Voluntary_Guidelines_For_Methamphetamine_And_Fentanyl_Laboratory_Cleanup.pdf

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

REVISED EDITION

AUGUST 2021

Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

1U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Contents Acronyms

1.2 Purpose and Scope

1.3 Methodology

1.4 Potential for Future Research

1.5 How to Use this Document

2.0 Remediation Standards

3.2 Hiring a Contractor

3.3 Ventilation

3.4 Worker Safety and Health

3.5 Preliminary Assessment

3.6 Pre-Remediation Sampling

3.7 Cleanup Plan

3.8 Removal of Contaminated Materials

3.9 Waste Characterization and Disposal Procedures

3.10 High Efficiency Particulate Air (HEPA) Vacuuming

3.11 Initial Wash

3.12 Heating, Ventilation and Air Conditioning (HVAC)

3.13 Detergent-Water Solution Washing

3.14 Post-Remediation Sampling

3.15 Encapsulation

3.16 Plumbing

3.17 Sewer/Septic

3.18 Outdoor Remediation

3.19 Final Report

4.2 Ceilings

4.3 Floors

4.4 Kitchen Countertops

4.5 Concrete, Cement and Brick

4.6 Appliances

2 U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

4.7 Wood

4.8 Windows

4.9 Electrical Fixtures, Outlets and Switch Plate Covers

4.10 Dishes, Flatware and Other Hard Non-Porous Household Goods

4.11 Toys and Other Children’s Items

4.12 Carpets

4.13 Clothing and Other Fabrics

4.14 Leather or Fabric Upholstered Furniture

4.15 Mattresses

4.16 Paper Items/Books

4.17 Mobile Residences

5.2 Sampling Theory

5.3 Wipe Sampling Methods

5.4 Microvacuum Sampling Methods

5.5 Quality Assurance/Quality Control (QA/QC)

6.2 Prevalence

6.3 Protection/Precautions/Planning

6.4 Remediation Standards

6.5 Remediation Techniques

6.6 Item- and Material-Specific Best Practices

6.7 Potential Sampling Constituents, Theory and Methods

Endnotes

Key Contributors

Appendix A: Primary Methods of Meth Production and Associated Hazards

Appendix B: Costs Associated with Meth Lab Cleanup

Appendix C: Properties of Chemicals Associated with Meth

Appendix D: Meth Resources

Appendix E: Meth Lab Remediation Diagrams

Appendix F: Fentanyl Resources

Appendix G: Common Fentanyl Analogs

Appendix H: Fentanyl Lab Remediation Diagrams

Appendix I: Photo Credits

3U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

AACT American Academy of Clinical Toxicology ACMT American College of Medical Toxicology APR Air Purifying Respirator ASTM American Society for Testing and Materials ASTSWMO Association of State and Territorial Solid Waste Management Officials ATSDR Agency for Toxic Substances and Disease Registry CDC Centers for Disease Control and Prevention CFR Code of Federal Regulations CIH Certified Industrial Hygienist CNS Central Nervous System DEA U.S. Drug Enforcement Administration DEC Drug Endangered Children DOJ U.S. Department of Justice DQOs Data Quality Objectives DTSC California Department of Toxic Substances Control EPA U.S. Environmental Protection Agency HAZWOPER Hazardous Waste Operations and Emergency Response HEPA High Efficiency Particulate Air HHW Household Hazardous Waste HVAC Heating, Ventilation and Air Conditioning IH Industrial Hygienist IHE Illicit Hazardous Environments LGR U.S. EPA Local Governments Reimbursement Program NACO National Association of Counties NAMSDL National Alliance of Model State Drug Laws NIOSH National Institute for Occupational Safety and Health NIST National Institute of Standards and Technology OJP U.S. Department of Justice Office of Justice Programs ONDCP White House Office of National Drug Control Policy OSHA Occupational Safety and Health Administration P2P Phenyl-2-Propanone PID Photoionization Detector PPE Personal Protective Equipment QA/QC Quality Assurance/Quality Control RCRA Resource Conversation and Recovery Act SCBA Self-Contained Breathing Apparatus TCOs Transnational Criminal Organizations TSP Trisodium Phosphate TSP-PF Phosphate-Free Trisodium Phosphate USCG U.S. Coast Guard VOCs Volatile Organic Compounds

Acronyms

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup4

1.0 Introduction

1.1 Background

The production and use of methamphetamine (meth) across the United States continues to pose considerable challenges to our nation. Meth is easy to make, is highly addictive and its production and use can have serious impacts on both human health and the environment.

Despite a decline in domestic meth production in recent years, vigilance is warranted not only because of the destructive nature of meth itself, but also due to the significant environmental hazards meth laboratories (labs) generate. See Appendix A: Primary Methods of Meth Production and Associated Hazards and Appendix B: Costs Associated with Meth Lab Cleanup for more information.

