ISR;
,,
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JOINT FEDERAL TASK FORCE
Drug Enforcement Administration
Washington. D.C. 20537
Environmental Protection Agency
Washington. D.C. 20460
MESSAGE FROM THE ADMINISTRATORS
The Joint • Federal Task Force, consisting of the Drug Enforcement
Administration, the Environmental Protection Agency and the U.S. Coast Guard, is
pleased to present this copy of the GUIDELINES FOR THE CLEANUP OF CLANDESTINE
DRUG LABORATORIES. It was prepared in response to Section 2405 of the Anti-Drug
Abuse Act (P.L. 100-690) enacted by Congress on November 18, 1988, to protect public
health and the environment.
The guidelines were developed for use by state and local law enforcement,
environmental protection and public health agencies as a framework for developing
programs for cleaning up clandestine drug laboratories. They are flexible, to allow for
their application in various local situations; they contain an overview of the
recommended procedures for enforcement, for safe disposal of contaminated materials,
and for cleanup of residual contamination.
The guidelines will assist state and local officials address many of the issues
facing them as they implement a coordinated program of drug law enforcement and
clandestine drug laboratory cleanup. The issues with which they must contend include
regulatory development and coordination, establishment of specialized training
programs, acquisition of appropriate protective equipment, as well as funding, including
the need for establishment or modification of asset forfeiture regulations in accordance
with the program outlined in the President's National Drug Control Strategy.
We are confident that this document and the continued support of the Joint
Federal Task Force member agencies will help resolve these issues and insure the
successful implementation of coordinated state programs.
Sincerely,
Sincerely,
C. Lawn
Administrator
Drug Enforcement Administration
William K. Reilly
Administrator
Environmental Protection Agency
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GUIDELINES FOR THE CLEANUP
OF
CLANDESTINE
DRUG LABORATORIES
PREPARED BY:
THE JOINT FEDERAL TASK FORCE OF
THE DRUG ENFORCEMENT ADMINISTRATION,
THE U.S. ENVIRONMENTAL PROTECTION AGENCY,
THE U.S. COAST GUARD
MARCH 1990
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GuioeuNES ON CLANDESTINE DRUG LABORATORIES
ACKNOWLEDGMENTS
The Joint Federal Task Force consisted of members from the U.S. Drug Enforcement
Administration (DBA), the U.S. Environmental Protection Agency (USEPA), and the U.S.
Coast Guard (USCG). The following representatives were instrumental in developing the
guidelines for cleaning up hazardous wastes at clandestine drug laboratories:
Co-chairmen
John W. Gunn, Jr., DBA, Washington, DC
Hans J. Crump-Wiesner, U.S. EPA, Washington, DC
USEPA
Kenneth Fischer, Denver, CO
William Freutel, Boise, ID
Ken Gigliello, Washington, DC
Edward M. Powell, Philadelphia, PA
Diane C. Regas, Washington, DC
Paul E. des Rosiers, Washington, DC
Emily Roth, Washington, DC
Andre" Zownir, Edison, NJ
DEA
Jorg6 Acevedo, Houston, TX
Richard Fox, Washington, DC
Lanny Hall, Dallas, TX
James Hannon, Washington, DC
Sidney A. Hayakawa, Washington, DC
Rolf P. Hill, Washington, DC
Raymond J. McKinnon, Washington, DC
William P. Morley, San Francisco, CA
Philip J. Shebest, Washington, DC
Harry F. Skinner, San Diego, CA
Matthew E. Taylor, Denver, CO
USCG
Glenn F. Epler, Washington, DC
Roger Laferriere, Washington, DC
Richard Reinemann, Washington, DC
ii
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TABLE OF CONTENTS
TABLE OF CONTENTS
SECTION
Introduction
PAGE
.V
What Is the Problem?
DEA's Clandestine Drug Laboratory Safety Certification Program.
Developing a State or Local Clandestine Drug Laboratory Program 7
Cleanup of Residual Contamination 13
Summary of Joint DEA/USEPA Task Force Recommendations 17
References
.18
List of Acronyms 19
Glossary 21
Appendices 23
iii
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INTRODUCTION
INTRODUCTION
The Joint Federal Task Force and Its Charter
The Anti-Drug Abuse Act of 1988 (PL 100-690), Section 2405, establishes a Joint Federal Task Force on
illegal (hereinafter referred to as clandestine) drug laboratories. The Task Force consists of representatives
of the United .States Drug Enforcement Administration (DBA) and the United States Environmental
Protection Agency (USEPA), and representatives of the United States Coast Guard (USCG). Congress
directed the Task Force to formulate a program for cleaning up and disposing of hazardous wastes produced
by clandestine drug laboratories and to assist federal, state, and local law enforcement agencies with
implementing programs.
Guidelines for Cleaning Up Clandestine Drug Laboratories
The DEA/USEPA Task Force prepared these guidelines for state and local law enforcement and health
agencies to provide a framework for cleaning up clandestine drug laboratories. The guidelines contain an
overview of the recommended enforcement procedures as well as safety guidelines and cleanup strategies.
In addition, these Task Force guidelines were designed to be flexible and provide guidance to state and local
agencies for addressing typical problems encountered at clandestine drug laboratories. The guidelines should
not be used as a training manual. State and local agencies have the option to develop and implement
clandestine laboratory programs which are more extensive than the program outlined in the guidance.
References are made throughout this document to pertinent federal regulations, guidance documents relevant
to the evaluation and cleanup of hazardous waste sites, and chemical hazard information sources. The Task
Force encourages state or local agencies to use these guidelines and the referenced documents in developing
their own programs to ensure the proper cleanup of clandestine drug laboratories.
Currently, no federal guidance documents address the unique problems associated with clandestine drug
laboratories. As a result, these guidelines were integrated from the experiences of DBA field investigators
and USEPA regulatory and emergency response personnel, from various guidance documents developed by
the USEPA for cleaning up hazardous waste sites, and from health and safety programs established by the
DEA and USEPA.
Although the potential impact of clandestine drug laboratories may be less than that associated with industrial
hazardous waste sites, the potential for human exposure and environmental contamination still exists. In the
-absence-of proper safety procedures and cleanup guidelines, enforcement agents, state and local law
enforcement personnel, and thepublic may experience both acute and chronic adverse health effects as a result
of exposure to solvents, reagents, precursors, by-products, and drug products improperly used or generated
during the manufacture of illegal drugs.
Regulatory requirements must also be considered. In probably all clandestine drug laboratory seizures, the
operators of the laboratory generating hazardous waste have not followed USEPA storage or disposal
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
procedures. Under USEPA regulations implementing the Resource Conservation and Recovery Act
(RCRA), a generator of hazardous waste is "any person, by site, whose act or process produces hazardous
waste... or whose act first causes a hazardous waste to become subject to regulation" (40 CFR 260.10).
In seizing a clandestine drag laboratory, the law enforcement agency may encounter materials that
technically qualify as hazardous wastes and therefore are "subject to regulation". If those wastes exceed
certain minimal quantities, the law enforcement agency becomes a hazardous waste generator and is required
to adhere to waste disposal regulations promulgated under RCRA, and to regulations governing the transpor-
tation of hazardous materials promulgated by the Department of Transportation (DOT).
The difficulty of securing sources of funding for cleaning up clandestine drug laboratories faces almost every
state, local and regional law enforcement office in the country. Asset forfeiture, as outlined in the President's
National Drug Control Strategy, is one mechanism which could be used for financing cleanup activities.
Under asset forfeiture, all assets derived from illegal drag transactions or used to facilitate such transactions
may be confiscated and used by the law enforcement officials to pay the cleanup costs. Law enforcement
agents should assume that assets are derived from drag enterprises if authorities can show that there is no other
likely source of income. State, local and regional law enforcement agencies are encouraged to develop and
implement their own asset forfeiture programs as a means to provide specialized training and protective
equipment, and to recover investigative and cleanup costs associated with clandestine drug laboratory
seizures.
VI
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WHAT is THE PROBLEM?
WHAT Is THE PROBLEM?
Large quantities of illegal drugs are produced in the United States. Clandestine drug laboratories, in violation of the
Controlled Substances Act (PL 91-513), manufacture stimulants, depressants, hallucinogens, and narcotics. These
laboratories could satisfy the current domestic illegal drug demand even if the entry of all drugs from foreign source
countries were halted.
WHAT Is A CLANDESTINE DRUG LABORATORY?
Domestic clandestine drug laboratories range from crude makeshift operations to highly sophisticated and technologi-
cally advanced facilities, some of which are mobile. They can be set up anywhere and are often found in private
residences, motel and hotel rooms; apartments, house trailers, houseboats, campgrounds, and commercial establishments.
Often these laboratories are hidden in nondescript houses or barns in remote rural areas. Many of these facilities contain
sophisticated surveillance equipment and are booby-trapped both to prevent intruders and law enforcement personnel
from entering, and to destroy any evidence if the facility is discovered.
CLANDESTINE DRUG LABORATORY SEIZURES
1200 -
1100 :
1000 -
900 -
DEA
SEIZURES 700 i
ONLY eoo :
500 :
400 -
300 '-_
200 :_
100 :
0
'81 '82 '83 '84 '85 '86 '87 '88 '89
Fiscal Years
| = Actual
I = Estimate
How MANY CLANDESTINE DRUG LABORATORIES EXIST?
More clandestine drug laboratories are operating in the United States than ever before, which increases the availability
of drugs such as stimulants and hallucinogens. This increase is attributed to the availability of precursor chemicals and
the increasing popularity, ease of manufacture, low production costs, and^high profits of the drugs. DEA enforcement
actions against these laboratories have increased dramatically throughout the 1980's by 22 - 25% per year (see graph on
this page). According to DEA statistics, the number of laboratories seized has grown from 184 laboratories in FY 1981
to 810 laboratories in FY 1988. While these numbers are significant, they do not include all the laboratories seized by
state and local law enforcement agencies.
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
WHERE Is THE PROBLEM?
Although the problem is a national one, four states account for 78 % of all types of laboratories seized by DBA in FY 19 8 8:
California (44%), Texas (19%), and Oregon and Washington (15% combined).
FY 1988 DBA Clandestine Drug Laboratory Seizures
1-NH
\ O!
WHO OPERATES CLANDESTINE
DRUG LABORATORIES?
The operators of these laboratories range from novices with
little or no chemistry background to chemists with Ph.D.
degrees. Organized gangs (e.g., motorcycle, street, etc.)
historically have manufactured and distributed ampheta-
mines and phencyclidine (PCP).
The "recipes" for most of the illegal drugs are relatively
simple and are available through both legal and illegal
sources. Many of the drugs produced by these laboratories
can be made with easily obtainable chemicals, and equip-
ment that is not much more sophisticated than that found in
a typical high school chemistry laboratory. It does not
require special training or facilities to produce illegal drags.
Therefore, anyone motivated by the high profit potential
can get involved in the illegal drug manufacturing business.
WHAT ARE THE DRUGS AND
HAZARDOUS WASTES PRODUCED?
DBA statistics indicate that the majority of the laboratories
produce three drags: methamphetamine (82%), ampheta-
mine (10%), and PCP (2.5%). Laboratories which manu-
facture these drags account for approximately 95% of the
total number of laboratories seized in FY 1988. However,
many different substances are also produced by clandestine
drag laboratories. The number is constantly growing as
new controlled substance analogs ("designer drugs") are
developed in an attempt to circumvent controlled substance
laws.
When a clandestine drag laboratory is seized, hazardous
waste/materials, such as chemicals and contaminated
glassware and equipment, must be disposed of properly.
These materials weigh from a few pounds to several tons
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WHAT Is THE PROBLEM?
and include solvents, reagents, precursors, by-
products, and the drug products themselves.
Many of these materials are reactive,
explosive, flammable, corrosive, and/or toxic.
Table 1 provides examples of representative
chemicals associated with methamphetamine
laboratories and lists some of their hazardous
properties. Additional listings of the health
effects from exposure to the most commonly
encountered chemicals associated with
clandestine druglaboratory types arepresented
in Appendix A. This listing includes most of
the laboratory types and represents the broad
spectrum of chemical hazards. For more
detailed information on health effects and
other properties of hazardous chemicals, refer
to references 1 to 9.
Although the quantities of hazardous materi-
als found at atypical clandestine druglabora-
tory are relatively small when compared to a
typical hazardous waste site, the substances to
which law enforcement personnel and others
may be exposed present very real public health
concerns.
Clandestine drug laboratories may contami-
nate water sources and/or soil. In some cases,
contamination may spread off-site. Careless
or intentional dumping by the illegal labora-
tory operator is not the only source of con-
tamination. The chemical reactions which
occur during the manufacturing of illegal drugs
may produce toxic vapors that permeate into
the building's plaster and wood or may be
vented outside. The problems are further
complicated when the chemicals are stored at
off-site locations such as rental lockers. The
lack of proper ventilation and temperature controls at these
off-site locations add to the potential for fire, explosion,
and human exposure.
WHO Is EXPOSED To THESE
HAZARDS?
