment conducted during the preliminary assessment, and wipe sampling for methamphetaminemeth and/or other chemical contamination to ensure that remedial goals have been met. In many cases, the post-remedial assessment is not conducted by the same individual or firm that conducted the preliminary assessment. The post-cleanup assessment should include the following, some of which may be obtained or extracted from a preliminary assessment:
• Preliminary assessment date, including the assessor’s description of methamphetaminemeth manufacturing methods, sampling results, extent of contamination, etc.
• Property dDescription including physical address, number and type of structures present, description of adjacent and/or surrounding properties, and other relevant observations.
• Discussions and interviews with the Ccustomer.
• Review of available law enforcement reports that provide information regarding the manufacturing method, chemicals present, cooking areas, chemical storage areas, and observed areas of contamination or waste disposal.
• A description of chemical storage areas
• A description of waste disposal areas
• A description of cooking areas
• A description of areas with signs of contamination such as staining, etching, fire damage, or outdoor areas of dead vegetation
• Results of inspection of plumbing system integrity and identification of sewage disposal system.
• Identification of adjacent units and common areas where contamination may have spread or been tracked
• Identification of common ventilation systems with adjacent units or common areas
• A description of sampling methods used, including sample collection, handling, and QA/QC
• A description of the analytical methods used and laboratory QA/QC methods.
• A description of the location and results of initial sampling, including a description of sample locations and a figure with sample locations and identification
• A description of health and safety procedures used in accordance with OSHA requirements
• A description of decontamination procedures used and a description of each area that was decontaminated
• A description of the removal procedures used and a description of areas where removal was conducted, and the materials removed
• A description of any encapsulation procedures used and a description of areas where encapsulation was conducted
• A description of the location and results of post-decontamination samples, including a description of sample locations and a figure with sample locations and identification
• Photographic documentation of the property conditions after cleanup.
4 Physical Assessment
The physical assessment of a post-remedial evaluation includes many of the elements contained in the preliminary assessment in addition to an evaluation of the success and completeness of remediation. Physical observations should include consideration of all of the elements and remedial recommendations contained in the preliminary assessment. It may be helpful to develop a checklist of completed remedial activities specific to each Site based on preliminary assessment recommendations and information. Physical observations should include:
• An evaluation of the property grounds to ensure that exterior (outdoor) remedial goals have been met,
• An evaluation of the interior property to ensure that remedial recommendations and goals have been met, including but not limited to:
o Visual observations to ensure that interior personal belongings and contents have been properly cleaned or removed, including an evaluation of ISDS
o Removal or decontamination of porous items, such as personal belongings, carpets, drapery, upholstered items, etc.
o Removal of affected food preparation surfaces
o Decontamination or removal of interior floor, wall, and ceiling surfaces, including affected attics, crawlspaces, garages, and outbuildings
o Decontamination or removal of HVAC system, including the furnace, filters, ductwork, diffusers, and grills
o Decontamination or disposal of affected plumbing systems components, including sinks, toilets, bathtubs, showers, ISDS, and associate traps
o Evaluation of adjacent properties or common areas, in the case of townhomes, condominiums, apartments, motels, public storage units, etc.
5 Post-remedial Sampling for Methamphetamine Residue
Surface sampling for methamphetaminemeth residue should be conducted to determine post-cleanup surface contamination levels in each functional space. Methamphetamine residue sampling is one of the most important parts of a post-remedial evaluation, as meth residue cannot be seen and areas of visible contamination from other sources (e.g. solvent, acid, corrosive spills, etc.) are typically entirely removed from the structure.
9. Challenges and Pitfalls [General comments – this section is largely redundant and these issues have already be presented elsewhere in the document]
There are many challenges presented to health and safety professionals in hazard evaluation, recognition, and remediation of clandestine methamphetaminemeth laboratorieslabs. and as has been discussed, tThese challenges facing regulators and health and safety personnel are constantly seem to be ever-changing. There are many different methods of methamphetamine manufacturing, some of which are known and some of which are evolving. It is without question that even aAs this document was being published, new methods for processing of methamphetaminemeth “cooking” operations were being tested are being and developed by the criminal world“meth cooks.”. Each method for processing of methamphetaminemeth manufacturing can present hazards unique to that method with respect to the equipment, chemicals used, byproducts, produced, and waste streams produced. Users of this document are advised to remain current with respect to the laws, regulations, and process methods of methamphetamine manufacture as the hazards presented can be a dynamic “moving target.”.