Our nation first demonstrated its commitment to better understand the hazards associated with meth labs in March 1990, when the Joint Federal Task Force (Task Force) published the Guidelines for the Cleanup of Clandestine Drug Laboratories (commonly referred to as the Red Book). The Task Force was created as a result of Section 2405 of the Anti-Drug Abuse Act of 1988 (Public Law 100-690) and included representatives from the U.S. Drug Enforcement Administration (DEA), the U.S. Environmental Protection Agency (EPA) and the U.S. Coast Guard (USCG). The Task Force’s charge was to issue guidelines to assist state and local officials conducting clandestine laboratory cleanups. The Red Book was first updated in 2005 and again in 2019.

DEA’s Guidelines for Law Enforcement—Cleanup of Illicit Hazardous Environments (2019), addresses the various types of illicit hazardous environments (IHEs) found at illicit drug operations to include clandestine meth laboratories and clandestine fentanyl laboratories.

Whereas DEA’s document focuses on law enforcement’s response to IHEs and their responsibility for the removal of hazardous chemicals and chemical waste (gross contamination), this document addresses remediation (the cleanup of residual contamination after gross removal has occurred), which is necessary to allow unrestricted future use of former clandestine drug laboratories.

In 2006, the White House Office of National Drug Control Policy (ONDCP) published the Synthetic Drug Control Strategy: A Focus on Methamphetamine and Prescription Drug Abuse (Synthetics Strategy) as a companion to the National Drug Control Strategy. The Synthetics Strategy acknowledges that, “compared to first responder issues, a more complicated and less understood area of science is the optimal set and sequencing of response actions at former meth lab sites that may possess residual chemical contamination.”1 Thus, the Synthetics Strategy tasked EPA with identifying best practices related to the remediation of former meth labs.

Congress passed the Methamphetamine Remediation Act (Public Law 110-143) in December 2007 directing EPA to establish voluntary guidelines for

EPA’s Local Governments Reimbursement Program In the event of a release (or threatened release) of hazardous substances, EPA may reimburse local governments for expenses related to the release and associated emergency response measures. The Local Governments Reimbursement (LGR) Program provides a “safety net” of up to $25,000 per incident to local governments that do not have funds available to pay for response actions.

Under the LGR Program, costs associated with the gross removal of meth labs and their related wastes may be eligible for reimbursement. These costs may include overtime wages related to hours spent securing the site or performing decontamination, costs for equipment purchased specifically for the response and contractor cleanup costs incurred by the local government for gross removal. However, costs related to long-term remediation actions as described in these voluntary guidelines (e.g., hiring a remediation contractor, conducting pre- and/or post-remediation sampling, developing a remediation cleanup plan and outdoor remediation) are generally not eligible for reimbursement under the LGR Program.

For more information, please visit the LGR website:

https://www.epa.gov/emergency-response/local-governments-reimbursement-program https://www.epa.gov/emergency-response/local-governments-reimbursement-program https://www.epa.gov/emergency-response/local-governments-reimbursement-program

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup 5 the remediation of former meth labs based on the best currently available scientific knowledge. This document, in addition to new research, serves to meet both the Synthetic Strategy’s and the Methamphetamine Remediation Research Act’s goals of improving “our national understanding of identifying the point at which former methamphetamine laboratories become clean enough to inhabit again.”²

1.2 Purpose and Scope

EPA prepared this document to provide voluntary cleanup guidelines to homeowners, cleanup contractors, industrial hygienists, policy makers and others involved in meth lab remediation. It does not set requirements, but rather suggests a way of approaching meth lab remediation. Those using this document should also consult their appropriate state and local requirements or guidelines. This document is not meant to supersede state and local requirements or guidelines (however, this document may be useful to state and local authorities as they develop and/or review and revise their own requirements or guidelines). EPA did not design this document for real estate transaction purposes. For disclosure laws, those using this document should consult their state and local authorities. Recognizing the emerging threat of fentanyl and the significant hazards fentanyl poses to the public, EPA updated this document in 2021 to include a new chapter on fentanyl remediation. This chapter can be found in Section 6.0.

The purpose and scope described above related to meth lab remediation may be applied to fentanyl lab remediation as well.

Tracking Former Drug Labs DEA maintains the National Clandestine Laboratory Register, which lists some former clandestine drug labs or dump sites.

[Note: The entries are reported by law enforcement and are not verified by DEA.] In addition, not all former clandestine drug labs or dump sites appear on the Register. The Register is available at: https://www.dea.gov/clan-lab.

Some states maintain their own clandestine laboratory registries.

Please refer to your specific state for additional information.

Meth Labs These voluntary guidelines specifically address the remediation of former meth labs and the unique dangers and hazards associated with them and may be applied to all meth labs regardless of the manufacturing method utilized. For the reasons listed below, no two meth labs are alike:

• Meth labs range from crude, makeshift operations to highly sophisticated and technologically advanced facilities.