Clandestine drug laboratories may present both acute and
chronic health risks to individuals involved in the seizure
and cleanup of the facility, to those who live or work
nearby, and to the violator operating the facility.
The raw chemical materials and the by-products of the
drug manufacturing process are often disposed of indis-
TABLE 1: SOME TYPICAL CHEMICALS FOUND IN
CLANDESTINE METHAMPHETAMINE LABORATORIES
(NOT An
INCLUSIVE)
Chemical Acute Toxicitv* Flammabilitv*
Acetic anhydride
Benzene
Chloroform
Ethanol
Hydrogen Cyanide
Hydrochloric Acid
Hydriodic Acid
Lead Acetate
Lithium Aluminum
Hydride
Mercury Chloride
Methylamine
Petroleum Ether
Phenylacetic Acid
Phosphine
Red Phosphorus
Sodium (metal)
Thionyl Chloride
* Based primarily on
Moderate
Moderate-High
Moderate
Low
Extreme
High
High
High
Moderate
High
High
Low
Low
High
Low
High
High
National Fire Protection
Moderate
High
Low
High
Low
Low
Low
Low
High
Low
Extreme
Extreme
Low
Extreme
Low
Low
Low
Other Properties
Irritant, Corrosive
Blood Disorders,
Carcinogen
Incoordination,
Probable
Carcinogen
Incoordination
Rapid asphyxia
Irritant, Corrosive
Irritant, Corrosive
Blood Disorders
Water reactive
Explosive
Irritant, Corrosive
Corrosive
Incoordination
Irritant
Reactive
Rapid asphyxia
Reactive &
Explosive
Water reactive
Corrosive
Water reactive
Corrosive
Association Standards
criminately by the outlaw-laboratory operator to avoid
detection. This can pose a significant human health or
environmental hazard. The operators of these laboratories
have little regard for quality control or safety. Spilling
chemicals on the floor or dumping waste into bathtubs,
sinks, toilets, or on the grounds surrounding the laborato-
ries, and along roads and creeks are common practices.
Surface and groundwater drinking supplies could be con-
taminated, potentially affecting large numbers of people.
Perhaps the greatest risk of long-term exposure is assumed
by unsuspecting inhabitants of buildings formerly used by
clandestine drug laboratory operators where residual con-
tamination may exist inside and outside the structure.
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GUOGUNES ON CLANDESTINE DRUG LABORATORIES
WHAT ARE THE HAZARDS To LAW
ENFORCEMENT PERSONNEL?
The primary health concerns at a clandestine drug labora-
tory site are the acute hazards to law enforcement officers
who carry out the raids. During a raid, the law enforcement
personnel may be exposed to solvents, reagents, precursors,
drug products, and by-products that are acutely toxic (i.e.,
irritant, corrosive, depressant, or asphyxiating). Further,
many of these solvents and reagents are explosive or flam-
mable.
Law enforcement personnel engaged in clandestine drug
laboratory investigations and seizures should have special-
ized training in the investigation of clandestine drug labo-
ratories, in appropriate health and safety procedures, and in
the use of personal protective equipment.
ARE THERE PROCEDURES FOR
DEALING WITH CLANDESTINE
DRUG LABORATORY HAZARDS?
DEA and its predecessor agencies have been involved in
seizing clandestine drug laboratories for several decades.
While each laboratory seizure is unique and presents many
types of hazards, there are standard procedures that DEA
agents follow during the investigation and seizure of a clan-
destine drug laboratory. An overview of the DEA's ap-
proach is presented as a general model for state and local
law enforcement agencies for the development of their own
programs/procedures.
You Need to Know
Levels of Protection
Level A
When to use Level A:
Total encapsulated protection against known highly
toxic corrosive materials which have severe acute
hazards by skin contact or by gas or vapor skin
absorption. For use in suspected hazardous areas
where materials are not identified with certainty and the
hazards are unknown.
Recommended Level A equipment:
- Pressure-demand, full-facepiece, Self-contained
Breathing Apparatus (SCBA) or pressure-
demand supplied-air respirator with escape
SCBA
- Fully encapsulating chemical-resistant suit
- Inner chemical-resistant gloves
- Chemical-resistant safety boots/shoes
— Two-way radio communications
- Hard Hat
LevelB
When to use Level B:
When the highest level of respiratory protection is
needed but the environment is not considered acutely
toxic to skin contact or by gas or vapor skin absorption.
Recommended Level B equipment:
— Pressure-demand, full-facepiece SCBA or
pressure-demand supplied-air respirator with
escape SCBA
- Chemical-resistant clothing (overalls and long-
sleeved jacket; hooded, one- or two- piece
chemical splash suit; disposable chemical-
resistant one-piece suit)
- Inner and outer chemical-resistant gloves
- Chemical-resistant safety boots/shoes
- Hard hat
- Two-way radio communications
Level C:
When to use Level C:
When the criteria for wearing respiratory protection is
present and the environment is not considered to be
toxic via skin contact.
Recommended Level C equipment:
- Full-facepiece air-purifying, canister/cartridge-
equipped respirator
- Chemical-resistant clothing (overalls and long-
sleeved jacket; hooded, one- or two- piece
chemical splash suit; disposable chemical-
resistant one-piece suit)
- Inner and outer chemical-resistant gloves
- Chemical-resistant boots
- Hard hat
- Two-way radio communications
- Five minute emergency escape pack
Level D:
When to use Level D:
When the atmosphere contains no known hazard; work
functions preclude splashes, immersion or the potential
for unexpected inhalation of or contact with hazardous
levels of any chemicals.
Recommended Level D equipment:
- Coveralls
- Safety boots/shoes
- Safety glasses or chemical splash goggles
- Hard hat
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DEA's CLANDESTINE DRUG LABORATORY SAFETY CERTIFICATION PROGRAM
DEA's CLANDESTINE
DRUG LABORATORY SAFETY
CERTIFICATION PROGRAM
The investigation of clandestine drug laboratories presents
unique challenges to law enforcement personnel and re-
quires specialized training. DEA's program consists of
two separate schools: (1) Clandestine Laboratory Investi-
gative School and (2) Clandestine Laboratory Safety School.
Each of these schools is approximately one week in length,
and the Investigative School is a prerequisite for attending
the Safety School. The list of courses for these schools is
provided in Appendix B.
The Safety School curriculum was developed in accor-
dance with regulations promulgated by the Occupational
Safety and Health Administration (OSHA) in Title 29 of
the Code of Federal Regulations and with recommenda-
tions from the National Institute of Occupational Safety
and Health (NIOSH).
All agents and chemists involved in these courses must
complete a medical screening (see Appendix C). Without
this medical screening and training, neither agents nor
chemists can participate in the entry, assessment, or
processing phases of a laboratory seizure.
The DBA program also addresses the protection of the
public health and safety and the environment by employ-
ing a qualified hazardous waste disposal firm to properly
manage and dispose of hazardous wastes.
AN OVERVIEW OF DEA's
CLANDESTINE DRUG LABORATORY
SEIZURE PROTOCOL
When the DBA begins the investigation, routine investiga-
tive techniques are employed to gather sufficient probable
cause to substantiate that a drug laboratory is operating on
the premises. The DBA Special Agents then request a
search warrant. If necessary, authority to destroy any haz-
ardous bulk chemicals and equipment used in the manufac-
turing of illegal, dangerous drugs may be requested in the
warrant. Due to the complexities of clandestine drug
laboratories, a DBA forensic chemist is consulted prior to
and during the seizure.
A DEA clandestine drug laboratory seizure usually pro-
ceeds in six steps: planning, entry, assessment, process-
ing, exit, and follow-up.
Planning The Raid
In planning the raid, the case agent first makes an assess-
ment of the hazards likely to be encountered and deter-
mines who needs to be notified before the raid (i.e., local
police, fire department, emergency rooms, and hazardous
waste contractor). Once the potential hazards have been
considered, the case agent assigns certified teams to con-
duct the raid. These teams include a forensic chemist and
a site safety agent who are trained and equipped with requi-
site safety equipment.
Initial Entry
The purpose of the initial entry is to apprehend and remove
the operators and to secure the laboratory.
DEA protocol calls for the initial entry team to employ
ballistic protection equipment and fire retardant clothing.
Respiratory protection (i.e., SCBA) is not used by the
initial entry team because it may restrict an agent's vision
and mobility. This may significantly interfere with an
agent's ability to defend against armed suspects. This
protocol was adopted after careful consideration of the
pros and cons and is based largely on the experiences of
field agents.
Assessment
After securing the premises, everyone is evacuated. Then
a specially trained and certified agent and forensic chemist
with Level B protective equipment (see Sidebar: Levels of
Protection, page 4) conduct a thorough assessment to de-
termine what, if any, immediate health and safety risks
(i.e., potential for fire and explosion, toxic vapors, booby-
traps, etc.) exist. The team then takes appropriate steps to
reduce imminent risks (i.e., properly shutting down active
"cooking" processes, ventilating the premises, etc.). After
the assessment team determines the level of risk and estab-
lishes the appropriate level of protection required, the
processing phase can begin.
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
Processing
During the processing phase, agents photograph and vide-
otape everything in the laboratory and then gather evidence.
No materials or apparatus are moved until the certified
chemist and agent have inspected and inventoried each
piece of evidence. The certified chemist, in consultation
with the agent, takes samples as needed for evidence. All
samples are labeled, initialed, packaged, and sealed for
transportation to a DBA laboratory. The recommended
one-ounce sample size is typically sufficient for DBA drag
analysis and, if necessary, a reanalysis. The team does not
lake possession of, or transport any chemicals, glass-
ware, or apparatus used in the laboratory other than the
samples taken for evidence. A qualified hazardous waste
disposal contractor is used to remove all remaining chemi-
cals (liquids and powders), and laboratory glassware and
equipment.
DEA considers all of these materials to be contaminated
and, therefore, manages them as RCRA hazardous
waste. When the processing has been completed, the case
agent authorizes the disposal contractor to remove and
dispose of all hazardous waste. The case agent verifies and
accounts for all hazardous wastes to be removed and
remains at the site until the disposal contractor has com-
pletely removed the hazardous waste. Any contaminated
protective clothing and equipment that cannot be decon-
taminated and reused is removed by the disposal contractor
(see Sidebar: Hazardous Waste Statutes and Regulations,
page 7).
Exit
When the removal of these hazardous wastes has been com-
pleted, the case agent conducts a final inspection of the
premises, signs all documents pertaining to the site and the
disposal contractor's driver log, and posts a prominent
warning sign on the premises (see Appendix F).
Follow-up
Notification letters are sent by the Special Agent in Charge
(SAC) of the DEA division to the property owner, with
copies to appropriate health and regulatory agencies. All of
these letters are sent by certified mail, return receipt
requested.
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DEVELOPING A STATE OR LOCAL CLANDESTINE DRUG LABORATORY PROGRAM
DEVELOPING
A STATE OR LOCAL CLANDESTINE DRUG
LABORATORY PROGRAM
The DEA program just outlined provides a basic frame-
work which each state or local law enforcement agency can
use as guidance to develop and implement its own pro-
gram. As the resources and particular needs of each state
vary, exact duplication of the DEA program may not nec-
essarily be possible or desirable. However, the state or
local program should reflect the basic principles and con-
siderations developed by the DEA.
The Congressional mandate to address the clandestine
drug laboratory problem is based on the recognition that
hazardous materials generated by these laboratories pose a
significant health threat to law enforcement personnel as
well as to the general public and the environment. It is
essential that cooperative interaction be established be-
tween law enforcement and other state or local agencies to
effectively address the clandestine laboratory problem in
their jurisdiction. Although law enforcement agencies can
initiate the cleanup activities through the bulk removal
effort, more extensive cleanup activities should be the re-
sponsibility of non-law enforcement groups designated by
the state or local governing body.
The DEA/USEPA Task Force recommends that each
state appoint a lead agency to assume responsibility for
developing a comprehensive clandestine drug labora-
tory program which addresses law enforcement and
environmental/health and safety concerns. The desig-
nated lead agency may wish to transfer authority to
local agencies which have the capability to respond to
these situations.
Although protecting the public health and welfare is the
primary goal of a clandestine drug laboratory program, the
cost of the cleanup process is also a concern. USEPA has
outlined its general approach to cost recovery and cleanup
procedures in the National Contingency Plan (NCP) (Ref-
erence 10) and in the EPA Superfund Removal Procedures
Manual (Reference 11). The DEA currently uses asset
forfeiture funds to finance cleanup activities at clandestine
drug laboratories. States could develop and implement
similar strategies for recovering costs. DEA's model pro-
gram on asset forfeiture can be used as a guideline for
creating state asset forfeiture programs (Reference 12).
Finally, it is essential that the guidelines which are devel-
oped within each state are consistent with federal and state
regulations and, where applicable, local regulations relat-
ing to the handling and disposal of hazardous wastes (see
Sidebar: Hazardous Waste Statutes and Regulations, this
page).
you Need to^Knoiff
Hazardous Waste Statutes and Regulations
When a law enforcement agency seizes a clandestine drug laboratory site, that agency may become a hazardous waste
generator under federal law (RCRA), and may need to comply with the following regulations.