There are similar and parallel issues developing with respect to processing the manufacture of other illicit and illegal drugs, such as ecstasy and LSD, in a clandestine fashion. Users of this document are advised that hazards encountered and presented in other types of clandestine drug manufacturing operations can be very different than those discussed herein. Users are cautioned to conduct additional research should other forms of drugs manufacturing be of concern.
As of the date of publication of this document, there are no recognized federal laws with respect to identification, cleanup, and remediation of clandestine methamphetaminemeth laboratorieslabs. Many states, counties, and municipalities across the country have enacted legislation and/or regulations pertaining to various aspects of meth lab cleanup. State regulations differ from state-to-state and can address many different issues, from certification and qualification requirements for those involved in assessment and remediation of meth labs, to defining cleanup requirements and clearance criteria for re-occupancy. Users are advised to check with local health department officials for the most current requirements pertaining to clandestine meth labs prior to conducting any work involving meth labs.
10. Web-Based Resources for AIHA Members
American Industrial Hygiene Association
State Resources [General comments – I recommend these resources be arranged in some form of logical order- such as alphabetical order]
Indiana
(proposed regs: )
North Carolina Regulations
Tennessee
Website:
Cleanup rules:
Cleanup guidance:
Arkansas Cleanup Guidance:
Missouri Cleanup Guidance:
Iowa Cleanup Guidance:
Wisconsin Website:
Minnesota Website:
Cleanup Guidance:
Laws:
North Dakota Guidance:
South Dakota Guidance:
Kansas Guidance:
Oklahoma Guidance:
Colorado Regulations:
Montana Regulations:
Idaho State Website (no guidance, contaminated properties list):
Washington State Website with regulations and guidance:
Oregon laws:
Cleanup requirements:
Alaska Cleanup Guidance:
California State Website with links to laws, regulations and chemical information:
11. References [General comment, reference 27 is missing – also I have included several new references as foot notes that need to be included]
1. Colorado Department of Public Health and Environment (CDPHE): Regulations Pertaining to the Cleanup of Methamphetamine Laboratories, 6 CCR 1014-3, March, 2005.
2. State of Minnesota Department of Health Pollution Control Agency: Clandestine Drug Lab General Cleanup Guidance, July 1, 2006.
3. National Institute on Drug Abuse Fact Sheet revised 11/06,
4. Gibson, D.R., M.H. Leamon, and N. Flynn: Epidemiology and Public Health Consequences of Methamphetamine Use in California’s Central Valley. J. Psychoactive Drugs. 34(3):313 – 319 (2002).
5. Burgess, J.L., and C. Chandler: Clandestine Drug Laboratories. In: Greenburg, M.I. ed. Occupational, Industrial, and Environmental Toxicology, 2nd ed. Mosby, Inc. Philadelphia, PA 2003. Pp 746 – 765.
6. Centers for Disease Control and Prevention (CDC): 2000. MMWR. Public Health Consequences Among First Responders to Emergency Events Associated With Illicit Methamphetamine Laboratories – Selected States, 1996 – 1999. MMWR Weekly, 49(45):1021 –1024 (2000).
7. Washington State Department of Health: Methamphetamine Related Incidents Included in the Hazardous Substances Emergency Event Surveillance Database in Washington State, 2001. Washington Department of Health, Office of Environmental Health and Safety, Olympia, WA, July 2002. 8 pp.
8. Burgess, J.L., D.F. Kovalchick, E.M. Siegel, T.A. Hysong, and S.A. McCurdy: Medical Surveillance of Clandestine Drug Laboratory Investigators. J. Occup. Env. Med. 44(2):184–189 (2002).
9. Martyny, J.W., S.L. Arbuckle, C.S. McCammon, E.J. Esswein, N. Erb, and M. VanDyke: Chemical Concentrations and Contamination Associated with Clandestine Methamphetamine Laboratories. J. Chem. Health Safe. 14(4): (2007). [In press.]
10. American Conference of Governmental Industrial Hygienists (ACGIH): 200612 TLVs® and BEIs: Based on the Documentation of the Threshold Limit Values for Chemical Substances and Physical Agents & Biological Exposure Indices. Cincinnati, OH: ACGIH. 200612. 2368 pp.
11. Harger, P.N., and L.W. Spolyar: Toxicity of Phosphine with a Possible Fatality from this Poison. Arch. Ind. Health 18:497–504 (1958).