• Meth labs can be set up almost anywhere and are often found in private residences, motel and hotel rooms, apartments, trailers, automobiles, campgrounds and commercial establishments. Labs are also found in rural outbuildings, barns and other structures that may appear uninhabitable.

• There are many ways to make meth, and the precursor chemicals, by-products and hazards associated with each production method differ.

Partial Meth Labs The manufacture of meth is a multi-stage process. In some cases, the various steps are performed in more than one lab or structure. For example, unrefined drug precursors may be chemically altered in one location and used in the final steps of the meth manufacture process later at a different location. Labs in which only a partial step of the meth manufacturing process was performed are called “partial labs.” The remediation process described in this document accounts for the possibility that precursor chemicals, in addition to meth, may be present in the structure. While each lab should be evaluated on a case-by-case basis, the remediation techniques contained in this document are applicable to partial labs.

Meth Conversion Labs Mexican Transnational Criminal Organizations (TCOs) are the primary suppliers of meth in the United States.

Manufactured on an industrial scale in Mexico, the meth is smuggled across the Southwest Border of the United States and is available in greater quantities and a lower cost than product made in domestic laboratories.

Before it is smuggled into the country, the meth is often dissolved into liquids including vehicle fluids, fuel, water and alcoholic beverages to avoid detection. Once across the border, the meth needs to be extracted from the solution in which it was dissolved and recrystallized so conversion labs are becoming more commonplace.

This process requires a variety of hazardous chemicals.3 While each lab should be evaluated on a case-by-case basis, the remediation techniques contained in this document are generally applicable to conversion labs.

Cooking vs. Smoking Meth Studies have shown that the smoking of meth alone can produce levels of airborne meth that may result in a general contamination of the structure in which it is smoked (although contamination levels will depend

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup6 upon how much meth was smoked and the smoker’s technique).4 While EPA originally developed these voluntary guidelines to apply to structures in which meth was manufactured or “cooked,” the voluntary guidelines contained in this document may be useful for cleaning up all sites contaminated by meth including “smoking sites” and other “use sites.” This may be especially relevant as the number of meth labs in the United States where manufacture occurs has significantly declined in recent years – from a high of 23,703 in 2004 to the lowest reported in 19 years of 891 in 2019.5 Despite the drop in the number of labs seized in the United States, the abuse of meth in this country remains high as does the likelihood of encountering contaminated meth sites.

Fentanyl Labs Properties may be contaminated by hazardous chemicals used or produced in the manufacture or packaging of fentanyl where those chemicals remain and where the contamination has not been remediated. Procedures for the assessment and remediation of properties or materials contaminated with fentanyl may be most applicable in situations where contamination of fentanyl is known (or determined) to have occurred. In this document, “clandestine fentanyl laboratory” means any location involved in the illegal manufacturing or storage of fentanyl. This may include manufacturing, compounding, converting, producing, deriving, processing or preparing, either directly or indirectly by chemical extraction, pill pressing, distribution, cutting, diluting, synthesis or other activity that has the potential to contaminate the property with fentanyl or any of its precursors.

As with meth labs, law enforcement will conduct the initial cleanup of the fentanyl-contaminated property limited to the removal of bulk hazardous materials, equipment and associated glassware that pose an immediate threat to public health and the environment.

Where fentanyl production has occurred, significant levels of contamination may be found throughout properties if the contamination is not remediated.

As of August 2021, there are currently no state or federal standards in the United States for determining when the site of a closed fentanyl drug laboratory has been successfully remediated.

While many of the remediation considerations and techniques for fentanyl are similar to those for the remediation of meth, the particle size, toxicity and production of fentanyl means a few different procedures should be followed. These differences are noted in Section 6.0.

Removal vs. Remediation Making a former meth or fentanyl lab safe for reoccupation requires two basic efforts: 1) the removal of gross contamination (i.e., containers of chemicals, equipment and apparatus that could be used to make illegal drugs); and 2) the remediation of interior structures and surrounding soil, surface waters and groundwater.

This document provides voluntary guidelines related to remediation. As the Synthetics Strategy explains, “remediation involves utilizing recognized procedures and technology-based standards to restore former meth labs to a state in which the property can be inhabited again—or, instead, identifying properties that are not yet ready for reoccupation and must undergo further treatment.”6 Remediation always occurs after gross chemical removal, when the site is secured and is no longer subject to criminal investigation.

Household Hazardous Waste While the Resource Conservation and Recovery Act (RCRA) allows disposal of household hazardous waste (HHW) in municipal landfills, meth and fentanyl lab waste chemicals would neither be generated as waste in normal residential households, nor generated in the quantities that might be used in the normal activities and maintenance of a residence. For these reasons, EPA does not consider meth and fentanyl lab waste chemicals and materials contaminated by those chemicals to be RCRA exempt household hazardous wastes.