1. The Resource Conservation and Recovery Act (RCRA) as amended by the Hazardous and Solid Waste Act (HSWA)
(40-CFR Parts 260 on definitions, 261 on hazardous waste determinations, 262 on generators, and 263 on trans-
porters) governs the transportation, storage, and disposal of hazardous wastes.
2. The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act (SARA), governs emergency responses for releases of hazardous
substances into the environment and the cleanup of inactive hazardous waste disposal sites (40 CFR 300).
3. The Hazardous Materials Transportation Act regulates packaging, marking, labeling, and transportation of hazard-
ous materials, including hazardous wastes (49 CFR Parts 170,171, and 172).
4. The Occupational Safety and Health Act (OSHA) regulates safety conditions in the workplace (29 CFR Part
1910.120) and establishes employee right to know provisions (Part 1200).
5. State and local regulations (can be more stringent than federal regulations governing hazardous waste).
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
Clandestine Drug Laboratory Safety
Certification
Personnel involved in the investigation and seizure of clan-
destine drug laboratories must receive medical screening
mid specialized training (see Appendix B on Training and
Appendix C on Medical Certification).
The DEA/USEPA Task Force recommends that medi-
cal screening and the specialized training programs be
considered an essential part of a clandestine drug labo-
ratory program.
Planning a Clandestine Drug Laboratory
Seizure
Clandestine laboratories, by the very nature of their activi-
ties, present a unique series of hazards and risks to law en-
forcement personnel. The degree of hazard depends on the
specific site, chemicals present, their concentrations, con-
ditions of storage (sealed, open, or leaking containers), and
their proximity to each other (which may lead to various
chemical reactions). Hazards which may be expected in-
clude:
• Exposure to hazardous materials such as
— explosive and reactive chemicals
- flammable agents
— acutely toxic substances
- irritant and corrosive agents
- possibly radioactive materials (e.g., thorium)
• booby-traps
• physical injury resulting from close quarters
Abandoned clandestine drug laboratory sites and chemical
storage areas present similar hazards and similar precau-
tions should be taken to ensure personnel safety.
The following safety procedures should be considered
when planning the raid:
• Notify fire department, hazardous materials re-
sponse team and police bomb squad, depending on
the size of the laboratory and the degree of hazard.
• Be sure fire extinguishers and a first-aid kit are
available.
• Avoid the use of shotguns or diversionary devices
such as flash bangs, smoke, or tear gas canisters.
These weapons can ignite fumes.
• Do not turn switches on or off. They could be
booby-trapped or cause sparks.
* Do not unplug "cookers," heating elements, or
cooling equipment. They could be booby-trapped
or cause sparks.
• Do not open refrigerators or freezers. They could
be booby-trapped or cause sparks.
Do not move containers that are in the way. Step
over or around them. They could be booby-trapped.
Do not use matches or flames of any kind. If you
have to look in dark areas, use an explosion-proof
flashlight.
• Do not taste, smell, or touch any substance.
• Do not use flashbulbs on cameras as they can cause
flammable solvents or fumes to ignite; use only
electronic strobes.
Do not smoke at the site.
Do not eat or drink at the site.
Do not touch your mouth, eyes, or other mucous
membranes with your hands.
Decontaminate clothing, equipment, and person-
nel (including prisoners) before leaving the labora-
tory site.
Initial Entry
The initial entry teams should be specially trained law en-
forcement officers who arrest the illegal laboratory opera-
tors and secure the site. After securing the premises,
everyone is evacuated and the assessment step begins.
The DEA/USEPA Task Force recommends that state
and local law enforcement agencies require that their
personnel wear protective clothing, where appropriate,
such as ballistic vests and fire retardant suits, when
seizing clandestine drug laboratories.
Assessment: Health and Safety Protocol
Only the laboratory assessment team enters the laboratory;
the laboratory is off-limits to all other personnel. The labo-
ratory assessment team uses Level B protection (see Side-
bar: Levels of Protection, page 4).
Decisions regarding the application of appropriate health
and safety protocols should be made by the laboratory
assessment team. This team should include a certified law
enforcement officer who is knowledgeable about, and
trained in, clandestine drug laboratory investigations and
seizures. A certified chemist who is knowledgeable about,
and trained in, illegal-drug manufacturing and knows how
to safely and effectively shut down operations and collect
evidentiary samples, should also be included in the team.
The team must have, and be trained in the usage of, appro-
priate monitoring instrumentation, such as air-sampling
pumps, explosimeters, oxygen meters, organic-vapor ana-
lyzers, or other air-monitoring instruments that are used to
determine the lower explosive limit (LEL) and the concen-
tration of organic vapors in the laboratory atmosphere. All
monitoring devices must be intrinsically safe (i.e., designed
to suppress sparks that may ignite explosive atmospheres).
-------
DEVELOPING A STATE OR LOCAL CLANDESTINE DRUG LABORATORY PROGRAM
You Need to Know
Conditions Requiring Ventilation During Seizure:
The laboratory must be ventilated if:
• The concentration of oxygen is less than 19.5 or
greater than 25 percent.
• The concentration of any combustible gas is
greater than 25 percent of the lower explosive
limit (LEL).
• The concentration of any organic vapors and
gases is greater than the permissible exposure
limit (PEL) or the threshold limit value (TLV) of
theirrespectivecomponents.orgenerally greater
than 5 parts per million if the compounds are not
known.
Caution: See information on this page regarding
LSD, fentanyl, alphaprodine, and MPPP labora-
tories.
After appropriate air measurements are taken, the next step
is to identify the chemicals and equipment present in the
laboratory and the potential hazards that may exist. If re-
quired, ventilation can be accomplished by opening doors
and windows, provided that a natural draft exists. Before
windows and doors are opened for ventilation, ascertain
that they are not booby-trapped. Unless they are intrinsi-
cally safe (i.e., explosion proof), fans should not be used
because sparks from the fan motor can cause flammable
solvents or fumes to ignite.
It is important to note that some laboratories (e.g., those
producing LSD, fentanyl, alphaprodine, and MPPP),
should not be ventilated because of the potential for
human exposure to the extremely toxic dusts or vapors
if they are released into the atmosphere.
If an emergency situation exists which indicates that there
is an imminent and substantial threat, or if there is a release
of a reportable quantity of a hazardous substance (see 40
CFR Part 302.4), the law enforcement agency or the state
or local agency involved in the clandestine laboratory in-
vestigation shall notify the NationalResponse Center (NRC)
(see Sidebar: What Information Should Be Reported to the
NRC?, page 12). The NRC notifies appropriate agencies
(i.e., the USEPA/USCG, state, and local government) in
accordance with established procedures. In addition to
NRC notification, there may be additional state and local
notification requirements that need to be addressed. After
notification, the cognizant agency initiates appropriate
response actions to protect the public health and the envi-
ronment.
The DEA/USEPA Task Force recommends that state
and local authorities recognize that each clandestine
drug laboratory is different, and, depending on the cir-
cumstances, different actions should be taken in seiz-
ing and securing them.
Laboratory Deactivation
Law enforcement officials should not attempt to dismantle
a working laboratory without the help of qualified, trained
chemists. While the procedures may appear to be simple
and straightforward, the dismantling can often be complex
and dangerous if not done properly. The personnel who
dismantle the laboratory must be familiar with the chemi-
cals involved, their properties, and the drug manufacturing
processes. For example, extreme care should be taken if
any metal hydrides (i.e., lithium aluminum hydride which
ignites upon contact with water) are present. Before deac-
tivation, it is also necessary to determine that none of the
apparatus is booby-trapped.
Procedures for Deactivation
The following are some examples of procedures generally
used in laboratory deactivation. Since clandestine drug
laboratory deactivation is complex and potentially danger-
ous, a qualified chemist should assist law enforcement per-
sonnel in carrying out the process.
Examine the setup to determine whether process-
ing is occurring; if so, determine the type of
process (heating, cooling, etc.).
Some reactions involve a vessel that is heated on
the bottom and has a tap-water cooler on top. For
this type of arrangement, remove the heat and wait
until the glassware is cool to the touch before stop-
ping the water or turning off any stirrers or shak-
ers.
If vacuum or gravity filtration is occurring, allow
the process to conclude before shutting it down.
If fingerprints are desired, keep this in mind when
the apparatus is dismantled. If required, a finger-
print technician who has received clandestine
drug laboratory safety training may lift prints
when the area is safe and prior to moving any
equipment.
• If compressed gas is being fed into a reactor, it
should be shut off first by turning the main valve
at the top of the cylinder and then shutting off the
regulator valve at the side of the tank.
If a vacuum system is in use, it should be brought
to atmospheric pressure by slowly allowing air
into the system before turning off the vacuum
pump.
• If there is an exothermic (heat-producing) reaction
-------
GUIDELINES ON CLANDESTINE DRUG LABORATORIES
in process, allow it to continue to completion and
then cool to room temperature.
Once the laboratory has been deactivated, another set of
atmospheric measurements should be taken to determine if
the established safety criteria have been met (see Sidebar:
Conditions Requiring Ventilation During Seizure, page 9).
If the atmospheric safety criteria are not met, begin or con-
tinue ventilating and monitoring every half hour. Ventila-
tion should continue until the safety criteria are met. If this
is impractical, the next step, laboratory processing, can be
accomplished with Level B protection (SCB A). If appro-
priate, a certified agent or chemist may downgrade the level
of protection to Level C.
Processing
Processing of the clandestine drug laboratory includes
taking photographs with identifying labels, making a
complete inventory, taking evidentiary samples, and dis-
posing of the bulk chemicals and apparatus.
Photographs
• Photograph everything in place
- General overviews
- Close-ups
- Specific items during inventory
— Evidentiary samples and original containers
- Visible contamination
• Photograph site after removal of bulk materials
Inventory
• Inventory all equipment and paraphernalia present
in terms of:
- Quantity
- Size
— Manufacturer's serial number
— Condition
— Location
• Inventory all chemicals present for
- Type
- Concentration
— Quantity
• Describe unknown or unlabeled materials in terms
of
- Phase (Solid, Liquid or Gas)
- Color
- Volume/Mass
- Appearance
• Describe the type, size, condition, and labeling of
all containers
- Plastic, glass, metal
- Five-gallon, 2-ounce, etc.
- Punctured, rusty, leaking, corroded, damaged,
uncapped, bulging
- Label, markings, etc.
• Identify the location of leaking or broken containers
- Describe spilled solids or liquids, specifying
odor, color, appearance, location, size of spill,
etc.
• Identify leaking compressed-gas cylinders
Identify unstable container storage
Identify other concerns
Sample
• Take samples of appropriate items for evidence
One-ounce sample size usually sufficient
• Photograph samples and original containers with
identifying labels
• Maintain chain of custody
The DEA/USEPA Task Force recommends that certi-
fied safety-trained personnel from the law enforcement
agency prepare a contamination report (see Appendix
D), documenting this information, that will assist the
state lead agency in carrying out its site evaluation proc-
ess.
The findings of the contamination report are not intended to
imply that all contaminated sites have been located or that
the sites have been decontaminated. It is meant as an aid to
the subsequent cleanup process, if necessary.
You Need to Know
Disposal Contractor Qualifications
A USEPA and state, if applicable, identification
number
Controlled substances registration, if mandated
by the state
Availability of the appropriate vehicles, materi-
als, personnel
Reasonable response time
Use of a RCRA permitted or interim status
disposal facility that is in compliance
• The knowledge and experience necessary to
manage and dispose of the hazardous materials
properly
* The state environmental agency should assist in
selecting a qualified disposal contractor
10
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DEVELOPING A STATE OR LOCAL CLANDESTINE DRUG LABORATORY PROGRAM
You Need to Know
- ' I ^^^••^^^^•^^•••[^•Mililllii | -
FEDERAL HAZARDOUS WASTE GENERATOR AND TRANSPORTER REQUIREMENTS
The transportation of hazardous materials and hazardous wastes is regulated by the U.S. Department of Transportation (DOT), according to 49
CFR Parts 171,172,173,178, and 179. The U.S. Environmental Protection Agency (USEPA) also has regulations governing the generation and
transportation of hazardous waste in 40 CFR Parts 261,262, and 263. These federal regulations, as well as state regulations apply when
?et|[m'T9lfwastes^
u £ u Pr°9ram mav have requirementsgoverning hazardous waste that are more stringent than the federal requirements. The following steps
should be taken to ensure compliance with federal regulations. (A qualified contractor should be familiar with these requirements- therefore it
may be unnecessary for each law enforcement agency to learn them.)
Stept. Determining if a waste is hazardous:
Determine if the waste meets the definition of hazardous waste ac-
cording to 40 CFR 261. The waste may include "listed" wastes (F-
List, K-List, U-List, or P-List) or may exhibit one of the "character-
istics" of hazardous waste: ignitability, reactivity, corrosivity, or
kilogram of acute hazardous waste), then the USEPA generator
requirements in 40 CFR Part 262 apply, which includes Steps 2-
7 below.
toxicity.