12. Burgess, J.L.: Phosphine Exposure from a Methamphetamine laboratory Investigation. Clin. Tox. 39(2):165–168 (2001).
13. Jones, A.T., R.C. Jones, E.O. Longley: Environmental and Clinical Aspects of Bulk Wheat Fumigation with Aluminum Phosphide. Am. Ind. Hyg. Assoc. J. 25: 375–379 (1964).
14. Burgess, J.L., S. Barnhart, and H. Checkoway: Investigating Clandestine Drug Laboratories: Adverse Medical Effects in Law Enforcement Personnel. Amer. J. Ind. Med. 30:488–494 (1996).
15. Salocks, C. and K.B. Kaley: Technical Support Document: Toxicity Clandestine Labs: Methamphetamine. Vol. 1, Number 2. Iodine. Cal/EPA. Office of Environmental Health Hazard Assessment. Sacramento, CA. 2003. 10 pp.
16. National Institute of Occupational Safety and Health (NIOSH): 2005. NIOSH Pocket Guide to Chemical Hazards. DHHS (NIOSH) Publication No. 2005-149. Centers for Disease Control and Prevention. National Institute for Occupational Safety and Health. Cincinnati, OH 424 pp.
17. Salocks, C. and K.B. Kaley: Technical Support Document: Toxicity Clandestine Labs: Methamphetamine. Vol. 1, Number 3. Hydrogen Chloride. Cal/EPA. Office of Environmental Health Hazard Assessment. Sacramento, CA. 2003. 10 pp.
18. Washington Department of Health: Review of Contamination Levels: Guidelines for Clandestine Drug Lab Cleanup. State of Washington, Department of Health. Olympia, WA. 2000. 6 pp.
19. Colorado Department of Public Health and Environment (CDPHE): Support for Selection of a Cleanup Level for Methamphetamine at Clandestine Drug Laboratories. Colorado Department of Public Health and Environment. Denver, CO. February, 2005. 31 pp.
20. Salocks, C. and K.B. Kaley: Technical Support Document: Toxicology, Clandestine Drug Labs: Methamphetamine. Vol. 1, Number 1. Ammonia. Office of Environmental Health Hazard Assessment. Department of Toxic Substances Control. Sacramento, CA. 2003. 11 pp.
21. Proctor, N.H., and J.P. Hughes: Chemical Hazards of the Workplace. Philadelphia, PA: J.B. Lippincott Co. 1978. 533 pp.
22. Occupational Safety and Health Administration (OSHA): U.S. Code of Federal Regulations 29 Part 1910, Subpart Z –Toxic and Hazardous Substances. Revised July, 1994.
23. American Industrial Hygiene Association (AIHA): Emergency Response Planning Guidelines and Workplace Environmental Exposure Level Handbook. Fairfax, VA: AIHA. 20011. 63 pp.
24. Witter, R.Z., J.W. Martyny, K. Mueller, B. Gottschall, and L.S. Newman: Symptoms Experienced by Law Enforcement Personnel In Association with Methamphetamine Lab Investigation, National Jewish Medical and Research Center. Submitted to the Journal of Occupational and Environmental Health. 2007. [Check on status of this with Sheila]
25. National Drug Intelligence Center: Information Bulletin. Children at Risk. Product # 2002-LO424-001. U.S. Department of Justice. Johnstown, PA. July 2002.
26. National Drug Intelligence Center: Information Bulletin. Methamphetamine Production Methods: A Guide for First Responders. Product No. 2003-L0490-001. U.S. Department of Justice. Johnstown, PA March, 2003. 11 pp.