Children’s Health Protecting children’s health from environmental risks is fundamental to EPA’s mission. Children may be more vulnerable to environmental exposures than adults because their bodily systems are still developing; they eat more, drink more and breathe more in proportion to their body size; and their behavior can expose them more to chemicals and organisms.7 According to the Department of Justice (DOJ) Office of Justice Programs (OJP), children who live in or visit meth labs or are present during drug production face acute health and safety risks. The age-related behaviors of young children (such as frequent hand-to-mouth contact and physical contact with their environment) increase the likelihood that they will inhale, absorb or ingest toxic chemicals, drugs or contaminated food. Their physiological characteristics (such as higher metabolic and respiratory rates and a developing central nervous system) leave them particularly vulnerable to the effects of toxic chemical exposures. Exposure to drugs and alcohol before birth places infants at increased risk for neurological abnormalities and respiratory problems, which may be compounded by ongoing

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup 7 environmental exposures. Children may also have a special vulnerability to certain harmful materials that may be present during meth lab remediation activities, including lead, asbestos and mercury. For these reasons, special care should be taken when cleaning up a former meth lab if a child lives or will live in the residence. The same considerations related to children’s health for meth lab remediation should be employed for the remediation of fentanyl.

Drug Endangered Children Many states have enacted Drug Endangered Children (DEC) laws to protect children from the consequences of drug production, trafficking and abuse. For more information, please see the National Alliance for Drug Endangered Children website: www.nationaldec.org.

Environmental Justice EPA does not regulate the cleanup of meth or fentanyl labs; the priorities for such cleanups are set by state and local laws. As such, concerns related to environmental justice (an EPA priority) should be left to the discretion of the state and local jurisdiction.

1.3 Methodology

A research team reviewed federal and state requirements and guidelines and other relevant studies, noting potential best practices as well as discrepancies in recommended practices.

After this research was completed, a group convened at EPA headquarters in Washington, D.C. in December 2007 to review the findings, provide feedback and share individual opinions. The group of 13 individuals (internal and external to EPA) included environmental, public health, industrial hygiene and toxicology professionals. During the meeting, these subject matter experts confirmed existing best practices, discussed the discrepancies in recommended practices and shared other best practices based on their own experiences.

EPA used both the findings from the research effort and the opinions expressed in the meeting to develop these voluntary guidelines.

Following the meeting, this document was distributed for wider review. EPA received comments from the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), the Agency for Toxic Substances and Disease Registry (ATSDR), the National Association of Counties (NACO), the National Institute of Standards and Technology (NIST), ONDCP and several other stakeholders. Updates were made based on these comments, as appropriate.

Then, in August 2008, the National Alliance of Model State Drug Laws (NAMSDL) convened a forum of its Cleanup and Remediation Working Group in Santa Fe, New Mexico to discuss the issues surrounding the cleanup and remediation of properties contaminated by meth labs. As part of the forum, working group members provided feedback on these voluntary guidelines and addressed outstanding questions. The voluntary guidelines were updated as a result of this input and other feedback from experts around the country.

In November 2012, EPA began a process to update these voluntary guidelines. As such, EPA solicited feedback from the original group of subject matter experts and other partners. The experts and partners assessed whether the information in this document was still accurate and relevant, identified other information that might be added and discussed how these voluntary guidelines are being used. Based on the input from the experts, the document was revised again and distributed for wider review during early 2013. Comments were received from several states and other stakeholders and additional updates were made to finalize these voluntary guidelines in March 2013.

In January 2020, EPA began the process of updating the guidelines again to better reflect the current state and to include a new section about fentanyl. Internal and external stakeholders reviewed the document and provided feedback and targeted comments. Based on the input from these partners, the document was revised and distributed for wider review. Additional updates were made to finalize these voluntary guidelines in August 2021. The name of the document was also changed to reflect the addition of the new fentanyl chapter.

A list of key contributors to this document can be found on page 37.

1.4 Potential for Future

Research

Because state and local approaches to cleaning up meth labs vary, there are sometimes differences in recommended practices or techniques. This variance in opinion indicates a need for further research. In many cases, the remediation techniques and approaches included in this document have not been vetted through rigorous scientific review. Instead, the recommendations are based on the lessons learned and practical experience of experts in the field. These voluntary guidelines may be augmented by EPA’s research and development, with support from DEA, NIST and other agencies, as it is made available.

The above also applies to fentanyl remediation. As of August 2021, there are no state or federal standards for

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup8 determining when a closed fentanyl drug laboratory has been successfully remediated in the United States.

Due to this and as on the ground situations change, new fentanyl analogs are encountered or remediation techniques are improved; these voluntary guidelines may need to be augmented by other sources and information.