The DEA/USEPA Task Force recommends, for reasons of ex-
pediency in site cleanup, that all chemicals and associated
glassware, equipment and contaminated materials in the labo-
ratory be managed as if they are hazardous wastes.
Depending on the waste code classification, the waste may be
subject to specific treatment standards prior to land disposal. The
Land Disposal Restrictions (LDR) are established in 40 CFR Part
268. Also, check your state's regulations governing hazardous
waste management. These regulations may be more stringent than
federal regulations.
If all materials are managed as if they are hazardous waste, go to
Step 2; if not, the following procedures must be followed:
Calculating Waste Quantities—Calculate quantities of acute and
non-acute hazardous waste. Again, check your state regulations
regarding hazardous waste. The quantities of hazardous waste will
determine how and where the waste must be disposed. The federal
requirements which may apply include the following:
AcuteHazardousWaste—The "P-List" in 40 CFR Part 261.33(e)
identifiescommercial chemical products classified as acute haz-
ardous waste and subject to the requirements and quantities
determinations of Part 261.5(e).
Conditionally Exempt Waste — If the total quantity of non-
acute hazardous waste on-site is less than 100 kilograms (and
the state also considers the small quantity generator waste con-
ditionally exempt), then 40 CFR Part 261.5 requirements may
apply. Conditionally exempt waste may be disposed of in a
facility licensed by the state to manage municipal or industrial
solid waste as described in 40 CFR 261.5(g)(3). (If all hazardous
waste on-site is conditionally exempt, Steps 2-7 are not re-
• quired.) (Reference 25>.
Greater than 100 kilograms—If the total quantity of non-acute
hazardous waste on site is greater than 100 kilograms (or 1
Step 2. Obtaining a USEPA ID Number
Call the USEPA Regional Office or state environmental agency for
a "Provisional EPA Identification Number." The number you are
given is site specific, for use only in connection with that site.
Step 3. Preparing Manifest and LDR Documentation
Manifest each shipment of hazardous waste for off-site shipment
according to 40 CFR Part 262 Subpart B (USEPA), and 49 CFR Part
172 and 173 (DOT) (see Appendix H).
Land Disposal Restrictions (LDR) requirements stipulate that a
notice and/or a certification must be prepared and included with
each shipment, if a restricted waste is intended for land disposal.
Step 4. Packaging
All hazardous waste must be packaged in accordance with DOT
regulations for off-site shipment (See 49 CFR Parts 173,178, and
179).
Steps. Marking
Hazardous waste for off-site shipment must be marked in accor-
dance with 40 CFR Section 262.32 (USEPA), and 49 CFR Part 172
Subpart D (DOT). In order to complete the manifest, you must
identify the DOT "proper shipping name" for all hazardous materials
,and hazardous waste (See 49 CFR Part 172 Subpart B and the
Hazardous Materials Table in 49 CFR 172.101); and identify the
hazard class and UN/NA ID number (see 49 CFR Part 172 Subpart
Caswellasotherrequirements). (See Appendix H for a completed
manifest.)
Steps. Labeling
Each package of hazardous waste must be labeled according to
DOT regulations (see 49 CFR Part 172 Subpart E).
Step?. Placarding
Each shipment of hazardous waste m ust be placarded, or the initial
transporter must be offered the appropriate placards, in accordance
with DOT regulations for hazardous materials (see 49 CFR Part 172
Subpart F).
Note: To ensure the safety of DEA employees and to provide forauniform, consistent policy, DEA contracts forthe services of a qualified hazardous
waste disposal company to safely and legally dispose of all non-evidentiary items as contaminated and, therefore treats them as hazardous wastes
DEA s policy requires that the hazardous waste disposal company incinerate, whenever possible, all hazardous waste to minimize potential liability
DEA recognizes the RCRAprovisions(40 CFR Part 261.5) for conditionally exempt small quantity generators; however, based on safety andliability
considerations, DEA elects to manage their hazardous waste under the more stringent generator requirements under RCRA (40 CFR Part 262) which
11
267-238 O - 90 - 2 : QL 3
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
Disposal of Contaminated Materials
After all pertinent evidence samples are collected, the other
chemicals, laboratory glassware and equipment should be
considered contaminated and disposed of properly. Appro-
priate health and safety protocols, as discussed earlier,
should be applied throughout the disposal phase.
Except for evidentiary samples, no glassware or equipment
should be retained by law enforcementpersonnel. If appro-
priate, a pretrial destruction order for such items should be
obtained with the search warrant (see Appendix E). After
evidentiary samples are removed from the clandestine drug
laboratory, the disposal contractor should be allowed ac-
cess to the laboratory for dismantling, packaging, marking,
labeling, transporting, storing, and disposing of aU remain-
ing laboratory and obviously contaminated materials.
The DEA/USEPA Task Force recommends that law en-
forcementagenciesalongwithstateenvironmental agen-
cies select a qualified disposal contractor to remove all
chemicals and associated glassware, equipment, and
contaminated materials from the clandestine drug labo-
ratory site (see Sidebar. Disposal Contractor Qualifica-
tions, page 10).
A law enforcement officer must be present to direct the
cnti re processing operatioa The contractor should prepare
manifests and adhere to all applicable federal, state, and
local laws and regulations (see Sidebar: Federal Hazardous
Waste Generator and Transporter Requirements, page 11).
Eitherthe disposal contractororthe law enforcementofficer
must sign the appropriate manifest forms for the disposal of
any hazardous waste. The disposal contractor or law en-
forcement officer may be given the authority to sign the
manifest onbehalf of the designated agency. Once the labo-
ratory has been processed and the disposal contractor has
left the site, the law enforcement officer prepares to exit the
laboratory site.
Exiting titie Site
Before exiting, the site must be secured and posted. The
posting should consist of a "hazardous materials" warning
sign which indicates that a clandestine laboratory was
seized at the location. The date of seizure should also be
included on the warning sign (see Appendix F). Alllaw en-
forcement personnel and reusable equipment should be de-
contaminated before leaving the site.
Follow-up
A notice of the raid and seizure must be sent to the properly
owner and/or rental agent by certified mail, with return
receipt; requested. Copies of the notice letter, the contami-
nation report, the drum packing lists, and a copy of the haz-
ardous waste manifest are also sent to the state and local
health and environmental protection agencies (see Appen-
dix G). These'notification letters should be sent within a
specified time frame established by the agency. In order to
expedite the notification process, oral notification proce-
dures may be implemented prior to written notification to
appropriate authorities.
The law enforcement agency's responsibilities regard-
ing the clandestine drug laboratory site end here.
Oversight of the cleanup of residual contamination
should be the responsibility of the state lead agency.
You Need to Know
What Information Should Be Reported To The NRC?
The watchstanders at the National Response Center
(1-800-424-8802) need concise and accurate informa-
tion. Be prepared to report as much of the following as
possible:
• Your name, address, and telephone number
• Name of the party or individual responsible for the
incident
• Mailing address of the site and/or responsible party
• Telephone number of the responsible party
• Nature of incident (i.e., clandestine drug laboratory
seizure)
• Date and time the incident occurred or was discov-
ered
• Name(s) of material(s) spilled or released
• Cause of the release
• Total quantity discharged
• Whether material was released to air, ground, water,
or subsurface
• Amount spilled into waterway (i.e., stream or sewer)
• Weather conditions
• Number and type of injuries or fatalities
• Whether evacuations have occurred
• Estimated dollar amount of property damage
• Description of cleanup action taken and future plans
• Other agencies that you have notified or plan to
notify immediately
• Type of assistance you require, if any (e.g., air
monitoring, emergency response).
12
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CLEANUP OF RESIDUAL CONTAMINATION
CLEANUP
OF
RESIDUAL CONTAMINATION
This section provides guidance for cleaning up residual
contamination remaining after the initial bulk disposal of
hazardous wastes which occurs as part of the seizure of a
clandestine drug laboratory. This includes the disposal or
decontamination of contaminated furnishings, building
materials, soil, etc.
The state lead agency should evaluate the site to determine
if residual cleanup actions are necessary.
What Is Typically Involved in the
Cleanup of a Clandestine Drug
Laboratory Site?
Because clandestine drug laboratories present a unique
and only recently recognized hazardous waste problem,
guidance documents for cleanup strategies at these types of
sites are not currently available. The guidelines offered
here are based upon the approaches used by USEPA and
state and local agencies in cleaning up hazardous waste
sites. References are cited in appropriate sections and
listed at the end of this document. Many can be readily ob-
tained through the National Technical Information Service
(NTIS), 5285 Port Royal Road, Springfield, VA 22161,
(703) 487-4600.
Few clandestine drug laboratory sites will pose a public
health or environmental risk justifying a response action
under Superfund. However, there may be residual con-
tamination which necessitates some degree of cleanup.
Therefore, USEPA and state and local guidance related to
hazardous waste site evaluation may be helpful.
In rare cases,^a raided site may pose an imminent and sub-
stantial hazard to the public health, welfare or environ-
ment, and require an emergency response. Such situations
would likely be discovered during the laboratory seizure.
Appropriate state agencies should be contacted as well as
the National Response Center (NRC) as stated on page 12.
It should be noted that federal notification requirements do
not supersede the requirements of appropriate state agen-
cies. Some states may, however, require that other agen-
cies are also notified.
Purpose of the Site Evaluation
The state lead agency should conduct a site evaluation.
Its purpose is to:
• ensure that problem sites are properly identified;
• determine whetheradditionalreleasesof hazardous
substances from the site, which could pose a
hazard or threat to the public health, may occur;
• determine the potential need for a residual cleanup
or decontamination action; and
• develop the necessary site data base in the event
that a serious long-term public health or environ-
mental threat exists.
The DEA/USEPA Task Force recommends that the
state lead agency (or appropriate state agency) respon-
sible for cleaning up clandestine drug laboratories
conduct a site evaluation, after notification by the law
enforcement agency, to determine the potential need
for a residual cleanup or decontamination action at the
seized clandestine drug laboratory site. This process
should commence within a specified time frame estab-
lished by the state lead agency.
Evaluation consists of compiling the necessary data to
compare with appropriate criteria to determine if a cleanup
action is necessary.
The National Oil and Hazardous Substances Pollution
Contingency Plan (NCP or National Contingency Plan, 40
CFR 300) describes in more detail the site evaluation
process. Also, USEPA has published several guidance
documents on the site evaluation process and documenta-
tion requirements (References 10 and 13 -16). These ap-
proaches can be scaled down to fit the requirements of a
particular clandestine drug laboratory site.
13
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
What Are the Steps in Conducting a Site
Evaluation?
The site evaluation strategy and necessary cleanup actions
identified during the site evaluation phase should be con-
ducted by trained technical personnel. Professionals who
may be of assistance include engineers, chemists, indus-
trial hygienists, and lexicologists.
The basic steps for conducting the site evaluation process
may include the following:
• Existing data - Collect and review existing data
from law enforcement agencies, the disposal con-
tractor and any other appropriate information
sources to characterize the operation, location and
population near the site. This should include haz-
ardous waste manifests and chemical inventory in-
formation compiled by the law enforcement agency
(i.e., Contamination Report, see Appendix D).
• Interviews - Interview any individuals (neighbors,
law enforcement, code enforcement officers, etc.)
who may be able to provide useful information on
site history.
• Perimeter inspection - Visually inspect the site
from the property perimeter to confirm or update
the data file with regard to site safety and potential
hazards.
• On-site survey/sampling - Identify suspected con-
tamination areas. Samples from potentially con-
taminated indoor and outdoor areas should be
taken and analyzed for hazardous chemicals.
Samples may include indoor air, dust deposits near
or on vents and vent fans, swipes of likely spills or
stained areas on floors, walls, ceilings, furniture
and appliances. Soil, surface water or groundwa-
ter, and vegetation samples should be taken if it is
suspected that outdoor dumping occurred. Proper
sampling technique and sample identification pro-
cedures should be employed. The types of chemi-
cal analyses to be conducted should be based on a
knowledge of the type of clandestine drug labora-
tory operation. If on-site sampling is undertaken,
the state lead agency may need appropriate au-
thorization to enter the property and take samples.
• Off-site survey/sampling - Identify surrounding
land use, population, and water supplies to deter-
mine who might be affected should hazardous
substances be released from the site. Identify sen-
sitive human populations or wildlife habitats. Ap-
propriate samples should be taken and analyzed if
there is reason to believe there was a release of
hazardous substances off-site. Possible sampling
areas are well water sources, surface water, con-
taminated areas of soil or vegetation, and areas
with high pedestrian traffic.
• Documentation - Document the results of the site
evaluation. Provide a detailed overview of the site
history, areas of contamination, nature and con-
centration of contaminants, toxicity and chemical
characteristics of the materials, possible routes of
chemical contamination, transport, and human
exposure, and any additional recommendations.
What Are the Primary and
Secondary Areas of
Contamination?