Appendix A
Glossary of Terms and Acronyms
Appendix B
Standardized Field Forms
Clandestine Methamphetamine Laboratory
Assessment Field forms
|Project name: |Form # ML1 |
|Date: |
|Reporting IH: | |
Property Description:
|Physical address | |
|Legal description | |
|or VIN | |
|Registered Property Owner | |
|Number of structures | |
|Type of Structures | |
|(Each affected structure will need a | |
|“Functional Space” inventory) |Square feet |
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| |Square feet |
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| |Square feet |
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| |Square feet |
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| |Square feet |
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|Adjacent and/ | |
|or surrounding properties | |
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| | |
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| | |
|General Property Observations | |
|Presumed Production Method | |
Plumbing Inspection and Inventory
|Project name: |Form # ML2 |
|Date: |
|Reporting IH: | |
|Functional Space |Room |Fixture |Indicia? |Comments |
| |Bathroom # 1 |Bath | | |
| |Bathroom # 1 |Shower | | |
| |Bathroom # 1 |Sink 1 | | |
| |Bathroom # 1 |Sink 2 | | |
| |Bathroom # 1 |Toilet | | |
| |Bathroom # 2 |Shower/Bath | | |
| |Bathroom # 2 |Sink | | |
| |Bathroom # 2 |Toilet | | |
| |Bathroom # 3 |Shower/Bath | | |
| |Bathroom # 3 |Sink | | |
| |Bathroom # 3 |Toilet | | |
| |Bathroom # 3 |Bidet | | |
| |Bathroom # 4 |Bath | | |
| |Bathroom # 4 |Shower | | |
| |Bathroom # 4 |Sink 1 | | |
| |Bathroom # 4 |Sink 2 | | |
| |Bathroom # 4 |Toilet | | |
| |Bathroom # 4 |Bath | | |
| | | | | |
| |Kitchen |Dishwasher | | |
| |Kitchen |North Sink | | |
| |Kitchen |South Sink | | |
| |Laundry Room |Slop sink | | |
| |Laundry Room |Washing machine | | |
Ventilation Inspection and Inventory
|Item |Y/N |Indicia? |Sampled? |Comments |
|Isolated AHU? | | | | |
|Common air intake? | | | | |
|Common bathroom exhausts? | | | | |
|Forced air system? | | | | |
|Steam heat? | | | | |
|Common ducts to other properties? | | | | |
|Passive plena to other properties? | | | | |
|Active returns to other properties? | | | | |
|Passive wall grilles to other properties? | | | | |
|Industrial ventilation? | | | | |
|Residential ventilation? | | | | |
|Pressurized structure? | | | | |
Functional Space Inventory
|Project name: |Form # ML3 |
|Date: |
|Reporting IH: | |
| |Functional Space |Indicia |Describe the functional space |
|Structure Number |Number |(Y/N) |(See drawings for delineating structural features ) |
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Law Enforcement Documentation
|Project name: |Form # ML4 |
|Date: |
|Reporting IH: | |
|Inventory of Reviewed Documents | |
|Described method(s) of production | |
|Chemicals identified by the LEA as being | |
|present | |
| | |
|Cooking areas identified | |
| | |
|Chemical storage areas identified | |
| | |
|LE Observation on areas of contamination or | |
|waste disposal | |
Field Observations
|Project name: |Form # ML5 |
|Date: |
|Reporting IH: | |
Structure:
|Indicator |Functional Space |Indicator |Functional Space |
|Acids | |Match components | |
|Aerosol cans | |Mercury | |
|Alcohols (MeOH, EtOH) | |Methamphetamine | |
|Ammonia | |Modified coolers/containers | |
|Ammunition | |Modified electrical | |
|Artistic expressions | |Modified plumbing | |
|Bags of salt | |Modified structure | |
|Bases | |Modified ventilation | |
|Basters/Pipettes | |Needles/Syringes | |
|Batteries | |OTC Containers | |
|Bi-phasic wastes | |OTC drugs | |
|Booby traps | |pH papers/indicators | |
|Bullet holes | |Phenyl-2-propanone | |
|Burn marks | |Pornography, Sex toys | |
|Cat litter | |Prescription drugs | |
|Chemical storage | |Presence of cats | |
|Colored wastes | |Propane bottles | |
|Corrosion on surfaces | |Pseudoephedrine | |
|Death bag | |Red P | |
|Delaminating paint | |Red Staining | |
|Drug paraphernalia | |Reserved | |
|Empty OTC Containers | |Salters | |
|Ephedrine | |Security devices | |
|Feces | |Signs of violence | |
|Filters | |Smoke detectors disabled | |
|Forced entry marks | |Solvents - (organic) | |
|Funnels | |Squalor | |
|Gang markings | |Staining on floors | |
|Gas cylinders | |Staining on walls or ceiling | |
|Gerry cans | |Stash holes | |
|Glassware | |Taping on surfaces | |
|Graffiti | |Tubing | |
|Heating mantle/hot plate | |Urine containers | |
|Hidden items | |Wall anchors | |
|Hydrogen peroxide | |Wall coverings | |
|Iodine | |Wall damage | |
|Lead | |Weapons | |
|Lithium | |Window block material | |
|Marijuana | |Yellow staining | |
( Present but not as indicia
( Copious or unusual quantities
( Present in normal household expectations
( Modified in manner consistent with clanlab use
Contaminant Migration Observations
|Project name: |Form # ML6 |
|Date: |
|Reporting IH: | |
Describe/identify adjacent areas where contaminants may have migrated.