1.5 How to Use this Document

This document begins with background information on quantitative meth remediation standards from across the United States. Next, this document presents users with a possible sequence of remediation activities, from securing the site to delivering the final report. Once the process for remediation is understood, users will find best practices on how to clean specific items and/or materials found within a former meth lab (e.g., walls, floors, appliances, electronics, fabrics, toys). This document also offers detailed information on sampling techniques and methods. A new chapter about fentanyl cleanup is included as well due to increasing clandestine fentanyl lab encounters in the United States. Special considerations are warranted because of the toxicity of fentanyl, its physical properties and the ability to alter the fentanyl structure resulting in hazardous/toxic fentanyl analogs. Finally, the appendices provide additional information and resources.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup 9

2.0 Remediation

Standards Due to the variety of chemicals that could potentially be used to manufacture meth, it can be time consuming and prohibitively expensive to sample for all of them. In addition, many of the chemicals used in the manufacturing process are already present in most homes. See Appendix C: Properties of Chemicals Associated with Meth for more information. [Note: In cases where the manufacturing method is known to employ chemicals that present unique hazards (such as a Phenyl-2-Propanone (P2P) lab), testing for individual components of the manufacturing process may be warranted.]

With this in mind, meth is often used as an indicator for the effectiveness of cleanup activities. This is based on the following assumptions:

• Bulk chemicals will be removed during the gross removal;

• Furniture, appliances or building materials with obvious stains (i.e., contamination) will be discarded;

• Many of the other potential contaminants are volatile organic compounds (VOCs) and tend to volatilize before and/or during cleanup; and

• The activities needed to clean up a structure to meet the applicable state standard for meth should be sufficient to reduce concentrations of other potentially hazardous chemicals as well.

EPA does not intend this document to set, establish or promote quantitative cleanup standards. Many state and local authorities have established quantitative cleanup standards for meth and chemicals associated with its production. As of August 2021, 21 states require or recommend that meth labs be cleaned to meet certain quantitative meth remediation standards.

Current state standards range from 0.05 µg/100 cm2 to 1.5 µg/100 cm2. The most common standard is 0.1 µg/100 cm2. Additionally, 11 states have process-based cleanup guidance materials, but no associated numerical remediation levels. See Appendix D: Meth Resources for more information. Those using this document should bear in mind that state and local requirements and guidelines change frequently.

Most state remediation standards are based on analytical detection limits and feasibility—they are not health-based standards. It is important to note, however, that these standards are believed to be set at sufficiently conservative levels to still be health-protective.8 In other words, remediation standards are believed to account for the scientific uncertainty involved in meth lab remediation in the interest of protecting human health and the environment.

In December 2007, California’s Department of Toxic Substances Control (DTSC) announced that it had calculated a health-based remediation standard for meth of 1.5 µg/100 cm2.9 In February 2009, DTSC finalized the scientific documents that form the basis for this health-based cleanup standard. In October 2009, the new health-based standard of 1.5 µg/100 cm2 was signed into state law as a safe level of methamphetamine on an indoor surface.

Washington adopted the 1.5 µg/100 cm2 remediation standard. Additionally, Kansas, Montana, Virginia and Wisconsin guidance use the value of 1.5 µg/100 cm2.

In addition to including remediation standards for meth, some states include quantitative standards for VOCs, corrosives, lead, mercury and iodine. Cleanup standards for meth and VOCs apply to all meth manufacturing sites, regardless of the cooking method(s) used. Cleanup standards for lead and mercury are especially relevant in instances where the P2P method of manufacturing meth was employed.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup10

As of August 2021, nine states require or recommend VOC levels of less than 1 ppm. Six states set corrosive standards or recommend targets for surface pH of 6 to 8. [Note:

The challenges associated with pH sampling are described in Section 5.1.] Ten states include lead standards or targets in their remediation guidelines; standards and targets range from 40 µg/ft2 (or its equivalent of 4.3 µg/100 cm2) to a more protective standard of 10 μg/ft2 (or its equivalent of 1 μg/100 cm2). Eleven states include mercury standards or targets in their remediation guidelines; standards and targets range from a more conservative 0.05µg/m3 (equivalent to 50 ng/m3) to 3.0 µg/m3 (equivalent to 3,000 ng/m3) of mercury in air. Two states set an iodine standard or target of 22 µg/100 cm2 for iodine-stained surfaces that are cleaned rather than removed. See Appendix D: Meth Resources for more information. These standards and associated sampling techniques are addressed in greater detail in Section 5.0.

Chemicals Used in Meth Production

Chemical Commonly Sold/ Found As Usage Health Hazards Po is on

Fl am m ab le

To xi c Va po rs

Ex pl os iv e

Co rr os iv e

Sk in

Ab so rp tio n

Acetone Paint Thinner, Nail Polish Remover

Solvent Reproductive disorders; skin and tissue irritation

Ammonium Nitrate

Instant Ice Packs, Fertilizer

Eye and lung irritant; skin irritant, permeator; ingestion of large amounts cause stomach irritation

Anhydrous Ammonia

Farm Nurse Tanks Reagent Freezes and burns skin; destroys mucous membranes;

causes asphyxia

Camping Fuel Coleman Fuel Solvent Skin irritation

Ether Starter Fluid Solvent Respiratory failure

Hydriodic Acid Sold commercially as lab grade

Reagent Burns; thyroid damage; lung damage

Hydrogen Chloride Gas

Sold commercially as lab grade

Reagent Respiratory failure; liver damage

Hydrogen Peroxide

First Aid Antiseptic (3%)

