[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:
http://www.aiha.org
Printed in the United States of America
Table of Contents
Foreword…………………………………………………………………………..
Committee Members……………………………………………………………...
1. Purpose………………………………………………………………………..
2. Scope………………………………………………………………………….
3. Glossary of Terms……………………………………………………….........
4. Methamphetamine Manufacturing……………………………………………
4.1 What is Methamphetamine?.......................................................................
4.2 Methamphetamine Manufacturing and its Hazards………………………
5. Exposure Considerations and Health Effects…………………………………
5.1 Phosphine…………………………………………………………………
5.2 Iodine……………………………………………………………………..
5.3 Hydrogen Chloride……………………………………………………….
5.4 Methamphetamine Exposures……………………………………………
6. Societal Effects……………………………………………………………….
6.1 Children…………………………………………………………………..
6.2 Property Owners………………………………………………………….
6.3 Law Enforcement Personnel……………………………………………..
6.4 Industrial Hygienists……………………………………………………..
6.5 Health Departments and Regulators……………………………………..
6.6 Insurance Companies…………………………………………………….
7. The Industrial Hygienist……………………………………………………..
7.1 How Industrial Hygienists Get Involved…………………………………
8. Why Decontaminate?…………………………………………………………
8.1 The Preliminary Assessment Process……………………………………
8.1.1 Law Enforcement and Health Department Document Review……..
8.1.2 Compliance with Local Regulatory Requirements………………….
8.1.3 Entry Considerations……………………………………………….
Personal Protective Equipment…………………………….
Atmospheric Monitoring…………………………………..
Training……………………………………………………
8.1.4 Conducting the Site Assessment…………………………………..
8.1.5 Manufacturing Method……………………………………………
8.1.6 Physical Assessment and Observations…………………………..
8.1.7 Sampling for Methamphetamine Residue…………………………
Sampling Theory………………………………………….
Hypothesis Testing………………………………………..
Wipe Sampling Procedures……………………………….
8.1.8 Sampling for other Chemical Contamination………………………
8.2 Remedial Recommendations……………………………………………….
8.2.1 Site Type and Characteristics………………………………………
8.2.2 Contents of a Property……………………………………………..
8.2.3 Structural Considerations…………………………………………
8.3 Post-Cleanup Assessment…………………………………………………
8.3.1 Physical Assessment………………………………………………
8.3.2 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
1. 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.
2. 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.
3. 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.