| | |
|Date: |
|Reporting IH: | |
| |Yes |No |N/C |
|Does the property have an ISDS | | | |
|Is there unusual staining around internal drains | | | |
|Are solvent odors present from the internal drains | | | |
|Is there evidence of wastes being disposed down internal drains | | | |
|Are solvent odors present from the external sewer drain stacks | | | |
|Was the septic tank lid(s) accessible | | | |
|Was the leach field line accessible | | | |
|Was the septic tank or leach field lines opened | | | |
|Are solvent odors present from the leach field lines (if “yes” see below) | | | |
|Are solvent odors present from the septic tank (if “yes” see below) | | | |
|Is “slick” present in the septic tank | | | |
|Are biphasic (aqueous-organic) layers present in the septic tank | | | |
|Was pH measured in the septic tank | | | |
|Were organic vapors measured in the septic tank (if “yes” see below) | | | |
|Is sampling of the ISDS warranted | | | |
|Were calawasi/drum thief samples collected from the septic tank | | | |
*NC = Not checked
Qualitative Organic Vapor Monitoring
|Instrument Type |Make and Model |
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|Location |MOS* |PID* |FID* |
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*Units of measurement are in parts per million equivalents compared to the calibration vapor.
Calibration gas________________ at _________________ppm
Utilities Locator Notes:
Pre-Remediation Photograph Log Sheet
|Project name: |Form # ML8 |
|Date: |
|Reporting IH: | |
Post-Remediation Photograph Log Sheet
|Project name: |Form # ML9 |
|Date: |
|Reporting IH: | |
Drawing of Cook Area(s)
|Project name: |Form # ML10 |
|Date: |
|Reporting IH: | |
| | |
|Date: |
|Reporting IH: | |
| | |
|Date: |
|Reporting IH: | |
| | |
|Date: |
|Reporting IH: | |
|DOCUMENTATION |Included? |
|Property description field form | |
|Description of manufacturing methods and chemicals | |
|Law Enforcement documentation review discussion | |
|Description and Drawing of Storage area(s) | |
|Description and Drawing of Waste area(s) | |
|Description and Drawing of Cook area(s) | |
|Field observations field form | |
|Functional Space inventory field form | |
|Plumbing inspection field form | |
|ISDS field form | |
|Contamination migration field form | |
|Identification of common ventilation systems | |
|Description of the sampling procedures and QA/QC | |
|Analytical Description and Laboratory QA/QC | |
|Location and results of initial sampling with figures | |
|Health and safety procedures in accordance with OSHA | |
|Contractor’s description of decontamination procedures and each area that was decontaminated | |
|Contractor’s description of removal procedures each area where removal was conducted, and the materials removed| |
|Contractor’s description of encapsulation areas and materials | |
|Contractor’s description of waste management procedures | |
|Drawing, location and results of final verification sample | |
|Pre-remediation photographs and log | |
|Post-remediation photographs and log | |
|Consultant’s Statement of Qualifications | |
|Certification of procedures, results, and variations | |
|Mandatory Certification Language | |
|Signature Sheet | |
|Analytical Laboratory Reports | |
|Field Sampling Forms | |
Sampling Field Form
|Project name: |Form # 14 |
|Date: | Alcohol Lot#: Gauze Lot#: |
|Reporting IH: |Cursory ____ Preliminary ____ Intermediate____ Final ______ |
|Sample ID |Type |Location |Functional |Dimensions |Substrate |
| | | |Space | | |
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Sample Types: W=Wipe; V=Microvacuum; A=Air; B=Bulk; L=liquid
Surfaces: DW= Drywall, P=Painted; W= Wood, L= Laminated, V= Varnished, M= Metal, C=Ceramic, Pl=Plastic
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[1] Salocks, et al, Technical Support Document: Toxicology, Clandestine Drug Labs: Methamphetamine
Volume 1, Number 8, California EPA, Office of Environmental Health Hazard Assessment, Revised 09/24/03 Referencing Neely, W.B. and Blau, G.E. (Eds.) (1985). Environmental Exposure from Chemicals. Volume 1. CRC Press, Inc.; Boca Raton, FL.