Typical locations of clandestine drug laboratories include:
• Private home—urban, suburban, rural
• Apartment
• Motel/hotel
• Factory, warehouse, or commercial building
• Mobile home or trailer
• Houseboat or ship
Campgrounds
• Other areas/vehicles
Primary and secondary areas of potential contamination at
these clandestine laboratory sites can be predicted based
on actual experience. Knowledge of these typical areas of
contamination will be useful in designing sampling proto-
cols and cleanup strategies. Primary areas of contamina-
tion are as follows:
• Processing ("cooking") areas near water or sewers
Causes: spills, boilovers, explosions, distillation,
extraction, and purification procedures
Specific items affected: floors, walls, ceilings,
glassware, containers, working surfaces, furniture,
drains, and vents
• Disposal ("dump"),areas
Indoors: sinks, commodes, bathtubs, floor drains,
vent fans, chimney flues, vents
Outdoors: soil, surface water (pond, stream, bay,
harbors, navigable waterways), groundwater (sur-
face or,artesian well), sewer or storm-water sys-
tem, septic system, cesspools, caves, mines
• Storage areas
Causes: spills, leaks
14
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CLEANUP OF RESIDUAL CONTAMINATION
Secondary areas of contamination may include:
• Locations where contaminationhas migrated (e.g.,
hallway where materials have been ca'nied on
shoes)
Atmospheric emissions: venting, air releases from
processing equipment
• Surfaces on which vented materials could be
deposited (e.g., curtains, blinds, light fixtures,
etc.)
Common ventilation systems in hotels/motels
The following conditions affecting the nature or extent of
contamination should also be considered:
• Fire - Products of incomplete combustion or con-
taminated ash materials may have been deposited
on various surfaces or structures.
Weather - Heat may increase volatilization, re-
sulting in the release of vapors or gases. Wind
may disperse dust or vapors which may increase
the probability of human exposure.
• Humidity - This will influence degradation and
deposition of various hazardous substances.
• Ground temperature and depth to the water table-
This may affect the volatilization rate of solvents
that have seeped into groundwater or soil, and
therefore influence indoor air concentrations in
basements or other rooms in a building.
What Are the Possible Courses
of Action?
In considering the need for residual cleanup or decontami-
nation actions at clandestine laboratory sites, it is likely
that primary emphasis will be placed onthe suitability of
the building structure for,rehabitation'or use. Whenthere
is sufficient/concern that a release or potential release of
hazardous substances threatens the public-health; welfare,
or the environment, the, designated state, lead, agency
should increase the scope of..the.evaluation.-as.necessary...
Justification for a more extensive site evaluation and sam-
pling-protocol would include instances in which signifi-
cant contamination of well water or groundwater from in-
diseriminant dumping of hazardous substances has oc-
curred. Furthermore, both acute and chronic health risks
to surrounding inhabitants, particularly sensitive popula-
tions such as children or the elderly, may require assess-
The most important things you should remember about
the investigation and seizure of a clandestine drug
laboratory are that:
1) Each clandestine drug laboratory is unique and
presents a variety of hazards.
2) Law enforcement personnel involved with clan-
destine drug laboratory programs need special
medical certification and regular medical monitor-
ing.
3) Law enforcement personnel need specialized
training regarding the investigation and seizure of
clandestine drug laboratories.
4) The clandestine drug laboratory raiding team
needs specialized equipment and training in its
use.
5) Only representative samples are needed for evi-
dence. All other materials, equipment, and glass-
ware should be disposed of for environmental and
health and safety reasons.
6) Only qualified hazardous waste disposal contrac-
tors should be'used to dispose of waste.
7) The proper state health, safety, and environ-
mental agency should be notified about the labo-
ratory seizure.
ment. Guidance for conducting, these more detailed as-
sessments are found in USEPA documents (References
17-20).
In addition to deciding on the type of cleanup response, the
lead agency should develop a Safety and Emergency Re-
sponse Plan which should be followed while performing
the cleanup. These plans should be developed on a site-
specific basis although they can be based on a generic
model. OSHA requirements are outlined in 29 CFR
1910.120 and standard operating procedures, guidelines
and factors to consider are found in NIOSH and USEPA
documents (References 21-23).
One of the following types of actions will generally be
appropriate:
No further action required
• Residual cleanup/decontamination
15
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GUiDELlNES ON CLANDESTINE DRUG LABORATORIES
No Further Action Required
This decision is made when it is determined that (a) the
corrcentrationofhazardoussubstancespresentinthesamples
taken from on-site and/or off-site are below federal or state
action levels, or (b) there is reasonable evidence to suggest
that contamination on-site or off-site does not pose either a
short-term or long-term threat to the public health, welfare
or to the environment.
Residual Cleanup/Decontamination
Actions
Residual chemical contamination in the building structure
or on the grounds around a clandestine drug laboratory site
may create a long-term health hazard and/or an odor prob-
lem. Additional cleanup activities may be necessary to
make the building suitable for rehabitation or use and to
reduce the health risk and aesthetic nuisance to local resi-
dents in the surrounding area.
The disposal of all wastes generated during the cleanup/
decontamination activities should be managed in compli-
ance with USEPA and USDOT regulations outlined on
page 10. Compliance with these regulations is the respon-
sibility of the party managing the cleanup/decontamination
activity.
Several approaches can be taken to reduce or eliminate
residual chemical contamination. With any method, proper
safety measures must be taken to protect workers from
exposure to dusts, vapors, gases, or liquids.
• Removal — The best approach is to remove, if pos-
sible, aU furnishings, draperies, carpeting, paneling,
wood trim, wallpaper, wallboard (anything easily dis-
mantled or disassembled) that have been contami-
nated. These materials should be disposed of through
a qualified disposal contractor either by incineration or
landfilling in properly permitted facilities. The proce-
dures for proper waste management outlined on page
lOshouldbefollowed. If removal methods are imprac-
tical, decontamination methods may be useful.
• Decontamination—Decontamination is the process of
physically removing the contaminant from the
contaminated object/material, limiting access to the
contaminant, or changing the chemical nature of the
contaminant to render it non-hazardous.
• Venting — Where solvents are slowly vaporizing in-
doors, proper ventilation and air monitoring/surveil-
lance techniques discussed in the "assessment" phase
will, in many cases, effectively reduce air concentra-
tions of vapors and decrease odor. Removal or wash-
ing the source may minimize the need for venting. The
decision to vent should be made with concern for
surrounding inhabitants and safety.
Neutralization—Where it is known that acids or bases
are the source of contamination (look for signs of cor-
rosion), neutralization with sodium bicarbonate solu-
tion for acids or weakly acidic wash solutions (e.g.,
vinegar, acetic acid) for bases, respectively, may be
useful. Use of strong alkaline or acidic wash solutions
on contaminated surfaces or objects may result in exo-
thermic reactions and the release of toxic fumes.
• Detergent-Water Washing—Nonporous surfaces, such
as floors and tiles, may be decontaminated with deter-
gent (or surfactant) and water solutions. Steam clean-
ing or high pressure washers may be useful for larger
areas of contamination.
• Encapsulating or Sealing — Where no other alterna-
tives are available, sealing the contaminated surface
with polyurethane, or with materials like those used to
contain asbestos may be considered.
In the event of outdoor contamination (i.e., soils, surfaceor
groundwater), several actions may be considered depend-
ing on the type and extent of contamination.
• Site control (i.e., restricted access using fencing, etc.)
• Removal of containers of hazardous materials that
were not discovered during entry, assessment or proc-
essing
Drainage control
Removal or treatment of contaminated soils and water
• Provision of alternative water supplies for those ex-
posed to contaminated wellwater
The presence of extensive outdoor contamination may
present a potential acute or chronic health hazard. Cleanup
strategies should be coordinated with state or local health
agency officials to ensure that the public health and welfare
are being addressed.
16
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TASK FORCE RECOMMENDATIONS
SUMMARY OF
JOINT DEA/USEPA
TASK FORCE
RECOMMENDATIONS
The Task Force recommends that:
1. Each state appoint a lead agency to assume responsibility for developing a comprehen-
sive clandestine drug laboratory program which addresses law enforcement and envi-
ronmental, health and safety concerns. The designated lead agency may wish to transfer
authority to local agencies which have the capability to respond to these situations.
2. Medical screening and specialized training programs (see Appendix B) be considered
an essential part of a clandestine drug laboratory program.
3. State and local law enforcement agencies require that their personnel wear protective
clothing, where appropriate, such as ballistic vests and fire retardant suits, when seizing
clandestine drug laboratories.
4. State and local authorities recognize that each clandestine drug laboratory is different,
and, depending on the circumstances, different actions should be taken in seizing and
securing them.
5. Certified safety-trained personnel from the law enforcement agency prepare a contami-
nation report (see Appendix D), documenting this information, that will assist the lead
state agency in carrying out its site evaluation process.
6. Law enforcement agencies, along with state environmental agencies, select a qualified
disposal contractor to remove all chemicals and associated glassware, equipment, and
contaminated materials from the clandestine drug laboratory site.
7. The lead state agency (or appropriate state agency) responsible for cleaning up clandes-
tine drug laboratories conduct a site evaluation, after notification by the law enforcement
agency, to determine the potential need for a residual cleanup or decontamination action
at the seized clandestine drug laboratory site. This process should commence within a
specified time frame established by the state lead agency.
17
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
REFERENCES
1 ACGIH (American Conference of Governmental
Industrial Hygienists), 1988. Threshold Limit Values
and Biological Exposure Indices for 1988 -1989,
ACGIH, Cincinnati, OH.
2 Baselt, R.C., 1982. Disposition of Toxic Drugs and
Chemicals in Man, 2nd Ed., Biomedical Publica-
tions, Davis, CA.
3 Clayton, G.D. and F.E. Clayton, (eds.), 1981.
Patty's Industrial Hygiene and Toxicology, 3rd Ed.,
John Wiley and Sons, New York, NY.
4 Gosselin, RJS., Smith, R.F., Hoage, H.C., and J.E.
Braddock, 1984. Clinical Toxicology of Commercial
Products, 5th Ed., Williams and Wilkins, Baltimore,
MD.
5 Klaasscn, C.D., Amdur, M.O., and J. Doull, 1985.
Casarett and Doull's Toxicology: The Basic Science
of Poisons, 3rd Ed., MacMillan Publishing Co., New
York, NY.
6 NIOSH Pocket Guide to Chemical Hazards, U.S.
Department of Health and Human Services, Public
Health Services, Centers for Disease Control,
National Institute for Occupational Safety and Health
(DHHS Publication No. 85-114), February, 1987.*
7 Sittig, M., 1985. Handbook of Toxic and Hazardous
Chemicals and Carcinogens, 2nd Ed., Noyes Publi-
cations, Park Ridge, EL.
8 Verschueren, K., 1983. Handbook of Environmental
Data on Organic Chemicals, Van Nostrand Reinhold
Co., New York, NY.
9 Windholz, M. (ed.), 1983. The Merck Index, 10th
Ed., Merck and Co., Rahway, NJ.
10 National Oil and Hazardous Substances Pollution
Contingency Plan, 40 CFR 300.*
11 Sitperfund Removal Procedures (Revision Number
Three), Feb., 1988. OSWER Directive 9360.03B,
U.S. EPA, Office of Emergency and Remedial Re-
sponse, Washington, DC.
12 Model Forfeiture of Drug Profits Act, U.S. DBA,
January, 1981, U.S. Department of Justice, Washing-
ton, DC.**
13 Preliminary Assessment Form Guidance, (U.S. EPA
Form 2070-12), Potential Hazardous Waste Site
Preliminary Assessment.*
14 Preliminary Assessment Guidance FY1988, (U.S.
EPA Document No. 934.0-01).*
15 Expanded Site Inspection Transitional Guidance FY
1988, (U.S. EPA Document No. 9345.1-02).*
16 Site Inspection Form Guidance (U.S. EPA Form
2070-13), Potential Hazardous Waste Site Report.*
17 Guidance for Conducting Remedial Investigations
and Feasibility Studies Under CERCLA, (Draft,
March 1988), Office of Emergency and Remedial
Response, Office of Solid Waste and Emergency
Response, U.S. EPA, Washington, DC.
18 Superfund Public Health Evaluation Manual, Office
of Emergency and Remedial Response, Office of
Solid Waste and Emergency Response (OSWER),
U.S. EPA, Washington, DC, October, 1986.*
19 Superfund Exposure Assessment Manual, Office of.
Emergency and Remedial Response, Office of Solid
Waste and Emergency Response, U.S. EPA, Wash-
ington, DC.*
20 U.S. EPA Toxicology Handbook, Principles Related
to Hazardous Waste Investigations, 1985.*
21 Standard Operating Safety Guide, 1988, U.S. EPA,
Office of Emergency and Remedial Response,
Washington, DC.*
22 Protecting Health and Safety at Hazardous Waste
Sites: An Overview, EPA/625/9-85/006, U.S. EPA,
Cincinnati, OH.*
23 Occupation Safety and Health Guidance Manual for
Hazardous Waste Site Activities (DHHS/NIOSH
Publication No. 85-115).*
24 The Report of the Oregon State Health Division's
Clandestine Drug Laboratory Committee "Chemical
and Toxicity Assessment of Illicit Methamphetamine
Manufacture," April, 1988.