Reagent Skin and eye irritant and corrosive; lung sensitizer

Iodine 7% Iodine Tincture Reagent Extremely hazardous in case of skin or eye contact

Isopropyl Alcohol Rubbing Alcohol Solvent Eye, lung and stomach irritant; somewhat hazardous in case of skin contact (irritant, sensitizer, permeator)

Lithium Metal Lithium Batteries Reagent Burns; lung damage

Methanol HEET Solvent Blindness

Mineral Spirits Paint Thinner Solvent Eye and lung irritation

Muriatic Acid Pool Cleaner/ Concrete Etcher

Reagent Burns; toxic vapors

Pseudoephedrine Decongestant (e.g., Sudafed)

Precursor Unknown

Red Phosphorous Striker Plates on Matches and Road Flares

Reagent Irritant; produces phosphine gas

Sodium Hydroxide Drain Cleaner (e.g., Drano)

Reagent Burns

Sodium Metal Sold commercially as lab grade

Reagent Eye and tissue burns; temporary hair loss

Sulfuric Acid Drain Cleaner (e.g., Liquid Fire)

Reagent Very hazardous in case of skin or eye contact; may produce severe irritation of respiratory tract

Toluene Paint Thinner Solvent Hazardous in case of skin or eye contact

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup 11

3.0 Remediation

Sequence and Techniques Section 3.0 suggests a remediation sequence and techniques.

3.1 Overview of Remediation

Sequence Below is an overview of the possible sequence in which remediation activities may occur. See Appendix E:

Meth Lab Remediation Diagrams for more information.

Each of the processes below is described in greater detail later in this section. The sequence in this list begins after gross removal has occurred and any law enforcement investigation has concluded. All procedures should adhere to the Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, 29 CFR

1910.120 and other applicable state and local requirements and guidelines. Gross removal includes the removal and disposal of bulk chemicals, equipment and apparatus (hazardous wastes) that could be used to manufacture meth and typically occurs immediately following the seizure of a clandestine lab by law enforcement. [Note:

Chemical containers, equipment or apparatus from the lab may be left behind during the gross removal step. If these items are encountered, stop work and contact local law enforcement personnel (or other appropriate agencies). If law enforcement does not need these items and they can be handled safely, dispose of them appropriately as outlined in the Red Book.]

1. Secure the property to prevent unauthorized entry.

The structure should not be reoccupied until after remediation is complete.

2. Hire a contractor to conduct remediation, sampling and air monitoring.

3. Ventilate or “air out” the structure with fresh, outdoor air [e.g., open doors and windows; use fans, blowers and/or a negative air unit with a high efficiency particulate air (HEPA) filtration system] to ensure worker safety and health. Continue ventilation during the remediation process, taking steps to protect nearby or adjacent structures from contamination.

documentation.

b. Conduct an on-site evaluation.

c. Assess the need for pre-remediation and post-remediation sampling.

the preliminary assessment. This should include a decontamination plan and a waste disposal plan.

7. Remove contaminated materials. Any materials or objects that will be disposed of should be discarded before cleanup begins.

8. Clean the rooms and areas in the structure from the back to the front, sealing those areas to avoid potential recontamination and continuing through the structure.

9. Vacuum walls, floors and other hard surfaces using a vacuum with a HEPA filter.

10. Complete an initial washing of the walls and floors to remove most of the contamination.

11. Clean and seal the heating, ventilation and air conditioning (HVAC) system at all openings. Do not run this system again until all other cleanup is complete to prevent potential recontamination.

floors, non-porous furniture and other items that will be kept.

14. Conduct post-remediation sampling, if applicable.

(Ensure structure/items are completely dry before sampling.)

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup12

15. Consider encapsulating washed ceilings, walls and floors once they meet remediation requirements or guidelines.

16. If wastewater from detergent-water washing is disposed of down drains within the structure, flush the system again after remediation.

17. Ventilate the structure once more after indoor cleanup is complete.

unauthorized entry.

20. Prepare the final report.

3.2 Hiring a Contractor

Hire a contractor who has hazardous waste expertise and is certified (if certification is required by the state) to conduct cleanup operations at known or suspected meth labs. Several states have developed meth lab remediation certification programs for contractors, which help to ensure remediation processes are adequately conducted.

Contractors who have not been certified in a similar program should, at a minimum, complete the 40-hour HAZWOPER training (OSHA 29 CFR 1910.120).

It may also be appropriate to involve a certified industrial hygienist (CIH) in cleanup operations. Some states require that a CIH or experienced industrial hygienist (IH) conduct the preliminary assessment and post-remediation sampling. A CIH is trained in the assessment and control of chemical hazards and can play a significant role in ensuring that working conditions are safe during the remediation process. It is recognized that a CIH may not be available to accompany contractors to every cleanup site and that the use of a CIH can be expensive if they are involved in the entire remediation process. Therefore, contractors may consult a CIH to establish a general meth lab cleanup strategy. Other potential resources that may be consulted include state and local health agencies and environmental health specialists.