[2] US National Libraries of Medicine, Hazardous Substances Data Bank, referencing Reynolds, J.E.F., Prasad, A.B. (eds.) Martindale-The Extra Pharmacopoeia. 28th ed. London: The Pharmaceutical Press, 1982., p. 365
[3] Based on unpublished finding in criminal searches and arrests by one of the AIHA Committee members (Connell)
[4] Kirk-Othmer Encyclopedia of Chemical Technology. 3rd ed., Volumes 1-26. New York, NY: John Wiley and Sons, 1978-1984
[5] Drug Identification Bible, 2003. ISBN 0-9635626-5-7
[6] Unpublished interrogations between one of these authors (Connell) and street cooks.
[7] Escamilla B, New Cut Hitting the West Coast, CS Alert, Vol. 5, No. 1 Feb, 2008
[8] Bureau of Justice Assistance, Methamphetamine Investigations Management Course, Denver, Colorado, March 2006
[9] CFR 21
[10] National Center for Biotechnology Information, National Library of Medicine, National Institutes of Health, PubChem, 8600 Rockville Pike, Bethesda MD, 20894, October 28, 2009
[11] National Center for Biotechnology Information, National Library of Medicine, National Institutes of Health, PubChem, 8600 Rockville Pike, Bethesda MD, 20894, October 28, 2009
[12] Young GC, Turner RK CNS stimulant drugs and conditioning treatment of nocturnal enuresis. Behaviour Research and Therapy 3, 93-101 (1965).
[13] Development of a Reference Dose (rfd) for Methamphetamine, External Peer Review Draft December 2007, Integrated Risk Assessment Branch Office of Environmental Health Hazard Assessment California Environmental Protection Agency
[14] Salocks C, Derivation of a Risk Based Remediation Standard for Methamphetamine, Jan 8, 2008 power point presentation, California Environmental Protection Agency
[15] Drug Identification Bible, 2003. ISBN 0-9635626-5-7
[16] Cook CE, Pyrolytic Characteristics, Pharmacokinetics, and Bioavailability of Smoked Heroin, Cocaine, Phencyclidine, and Methamphetamine (From: Methamphetamine Abuse: Epidemiologic Issues and Implications Research Monograph 115, 1991, U.S. Department Of Health And Human Services Public Health Service Alcohol, Drug Abuse, and Mental Health Administration National Institute on Drug Abuse
[17] Cook CE, Jeffcoat AR, Hill JM, et al. Pharmacokenetics of Methamphetamine Self-Administered to Human Subjects by Smoking S-(+)-Methamphetamine Hydrochloride. Drug Metabolism and Deposition Vol. 21 No 4, 1993 as referenced by Martyny JW, Arbuckle SL, McCammon CS, Erb N, Methamphetamine Contamination on Environmental Surfaces Caused by Simulated Smoking of Methamphetamine (The publication of this study is currently pending. Copies of the study are available from the Colorado Alliance for Drug Endangered Children.)
[18] Harris DS, Boxenbaum H, Everhart ET, Sequeira G, et al, The bioavailability of intranasal and smoked methamphetamine, Pharmacokinetics and Drug Disposition, 2003;74:475-486.)
[19] Cook CE, Jeffcoat AR, Hill JM, Pugh DE, et al Pharmacokinetics of methamphetamine self-administered to human subjects by smoking S-(+)-methamphetamine hydrochloride Drug Metabolism and Disposition, Vol 21, No. 4, pp. 717-723, 07/01/1993
[20] Federal Register, December 12, 1979, Vol. 44, No. 240, Page 71822
[21] Christian DR, Forensic Investigations of Clandestine Laboratories, CRC Press 2004
[22] Hammon TL, Griffin S, Support for selection of a methamphetamine cleanup standard in Colorado, Regulatory Toxicology and Pharmacology 48 (2007) 102–114
[23] Cullis CF, Firth JG Detection and Measurement of Hazardous Gases, Heinemann Publishers, 1981
[24] Connell CP, Toxic Mold in Marijuana Grow Operations, The Colorado Law Enforcement Officer, Fall/Winter 2011.
[25] Unpublished “law enforcement only” sensitive documentation.
[26] Hammon TL, Griffin S, Support for selection of a methamphetamine cleanup standard in Colorado, Regulatory Toxicology and Pharmacology 48 (2007) 102–114
[27] Snawder JE, Striley CAF, Esswein, EJ et al, Use of Direct Reading Surface Sampling Methods for Site Characterization and Remediation of Methamphetamine Contaminated Properties, Journal of ASTM International, Vol. 8, No. 6, Paper ID JAI103481 (2011).
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