25 Understanding The Small Quantity Generator Haz-
ardous Waste Rules: A Handbook for Small Busi-
ness, EPA/530-SW-86-019, Office of Solid Waste
and Emergency Response, U.S. EPA, Washington,
DC*
* These publications maybe obtained from the National Technical
Information Service (NTIS), 5285 Port Royal Road, Springfield,
VA 22161, (703) 487-4600.
** Contact the Office of Forensic Sciences, Attn: AFSH, Drug
Enforcement Administration, Washington, DC 20537.
18
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LIST OF ACRONYMS
LIST OF ACRONYMS
CFR Code of Federal Regulations
CERCLA....Comprehensive Environmental Response, Compensation and
Liability Act (Superfund)
DEA United States Drug Enforcement Administration
HSWA ..Hazardous and Solid Waste Amendments (amends the Resource
Conservation and Recovery Act)
LEL Lower explosive limit
MOU Memorandum of Understanding
NCP ....National Oil and Hazardous Substances Pollution Contingency
Plan; National Contingency Plan
NIOSH National Institute of Occupational Safety and Health
NFPA National Fire Protection Association,
NRC National Response Center
OSHA Occupational Safety and Health Administration
PEL Permissible exposure limit
PPM Parts per million
RCRA Resource Conservation and Recovery Act
SARA Superfund Amendments and Reauthorization Act
SCBA Self-contained breathing apparatus
TLV Threshold limit value
USCG.... United States Coast Guard
USDOT United States Department of Transportation
USEPA United States Environmental Protection Agency
19
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
GLOSSARY
AcutetOXidty. Adversehaaltheffectsresultingfromabriefiexposure
toachernicalsubstanceormixture. Theeffectsmayberexersible
or irreversible.
Anti-Drug Abuse Act. Public Law;(PL) 100-690. Section 2405.of
this act established the Joint Federal Task Force to address the
issue of hazardous waste contamination at clandestine drug
laboratories.
Assessment. Determination of immediate safety or health risks and
reduction, if possible, of any imminent hazards to law enforce-
ment personnel in later stages of the seizure operation.
By-product. Chemical substance remaining after synthesis of illicit
drugs that is formed'as-part of the chemical reaction.
Bulk Chemicals* Drums, containers, or .packages of precursors,
• reagents, solvents, by-products.or illicit drugs that should be
taken for evidence or removed to a permitted waste disposal
facility.
., Chronic tOXidty. Adversehealth effects resulting from continuous
or intermittent exposure- to low levels or doses of a chemical
substance or mixture over a long period of time (weeks to years).
Clandestine drug laboratory. Any operation that is engaged in
- the manufacture of illegal .drugs as defined in PL 91-513.
Clandestine laboratory safety program. A program developed
by the U.S. Drug Enforcement Administration to protect the
safety of its-investigators from the chemical hazards posed by
clandestine drug laboratories.
, Cleanup. As defined in these guidelines, the process(es) of removing
materials contaminated with hazardous substances, or decon-
- laminating their surfaces.
Combustible. A term used by the National Fire Protection Associa-
tioni(NFPA), Department of Transportation (DOT), and the Oc-
cupational Safety and Health Admiriistration (OSHA) to denote
substances that will burn, usually with-a flashpoint greater than
100 degrees F (38 degrees Celsius).
Condemnation. The legal act of declaring aproperty unfit for use by
the public.
Contamination report. Areportcompletedby thelawenforcement
agency during the planning, assessment and processing phases of
: the seizure operation that provides a summary of the types and
amounts of chemicals seized, and possible areas of the property
or surrounding area that might be contaminated.
Controlled Substances Act. Public Law 91-513. Provides the
legal basis for drug law enforcement in the United States and
establishes regulations and activities governing controlled sub-'
stances.
Controlled Substance analog. A chemical derivative of a known
illicit drug; "designer" drug.
Corrosive. Under RCRA regulations (40 CFR 261.22), a substance is
corrosive if itcorrodesmetal(e.g.,steel)under certain conditions,
or if it exhibits strongly acidic or alkaline pH that would enable
it to harm human tissue or aquatic life.
Deactivatlon. See "Dismantling."
Decontamination..-Sfhs process of removing chemical contamina-
" tion from surfaces by washing'or by chemical treatment.
Designer drugs. See "Controlled substance analog."
Dismantling. Deactivation of all chemical reactions and laboratory
activities after the assessment phase.
Disposal Contractor. An individual or company that is appropri-
ately qualified (or registered with the state, if necessary) to
dispose of hazardous wastes in approved facilities.
Draeger tube. A tube used in conjunction with a Draeger pump to
collect, andquantitateby color reactions, gas vapors in the atmos-
phere.
Dust. Suspension in air of fine particles or solids formed from grinding,
milling or other disintegration processes of a mechanical nature.
Emergency response. Theprocess, initiated by calling the National
Response Center (NRC), of evaluating, and if necessary, taking
^•actions to reducaor prevent the release of a hazardous substance
into the environment that may pose an imminent and substantial
threat to the public health or environment.
Entry. Apprehension and removal of clandestine drug laboratory op-
erators by law enforcement agents.
^Evidentiary samples. Samples of drugs and other items collected
• •' by acertified chemist at a clandestine laboratory site to be used
as£vidence againstthe perpetrator(s). S amples are taken prior to
bulk disposal of the chemicals and other materials.
Explosive. A material producing a sudden, almost instantaneous
release of pressure, gas, andheat when subjected to abrupt shock,
pressure or high temperature.
Exit. Final inspection of the laboratory after processing and posting of
the premises.
Explosimeter. An instrument that measures the concentration of a
-flammable gas or vapor as a percentage of the lower explosive
limit (LEL).
Flammable. Describes any solid, liquid, vapor or gas that will ignite
easily and burn. Flammable liquids are defined by DOT and
NFPA as those having a flashpoint of less than 100°F (38°C).
Flashpoint. The lowest temperature at which a substance gives off
flammable vapor to form an ignitable mixture with air near its
surface or within a vessel.
Follow-up. Notification of property owners and state and local health
agencies by the law enforcement personnel in charge that the
clandestine laboratory has been seized and posted.
Fume. A type of aerosol in which solid particles are formed by conden-
sation of particles from heated metals or other solids.
Gas. A thin, shapeless fluid, like air, capable of indefinite expansion,
but convertible by compression and cold into a liquid, and
eventually a solid. Gases exist naturally at 20 degrees Celsius.
Generator. Any person, by site, whose act or process produces haz-
ardous waste identified or listed in Part 261 of RCRA regulations
or whose act first causes a hazardous waste to become subject to
regulation.
21
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GLOSSARY
Hazardous Substance. Chemical substances, elements, mixtures,
orsolutions variously defined or listed under anumberof federal
and slate regulations. Some of the pertinent federal regulations
arc: CERCLA (Section 101, 102); RCRA (Sections 3001,
3002); TSCA (Section 7); Federal Water Pollution Control Act
(Sections 307 [a], 311[b] [2] [A]); and the Clean Water Act
(Section 112).
tla&irdOUS Waste. Ahazardous wasteasdefinedin40CFRPart261
of RCRA regulations or pertinent state regulations.
Ignttable. Defined under RCRA (40 CFR 261.21) as a solid waste
capable during routine handling of causing a fire or worsening a
fire once established. It includes liquids, nonliquids, com-
pressed gases (as defined under DOT regulations, 49 CFR
173.300) or an oxidizer (as defined under DOT regulations, 49
CFR 173.151).
Irritant. A chemical substance which produces reversible redness,
swelling or soreness when in contact with the skin or mucous
membranes.
Lead agency. A state-appointed agency (state or local) responsible
for supervising, coordinating and facilitating the cleanup of
clandestine drug laboratories, within the given state, in coopera-
tion with law enforcement personnel.
Level A protection. The level ofprotectiveequipmentinsituations
where the material is considered acutely vapor toxic to the skin •
and hazards arc unknown.
Level B protection. The level of protective equipmentin situations
where the environment is not considered acutely vapor toxic to
Ihe skin but may cause respiratory effects.
Level C protection. The level of protective equipment required to
prevent respiratory exposure but not to exclude possible skin
contact.
Level D protection. The level of protective equipment required
when the atmosphere contains no known hazard, when splashes,
immersion, inhalation, or contact with hazardous levels of any
chemical is precluded.
Lower explosive limit (LEI). Refers to the lowest concentration
of gas or vapor (% volume in air) that will bum or explode at
ambient temperatures if an ignition source is present
Manifest. The Uniform Hazardous Waste Manifest, USEPA Forms
8700-22 and 22A (40 CFR Part 262).
Notification letter. Letters from law enforcement or health agen-
cies to appropriate parties regarding the status-of a clandestine -
laboratory site relative to legal and health/safety issues;
On-SCene coordinator. Personnel of the USEPA and USCG who
respond to emergencies involving the release of hazardous sub-
stances that may endanger the public health or environment.
Organic Vapor analyzer. A device that detects the presence and
concentrations of organic vapors in the air thatmay pose an acute
health or safety hazard.
Personal protective equipment. Various types of clothing (e.g.,
suits, gloves, hats, boots) or apparatus (i.e., face masks, respira-
tors, radios, etc.) designed to prevent inhalation, skin contact or
ingestionof hazardous chemicals. Various "levels" of protection
have been developed to protect individuals who may be exposed
to different degrees of adverse health risks.
Planning. The preliminary stage of a clandestine drug laboratory
seizure which includes surveillance and assessments of Ihe
hazards present in order to develop the safest strategy for entry
of the laboratory.
Precursor. A chemical substance required for the synthesis of an
illicit drug and which is ultimately incorporated into the drug
structure. Some precursors are hazardous in their own right, and
are regulated through federal and state substance abuse laws.
Processing. The stage of a seizure operation in which evidence is
gathered and bulk chemicals are disposed of through a licensed
disposal contractor.
Public health evaluation. A process used by US EPA,, stale or
local public health agencies to ev aluate the risk of adverse health
effects (i.e., carcinogenic; noncarcinogenic) to humans by haz-
ardous substances.
Reactive. Under RCRA (40 CFR 261.23), reactive substances are gen-
erally those that are normally unstable and have a tendency to
react violently with water or explode during handling. Explo-
sives, as defined under 49 CFR 173.51,173.53, or 173.88 are also
included in this definition.
Reagent. A chemical required for the synthesis of an illicit drug
substance but which is not incorporated into the final chemical
product.
Removal. The process of physically disposing of chemical contami-
nants or chemically-contaminated objects to a specially-permit-
ted disposal facility, as required under RCRA.
Residual contamination. Small amounts of chemical contamina-
tion thatremain inside the laboratory or on the grounds surround-
ing the site thatmay pose a public health or environmental risk.
Seizure. The act of taking control of a clandestine drug laboratory
which involves planning, initial entry, assessment, processing,
exit, and follow-up.
Solvent. An organic liquid used in various chemical reactions or
extraction procedures to dissolve or separate precursors, rea-
gents or drug substances, but which is not incorporated into, the
final product.
Superfund reniO VOl Site. A site where the USEPA has determ ined
that releases or potential releases,of hazardous substances pose
a threat to the public health and/or environment and which has
been designated eligible for federally-funded cleanup through
CERCLA.
ToXlClty. The quality or degree of being poisonous or harmful to plant,
animal, or human.life as the result of exposure (ingestion, inha-
lation, or skin contact) to ahazardous chemical, mixture, onillicit
drug. The characteristic of EP toxicity is defined in 40 CFR
261.24.
Vapor. The gaseous state of a material suspended in air that would
otherwise be a liquid or solid at 20 degrees Celsius and normal
atmospheric pressure. Examples are benzene and iodine.
22
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX A
Chemical Properties and Health Hazards Associated with Chemicals Commonly Found at Clandestine Drue
Laboratory Sites. Tables were adapted with permission of the Oregon State Health Division (see Reference 24).