3.3 Ventilation

For the safety of on-site personnel, ventilate or “air out” meth labs with fresh, outdoor air (by opening doors and windows, and using fans, blowers and/or a negative air unit with a HEPA filtration system) before, during and after the remediation process. HVAC systems should be shut down and remain off until remediation of the former meth lab is complete.

Pre-Remediation Ventilation Ventilate the lab prior to the entry of cleanup personnel.

In some cases, law enforcement personnel will have already ventilated the lab before conducting criminal investigation activity or the gross removal of chemicals.

If the lab was sealed after these activities, ventilate the lab again before remediation occurs. Ventilation should be performed per the contractor’s recommendation or for a minimum of 24 hours.10

While several state guidelines recommend “baking,” or heating the structure with the doors and windows closed to promote the volatilization of chemicals, its effectiveness has not been documented. Baking is sometimes used for the remediation of mercury, so in cases of a P2P lab, this step might be employed. However, it is believed that baking may mobilize and redistribute chemicals, thereby spreading contamination. For this reason, baking is not recommended until further research is conducted.

Continued Ventilation It is important to continue ventilation throughout the remediation process (except when it would interfere with air monitoring). To protect workers and to limit cross-contamination, leave windows open and use fans, blowers and/or a negative air unit with a HEPA filtration system during cleanup. If using fans, blowers and/or a negative air unit, personnel should take precautions to avoid contaminant migration to areas that were not previously contaminated. A negative air unit equipped with a HEPA filtration system limits or prevents the transfer of airborne contamination from dirty to previously cleaned areas.

Also, take precautions to avoid contamination of nearby or adjacent structures during all ventilation activities.

Post-Remediation Ventilation Ventilate the property after cleanup is completed. After completion of all cleanup activities, contractors, owners and future occupants should be on alert for any new staining and/or odors (the presence of which would indicate that additional cleaning is necessary).

3.4 Worker Safety and Health

All procedures should adhere to OSHA HAZWOPER Standard, 29 CFR 1910.120 and other applicable state and local worker safety and health requirements. Do not begin remediation work until gross chemical removal is complete, law enforcement personnel have cleared the structure of defense measures placed by the lab operators (such as anti-personnel devices or “booby traps”) and the structure has been ventilated. Use the “buddy system” when making initial entry for remediation work, in case unforeseen dangers are encountered. In addition, conduct air quality monitoring to ensure the atmosphere is safe for entry.

Personnel who enter a former meth lab should have safety and health training (40-hour HAZWOPER training), and should use the appropriate level of personal protective equipment (PPE) based on the site-specific conditions.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup 13

Types and Levels of Personal Protective Equipment (PPE)* Level A (greatest level of skin, respiratory and eye protection) — positive pressure, full-facepiece self-contained breathing apparatus (SCBA), or positive pressure supplied air respirator with escape SCBA, approved by the National Institute for Occupational Safety and Health (NIOSH); totally-encapsulating chemical-protective suit; gloves, outer, chemical-resistant;

gloves, inner, chemical-resistant; boots, chemical-resistant, steel toe and shank; and disposable protective suit, gloves and boots (depending on suit construction, may be worn over totally-encapsulating suit).

Level B (highest level of respiratory protection but lesser level of skin protection) — positive pressure, full-facepiece SCBA, or positive pressure supplied air respirator with escape SCBA (NIOSH approved); hooded chemical-resistant clothing (overalls and long-sleeved jacket; coveralls; one or two-piece chemical-splash suit; disposable chemical-resistant overalls);

gloves, outer, chemical-resistant; gloves, inner, chemical-resistant; boots, outer, chemical-resistant steel toe and shank.

Level C (concentration(s) and type(s) of airborne substance(s) is known and criteria for using air purifying respirators are met) — full-face or half-mask, air purifying respirators (APR) (NIOSH approved);

hooded chemical-resistant clothing (overalls; two-piece chemical-splash suit; disposable chemical-resistant overalls);

gloves, outer, chemical-resistant; gloves, inner, chemical-resistant.

Level D (work uniform affording minimal protection: used for nuisance contamination only) — coveralls; boots/shoes, chemical-resistant steel toe and shank.

*OSHA Standard 1910.120, Appendix B

PPE for meth labs may include protective eye glasses, disposable gloves, foot coverings, steel toe boots and long-sleeved coveralls or a disposable protective suit.

Decontaminate or discard, as appropriate, all clothing and PPE worn during remediation.

Because meth can be injected intravenously, loose hypodermic needles may be present in a former meth lab and may pose a danger to those involved in remediation activities. Therefore, wear heavy work gloves and thick-soled leather shoes when collecting and removing trash, bedding, clothing, drapes, furniture, carpet, flooring or materials from any location that could conceal needles.11 Dispose of all needles in a labeled sharps container following state and local requirements or guidelines.