TABLE A-l CYANIDES
Substance
Sodium Cyanide
Potassium Cyanide
Benzyl Cyanide
Hydrogen Cyanide
Form
Solid
Solid
Liquid
Gas, Liquid
EPA Hazardous DOTUN/NA
Exposure Waste Numbers* ID Numbers
Skin, Eyes, Ingestion P106 UN 1689
Skin, Eyes, Ingestion P098 UN 1680
Skin, Eyes, Inhalation, Ingestion
Inhalation P063
Health Effects:
Highlytoxicsubstances. If solid cyanide salts come in contact with acid, hydrogen cyanide gas will bereleased. Inhalation
of hydrogen cyanide may result in rapid progression of symptoms to respiratory failure, coma and death. Ingestion of
the salts may also lead to these symptoms, but hydrogen cyanide gas poses the greater exposure risk
TABLE A-2 IRRITANTS AND
Substance
Acetic Acid3
Acetic Anhydride3
Acetyl Chloride
Ammonia (anhydrous)
Ammonium Hydroxide
Benzyl Chloride3
Dimethylsulfate
Formaldehyde
Formic Acid
Hydrogen Chloride/
Hydrochloric Acid
Hydrobromic Acid
Hydriodic Acid
Hydroxylaminea'b
Methylaminea
Methylene Chloride3
I f^tf^n t r\vf\r\^s*t-V\r*'*\s* -wmt-l^-r -,1 A« *+. J
CORROSIVES
Form
Liquid
Liquid
Liquid
Gas
Liquid
Liquid
Liquid
Gas, Liquid
Liquid
Gas, Liquid
Liquid
Liquid
Liquid, Solid
Gas, Liquid, Solid
Liquid
Exposure
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
EPA Hazardous DOTUN/NA
Waste Numbers* ID Numbers
UN 2790
UN 1715
U006 UN 1717
UN 1005
NA 2672
P026 UN 1738
U103 UN 1595
U122 UN 1198
U123 UN 1779
UN 1789
UN 1788
UN 1787
U080 UN 1593
Methyl Methacrylate Liquid
Nitroethane3-13 Liquid
Oxalylchlorideb Liquid
Perchloric Acide Liquid
Phenylmagnesium Bromide3-1' Liquid
Phosphine3 Gas
Phosphorus Oxychloride Solid
Phosphorus Pentoxide Solid
Sodium Amide (Sodamide)b Solid
Sodium Metal a-b
Sodium Hydroxide
Sulfur Trioxide
Sulfuric Acidf
Tetrahydrofurana-b
Thionyl Chloride
* Refer to 40 CHR 26133 for a detailed listing.
Solid
Liquid, Solid
Liquid, Solid
Liquid
Liquid
Liquid
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes
Skin, Eyes, Inhalation
Skin, Eyes
Skin, Eyes
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
23
U162 NA 1247
UN 2842
UN 1873
P096 UN 2199
UN 1810
UN 1425
UN 1428
UN 1823,1824
UN 1829
UN 1830
U213 UN 2056
UN 1836
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APPENDIX A
TABLE A-2 IRRITANTS AND CORROSIVES (CONT.)
Health Effects: Vapors of volatile corrosives may cause eye irritation, lacrimation, conjunctivitis and corneal injury.
Inhalationmay cause irritation of mucous membranes of the nose and throat, and lung irritation resulting in cough, chest
pain, and shortness of breath. Pulmonary edema, coughing up of blood, and chronic lung disease may occur in severe
cases High concentrations of vapor may cause skin irritation. Additional symptoms of vapor inhalation may include
hcadachefnause^dizzinessandanxiety.Phosphinemaydetonat^and has theodor of decayingfish. Direct contact with
corrosivesmayresultmsevereeyeorskmbums.Mernylm^
sensitization Formaldehyde is a suspected human carcinogen. Formic acid ingestion or inhalation may result in kidney
or Uver.damage. Sodium metal reacts violently with water. Tetrahydrofuran and Perchloric Acid can form explosive
crystals.
« Flammable d Uninhibited
b Explosive e>50% but <, 72% strength
e Flash Point < 141° F f Unspent
TABLE A-3 SOLVENTS
Substance Form
Acetone* Liquid
AcGlonitrile* Liquid
Aniline Liquid
Benzene* Liquid
Benzylchloride* Liquid
Carbon Tetrachloride Liquid
Chloroform Liquid
Cydohexanonea-d Liquid
Dioxane* Liquid
Ethanol* Liquid
Ethyl Acetate* Liquid
Ethyl Ether*-6 Liquid
Freon 11 Liquid
(trichloromonofluoromethane)
Hexane* Liquid
Isopropanol* Liquid
Methanol* Liquid
Methylene Chloride Liquid
(dichloromethane, methylene dichloride)
Petroleum Ether" Liquid
Pyridine* Liquid
Toluene* Liquid
o-Toluidine"-1' Liquid
•Refer to 40 CFR26133 fora detailed listing.
Exposure
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
EPA Hazardous
Waste Numbers*
U002
U003
U012
U019
U211
U044
U057
U108
U112
U117
U121
U154
U080
U196
U220
U328
DOT UN/NA
ID Numbers
UN 1090
NA 1648
UN 1547
UN 1114
UN 1738
UN 1846
UN 1888
UN 2896
UN 1165
T TN. Til T f\
UN 1170
UN 1173
UN 1155
UN 1208
T TN. T "1 1 1 C\
UN 1219
UN 1230
UN 1593
UN 1271
UN 1282
UN 1294
Health Effects:
Inhalation of vapors at low concentrations may result in mild eye, nose and throat irritation. Symptoms of intoxication
(drowsinessandincoordmation)orlossofconsdousnessrmyoccurathighconcentrations. Liverandkidneyimpairment
rnayalsooccurathighdoses,or with prolonged exposure. Berizene is a known human cardnogen. Chloroform carbon
tetrachloride,dJoxane,o-toluidine,andmemylenechlorideareprobablehumancarcinogens.SPinmgoffreononthesb
rnayresultinfreezinginjury. Ingestion of small amounts of methanol may lead to permanent damage:to vision. Aniline
can be readily absorbed through the skin and may cause mental confusion and decreased blood hemoglobin by all
exposure routes. o-Toluidine is highly toxic when absorbed through the skin, inhaled as a vapor, or ingested, causing
possible kidney injury.
* Flammable
b Explosive
c Ethers may form explosive peroxides
d£ 50% peroxide
24
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
TABLE A-4 METALS/SALTS
Substance
Aluminum Chloride
MagnesiumM
Palladium
Red Phosphorus13
Iodine
Mercuric Chloride
Lead Acetate
Lithium Aluminum Hydridea/b
Lithium Hydroxide
Potassium Hydroxide
RaneyNickela'b
Sodium Hydroxide
Sodium Metala-b
Potassium Metala-b
Thorium Saltsc
Form
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid in kerosene
Solid in kerosene
Solid
Exposure
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
Skin, Eyes
EPA Hazardous DOT UN/NA
Waste Numbers* ID Numbers
UN 1726
UN 1869
UN 1624
UN 1616
UN 1410
UN 1813
UN 1823
UN 1428
UN 2257
UN 2976
f Refer to 40 CFR 261.33 for a detailed listing. Currently, none of these possess EPA Waste Numbers.
Health Effects:
Most metals and salts are stable solids with minimal potential for exposure unless ingested or the metal is present in the
air as dust or fumes, if heated. Sodium and potassium metal, and sodium and lithium hydroxides are extremely corrosive
in the presence of moisture. Lithium aluminum hydride, and sodium, magnesium and potassium metals are extremely
reactive with air and water and can ignite or explode. (Hydrogen gas may be liberated which is explosive.) Thorium is
an alpha-emitting radioactive material. Flu-like symptoms and possible lung damage may result from breathing metal
fumes. Acute overexposure to lead or mercury salts may lead to nausea and vomiting, and long-term exposure can affect
the central nervous system. Hematologic and neurologic complications and kidney damage may occur with chronic ex-
posure to mercury salts. Red phosphorus, if contaminated with white phosphorus, may explode on contact, or with
friction or heat, but is relatively nontoxic by ingestion.
a Flammable c Radioactive
b Explosive d Magnesium metal (powder, pellets, turnings on ribbon)
TABLE A-5 OTHER HAZARDOUS PRECURSORS, SOLVENTS, REAGENTS, DRUG PRODUCTS AND BY-
PRODUCTS FOUND IN CLANDESTINE DRUG LABORATORIES
Substance
Form Exposure
Health Hazard
Cyclohexanone
Fentanyl
Hydrogen
Lysergic Acid Diethylamide
MPTP, MPPPa
Methylfentanyl
Phenylacetic Acid
Phenyl-2-Propanone
(phenylacetone)
Piperidine
a MPTP (l-methyl-4-phenyl-l, 2,
Liquid Skin
Solid Inhalation, Skin, Eyes
Gas Inhalation
Powder Ingestion, Inhalation
Solids Inhalation, Skin
Solid Inhalation, Skin, Eyes
Solid Skin, Eyes
Liquid Skin, Inhalation
Irritant
Narcotic drug product causing respira-
tory failure at extremely low doses (i.e.,
equivalent to a few grains of dust)
Flammable, Explosive
Hallucination at extremely low doses
By-product or intermediates of alpha-
prodine laboratories. (Extremely low
doses may cause irreversible Parkinson's
disease.)
See "Fentanyl"
Irritant
Irritant; few toxicity data available
Liquid Skin, Inhalation Irritant; few toxicity data available
3,6-tetrahydropyridine); MPPP (l-methyl-4-phenyl-4-propionoxypiperidine)
25
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8
APPENDIX B
DEA's Clandestine Laboratory Safety Certification Program consists of the following schools:
1. Clandestine Laboratory Investigative School
2. Clandestine Laboratory Safety School
Each of these schools is approximately one week in length; the Investigative School is a prerequisite for at-
tending the Safety School.
CLANDESTINE LABORATORY INVESTIGA-
TIVE SCHOOL CURRICULUM (25-36 Hours)
Course Title
Introduction to & History of
Clandestine Laboratories
Initiation and Development of
Clandestine Laboratories
Role of the Chemist
Role of the Prosecutor
Search Warrants
Raid Planning
Laboratory Syntheses
Financial Aspects
Bombs and Booby Traps
Drug Analogs
Hours
6-8
1-2
1-2
2-4
1-2
6-8
1-2
3-4
2
CLANDESTINE LABORATORY SAFETY
SCHOOL CURRICULUM (31-36 Hours)
Course Title Hours
Basic Toxicology . 2
Chemical Hazards 1.5
Physical Hazards 1.5 -
Air Monitoring 2
Hazard Assessment 2
Work Practices/Personal Hygiene 0.5
Protective Clothing & Equipment 1.5
Respiratory Protection 2
Chemical Handling 1.5
Site Control 1.5
Practical Exercise - Air Monitoring 2
SCBA Demonstration 1
First Aid at Clandestine Laboratory Sites 3
EPA Regulations - 1-2
Field Exercises 8-12
Air Monitoring
Respiratory Fit Test
Fire Suppression
Smoke Room
Mock Clandestine Laboratory
Decontamination
For your information, DBA has also developed the
Advanced Clandestine Laboratory Safety School in
response to the OSHA requirement for 8 hours 'of
annual refresher training which an individual needs
to maintain in order to enter hazardous laboratory
sites.
ADVANCED CLANDESTINE LABORA-
TORY SAFETY SCHOOL CURRICULUM
(28-32 Hours)
Course Title
Review of Clandestine Laboratory
Safety School
SCBA Review
Air Monitoring Review
SCBA Instrument Lab
3-4
3-4
4
Gas Tech 1314/Draeger Instrument Laboratory 5-6
Advanced Safety 5-6
Toxicology
Levels of Protection
Decontamination
Hazard Communication
Hazardous Waste Manifesting/Bill of Lading 2
Waste Management 1
Hazardous Waste Containers 1
Clandestine Laboratory Raid Vehicles 1
The Clandestine Laboratory Program Managers
may be contacted at the following address:
DBA/FBI Academy
Bldg 12 TRDF
Quantico, VA 22135
27
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX C
Letter to Physician for Medical
Certification of State and Local Officers
and Clandestine Laboratory Safety Certification School
Suggested Guidelines for Medical Certification
Dear Doctor:
The purpose of this medical examination is to obtain a medical clearance for work during seizure of illegal drug labo-
ratories in compliance with the worker protection rule for hazardous waste operations and emergency response (29
CFR 1910.120). In addition to traditional law enforcement activities, the examinee will be required to use personal
protective equipment for protection from chemical exposures.
The personal protective equipment, workplace and environmental factors of concern are described below. Suggested
guidelines for the medical evaluation are attached.
Protective Equipment: Will use a twin cartridge, full face mask, air purifying MSA Ultra twin respirator, and an
MSA Airpac (pressure demand, open circuit) self contained breathing apparatus. Will use neoprene boots, chemi-
cally resistant gloves, and a chemically resistant (vapor barrier) suit of Tyvek or Saranex.
Type of Work: Includes pursuit, confrontation, control and arrest of suspects which may involve strenuous physical
activity. Includes light to moderate exertion while wearing personal protective equipment with increased work of
breathing, cardiovascular stress and heat load. Includes responsibility for the safety of others and responsiveness in
rescue and emergency, situations. Such work may be done daily or once a month or less, up to 8 hours at a time.
Work Setting: Work in uncontrolled, poorly ventilated, makeshift laboratories with unidentified chemical processes
in progress. Potential for fire, explosion and chemical spills likely. Potential for exposure to organic solvents,
inorganic acids and alkalis, cyanides, other drug precursors, unknown chemicals, reactants, and by-products of
chemical reactions, controlled substances in solution or powdered form. Includes work indoors, and outdoors in
extremes of seasonal environmental temperatures and humidity. Prior acclimation to hot environments is unlikely.