Use respiratory protection when removing carpet and other flooring or working in highly contaminated areas.

Respirators also should be used if the inhalation of sampling materials and cleanup solvents poses a threat to human health. Never eat, drink, smoke or store food or beverages in a former meth lab prior to or during remediation.

3.5 Preliminary Assessment

Once the materials and equipment used in the manufacture of meth have been removed by law enforcement, a preliminary assessment should be conducted. The goal of the preliminary assessment is to provide information that will inform the development of the sampling and cleanup plan (if needed). The preliminary assessment should be documented in a written summary and include a record review and a site survey.

Record Review To perform the record review, coordinate with state and local health departments and review copies of law enforcement or hazardous waste removal contractor reports (if available) for information on the duration of lab operation, manufacturing method, chemicals found, cooking locations, storage locations, disposal areas and observed contamination. This information, when coupled with the professional judgment of a cleanup professional (e.g., cleanup contractor, CIH/IH), can provide a foundation for the cleanup plan. Information gathered from those directly involved with the meth lab should be evaluated carefully because they may not be reliable sources.

Based on law enforcement or hazardous waste removal contractor reports, or on the professional judgment of the assessor, the record review can help to:

1. Establish the cooking method(s) employed during the manufacturing process.

2. Determine the quantities of chemicals found at the site and types of chemicals expected to have been on-site, based on the cooking methods.

3. Identify areas of expected contamination.

Site Survey After compiling all available information, conduct the site survey to confirm the information gathered during the record review, document actual conditions of the site and provide information for developing the cleanup plan.

Whenever possible, document conditions of the site with photographs.

While conducting the site survey, take precautions to ensure worker safety and health. Contamination can be removed prior to the preliminary assessment if it poses an imminent threat to human or environmental health.

The structure(s) should be ventilated before entry, and assessors should wear the appropriate PPE.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup14

Assessors should notify law enforcement personnel (or other appropriate agencies) if additional materials likely to have been used in the manufacture of meth are discovered.

To complete the site survey:

1. Compile a description and diagram of the site that includes: address, description and location of all structures; the layout of the property; and a description of adjacent properties and structures. For structures, the diagram should document the size and location of all rooms (e.g., basement, attic, closets), how the rooms connect and their expected use (e.g., bedroom, closet). In addition, the location of doors, windows, the ventilation system and appliances should be noted on the diagram. This description should include interior surfaces (e.g., walls, ceilings, floors, countertops) and any furnishings that remain on-site after gross removal.

2. Document areas of heaviest contamination. These areas could be identified by visible evidence of contamination (such as staining) or based on the professional judgment of the assessor. If visible signs of contamination do not exist, this does not mean there is no contamination. Residual meth should be routinely expected throughout the structure.

3. Determine or confirm the cooking method(s) employed during the manufacturing process.

4. Determine the presence of other potential hazards to cleanup personnel or future occupants including lead, asbestos and mercury which may include specific health concerns in their own right.

5. Examine the ventilation system for signs of contamination (e.g., rust). If contamination is suspected, sample the cold air return.

6. Examine the plumbing system (e.g., sinks, toilets, showers, tubs, drains) for damage. In addition, the assessor should identify the type of wastewater disposal system present (e.g., sewer connection, septic system).

7. Investigate any adjacent or nearby structures for avenues of potential contamination (e.g., common spaces, hallways, shared ventilation system). Cross contamination can often occur in townhouses, motels/ hotels, apartments or duplexes.

8. Determine if outside disposal occurred (e.g., burning, dumping, burying, drainage to septic system) and caused soil, surface waters or groundwater contamination. Common signs of outside disposal include burned or dead vegetation and stained soil.

3.6 Pre-Remediation Sampling

The decision whether to conduct pre-remediation sampling (and for which constituents) is best made on a property-specific basis. Owners and contractors should consult state and local requirements or guidelines when making the determination whether to conduct pre-remediation sampling.

Pre-remediation sampling can reduce costs by streamlining the cleanup process and identifying materials that are too contaminated to clean and should simply be removed. Pre-remediation sampling also can be useful in excluding certain portions of a property from a cleanup, such as areas to which the operators of the lab did not have access.

If pre-remediation sampling is conducted it should be conducted using the same protocols used for post-remediation sampling (see Section 5.0).

Pre-remediation sampling also may be performed for the following reasons:

• To ensure the safety and health of those working on a site before or during remediation.

• To establish whether contamination exceeds state and local requirements or guidelines.

• To inform the cleanup plan and process by identifying the extent of contamination in areas of the former lab.

• To determine which materials can be cleaned and which should be removed. This assessment can help lower overall cleanup costs.

• To help quantify cost estimates for cleanup.

• To sample for lead and mercury, two elements commonly associated with the P2P method of production, if this method was…