If there are any abnormalities such as cardiovascular or respiratory conditions, musculoskeletal problems, lapses of
consciousness, sensitivity to heat injury, or other medical conditions that would present an unusual risk of harm to
the individual or to others in performing these duties, please notify me as soon as possible.
If you find the individual cleared for performing the duties described above, please sign and date the certification
below and return it to me. Thank you for your help.
Sincerely Yours,
Chief Medical Officer
I examined
on
Medical Certification
and
(Name) (Date)
find the individual to be medically able to perform the duties described above without unusual medical risk of harm
to the individual or others.
Physician's Signature.
Physician's Name
Date
29
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APPENDIX C
Clandestine Laboratory Safety Certification School
Suggested Guidelines for Medical Certification
The following elements are suggested for'the initial medical evaluation of individuals who are to be consid-
ered for a medical clearance to work in clandestine drug laboratories. Additional elements may be added
based on local considerations.
I. General Medical History:
History of current complaints and illnesses, if any.
Review of systems: special emphasis on the skin, respiratory, cardiovascular and neurologic systems.
Questions about use of respirators and protective gear, including problems with their use and history of
claustrophobic reactions.
History of heat injury.
Medications, smoking history, alcohol use.
Reproductive history.
Exercise Capacity.
Occupational and Exposure History.
n. General Medical Examination:
Vital signs. Examination with emphasis on the skin, respiratory, cardiovascular, hepatic and neurologic sys-
tems.
ffl. Laboratory Tests:
CBC.
Blood chemistries that include kidney and liver function tests.
Urinalysis.
IV. Other Tests:
Spirometry, including FVC, FEV, and FEF 25-75 conforming to NIOSH Standards.
Resting 12 lead electrocardiogram.
Exercise stress test, chest radiograph and other medical tests if medically indicated.
30
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX D
Contamination Report
A. LABORATORY TYPE AND HAZARDS
Laboratory Type (Check)
nMethamphetamine r~| Amphetamine
~ Cocaine ~ Fentanyl
~P2P - POP
JLSD [j Other (Specify)
Production Method:
Potential Chemical
n Respiratory Tox.
Systemic Tox.
External Tox.
~ Carcinogens
~ Corrosives
Specific High Hazai
Hs
d
izards (Check)
Flammables
Explosives
Oxidizers
Pyrophorics
Water Reactives
Chemical:
Other Potential He
Q Com Gas Cyldr T
Heat Stress
~ Cold Stress
Confined Space "
Limited Egress
Poor Visibility
Other:
izards (Check)
T Slip/Trip/Fall Haz.
Electrical Shock
Burn Hazard
Leaking Containers
Damaged Structure
Excavation
B. SITE DESCRIPTION
LABORATORY ADDRESS
SITE LOCATION AND DESCRIPTION
STRUCTURE DESCRIPTION
Location of Laboratory Processing Area
(i.e., kitchen, bathroom, basement, etc.)
Estimated Laboratory Size
Small Med.
.Large
• Approximate square footage
C. HAZARD ASSESSMENT FINDINGS
LEL
% OXYGEN
PPM
LOCATION IN LABORATORY
INDICATOR TUBES
Check any used
RESULTS
(circle)
Factor
COLOR (changed to) LEVEL PPM X Conversion
Adjusted
Reading
Maximum
Value
Acetic Acid -
Acetone -
Benzene -
Carbon Disulfide -
Ethyl Acetate -
Formic Acid •
Hydrocyanic Acid
Methanol -
O-Toluidine -
Trichloroethane -
Triethylamine -
D. COMMENTS (Include additional information, such as poor walking surfaces, limited work space, obstacles, limited egress, etc.]
31
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APPENDIX D
SECTION E. POSSIBLE CONTAMINATION FOUND INDOORS:
floors
walls.
ceilings.
Attach diagram of indoor area, indicating where contamination was found.
SECTION F. POSSIBLE CONTAMINATION FOUND OUTDOORS:
soil
vegetation.
pools, lakes or streams.
pavement.
Attach diagram of outdoor area, indicating where contamination was found.
SECTION G, INVENTORY: inventory containers of chemicals, including container type, size, contents (write "UNK"
if unknown) and describe color or appearance of contents, and if possible volume of mass. Include compressed
gas cylinders, and include equipment and paraphernalia present.
Attach a copy of the hazardous waste manifests and drum packaging lists used to ship chemicals and
contaminated materials from the site.
DISCLAIMER: The information provided on this form has been provided by law enforcement personnel not formally trained in environmental health and
safety site evaluations. This information may be incomplete, and the law enforcement agency does not guarantee its accuracy.
INSTRUCTIONS
SECTION A LABORATORY TYPE AND HAZARDS
Laboraioiy Type: Write in the production method if known or suspected (example: methamphetamine via red phosphorus/hydriodic acid).
Potential Chemical Hazards: last any specific highly hazardous chemicals known or suspected of being present (example: ether, thionyl
chloride, red phosphorus, etc.)
Other Potential Hazards: Check all boxes indicating known or suspected hazards. list any other known or suspected hazards (example: low
overhead, unstable container storage, booby traps, etc.)
SECTIONS SITE DESCRIPTION
Site Location and Description: (Example: detached garage 10 yards from house, outside storage shed near rear door of main building).
Structure Description: Physical description i.e., size, shape, type, condition, etc., (example: 10' x 10' wood barn, no windows; small warehouse,
fire damaged wilh opposing roll up doors).
SECTION C HAZARD ASSESSMENT FINDINGS. During initial assessment, measure and record findings as indicated.
LEL - (Lower explosive limit level) (Example: 1%, 15%, etc.)
% Oxygen - (percent oxygen) (Example: 21%, 18%, etc.)
PPM-(pans per million) (Example: 100 ppm, 350 ppm)
Location in the lab - Describe each location where a series of three measurements were taken. (Example: front door, southeast corner ol
bathroom)
Indicator Tubes (If available and if situation warrants their use) - Check name of each tube to be used/tested.
After the test, circle+for color changes, and circle - for no color change.
Describe color change (example: dark brown, etc.).
Record the ppm level reading from tube. ....
Write in the conversion factor, if necessary, according to instructions with the tubes for substances related to those for which the tube is speciti-
cally designed (Example: 2.3,4).
Calculate an adjusted reading, i.e., ppm x conversion factor (example: 100 ppm x 2 = 200 ppm)
SECTION D COMMENTS - include additional information, such as poor walking surfaces, limited work space obstacles, limited egress, etc.)
SECTIONS E & F DESCRIBE the contamination found in each of the areas listed (Example: odor, color, solid/liquid, etc.) and estimate the extent (Example:
3 feet by 5 feet) where possible.
SECTION G INVENTORY - self explanatory.
32
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX E
Sample Pre-Trial Destruction Order
Based upon my training and experience, I believe that a search warrant of property located at
will result in the seizure of numerous dangerous and toxic chemicals, as well as
contaminated glassware and equipment. Preservation of these items would pose a high risk of
explosion and contamination of other evidence in holding facilities, as well as danger to the seizing
officers and eventually the evidence custodians. I seek, by this affidavit, an order authorizing
destruction of any toxic or dangerous chemicals, contaminated glassware, and equipment found on
the premises.
Samples of suspected controlled substances will be preserved for evidentiary use, testing, and
analysis.
33
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APPENDIX F
APPENDIX F
WARNING WARNING WARNING
A clandestine laboratory for the
manufacture of illegal drugs and/or
hazardous chemicals was seized at
this location on (Date)
Known hazardous chemicals have
been disposed pursuant to law.
However, there still may be hazardous
substances or waste products on this
property, either in buildings or in the
ground itself. Please exercise caution
while on these premises.
Name
Address
Phone Number of the
Law Enforcement
Agency
Agency Logo
WARNING
35
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX G
Draft Notification Letter to Health, Law
And Environmental Agencies
Date:
Name
Address
Dear Sir or Madam:
This letter is to advise you about the search of the property located at
(Address Including Zip Code), on (Date of Seizure). A clandestine drug
laboratory was seized and hazardous chemicals and/or wastes were found at the
said property. Hazardous chemicals and substances were seized by (Agency
Making Seizure) and have been disposed pursuant to existing federal and/or
state laws.
The person(s) arrested on the property was/was not the legal owner of the
property where the clandestine laboratory was seized. Our investigation
revealed that (Full Name of Legal Owner) of (Address and Zip Code of
Owner of Property) is the legal owner of the property. On (Date), we sent
(Name of Owner) a certified letter informing of the above seizure (copy
attached). This letter serves as a warning that there may still be hazardous
substances or waste at or on the property. Attached to this letter is a contami-
nation report with copies of the manifest and drum packing list, which will
assist your office in conducting a site evaluation to determine appropriate
measures to further protect health and the environment.
Sincerely yours,
Authorized signature
Title of authorized person
Attachments
37
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APPENDIX G
Draft Notification Letter to Property Owner
Date:
Name
Address
Dear Sir or Madam:
This letter is to advise you, as a legal owner of the property known as
_, that on
., as a result of the search of your property, a clan-
destine drag laboratory was seized, and/or hazardous chemicals were found at
said property. Known hazardous chemicals and substances were seized by the
government and have been disposed pursuant to existing federal and/or state
laws.
This letter also serves as a warning that there may still be hazardous substances
or waste products at or on your property.
Sincerely yours,
Authorized signature
Title of authorized person
Name of Law Enforcement Agency
38
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX H
.Call EPA for Provisional No.
UNIFORM HAZARDOUS
WASTE MANIFEST
1 Generator's US EPA ID No.
lanltest
Document No.
C|A|T| l|2|3|4l5|6|7|8|9|l|2|3l4l
2. Pagel
of.
3. Generator's Name and Mailing Address
Anyplace State Police
111 State Street, Hometown, CA 00932
4. Generator's Phone
A. State Manifest Document Number
87133329
B. State Gererator's ID
H|Y|H|A|8|3| 8J 9| 1\ 1\2\
5. Transporter! Company Name
Anyplace Environmental Management Corp.
6. US EPA ID Number
c| A| D| 9\ 8\ 0\ 8\ 4| l| S\ 3
C. Slate Transporter's ID 60 01
D. Transporter's Phone 916/985-6666
7. Transporter 2 Company Name
8. US EPA ID Number
E. State Transporter's ID
F. Transporter's Phone
9. Designated Facility Name and Site Address 10. US EPA ID Number
Anyplace Environmental Management Corp.
11855 White Rock Rd.
G. State Facility's ID
ClAlDl9 18 I 8 I 8 14 11 I 8 13
1 L1 l.l..l.JlluJ ' ' ' > ' '
|C|A|
R racili
Smithville, CA 95670
ClAlD 19 18 10 18 14 11 |8 13
ility's Phone
916/985-6666
11. US DOT Description (including Proper Shipping Name, Hazard Class, and ID Number)
12. Containers
13. Total
Quantity
14.
Unit
Wt. Vol.
Waste No.
R.Q., Waste Ethyl Ether, (D001)
Flammable Liquid, UN 1155
212
00
Waste Poison B, Solid, N.O.S.,
Poison B, UN 2811
State
331
300
EPA/Other
EPA/Other
EPA/Other
J. Additional Descriptions for Materials Listed Abow
^^^
11. b. contains ephenrlne
K. Handling Codes for Wastes Listed Above
a. b.
15. Special Handling Instructions and Additional Information
Inhalation hazard - wear proper respirator
Avoid skin contract - wear boots, gloves, goggles
Additional Information: These materials were seized by State Police at a Clandestine Drug Laboratory located at
16.
GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and
are classified, packed, marked, and labeled, and are in all respects in proper condition fortransport by highway according to applicable-international and national
government regulations.
If 1 am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be
economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present
and future threat to human health and the environment; OR, if I am a small quantity generator, I have made a good faith effort to minimize my waste generation and
select the best waste management method that is available to me and that I can afford.
Printed/Typed Name John Jones, «on behalf of
Anyplace State Police"
Signature
Month Day Year
1° I5 I1 I8 Is 19
17. Transporter 1 Acknowledgement of Receipt of Materials
Printed/Typed Name
Signature
Month Day Year
I I I I I
18. Transporter 2 Acknowledgement of Receipt of Materials
Printed/Typed Name
Signature
Month Day Year
MINI
19. Discrepancy Indication Space
20. Facility Owner or Operator Certification of receipt of hazardous materials covered by this manifest except as noted in item 19
Printed/Typed Name
Signature
Month Day Year
I I I I I I
39
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APPENDIX
APPENDIX I
Drug Enforcement Administration
Division Offices
Atlanta Field Division
Richard B. Russell Federal Building
75 Spring St., SW, Room 740
Atlanta, GA 30303
(404) 331-4401
Boston Field Division
50 Stamford St., Suite 200
Boston, MA 02114
(617) 565-2800
Chicago Field Division
500 Dirksen Federal Building
219 S. Dearborn St.
Chicago, IL 60604
(312) 353-7875
Dallas Field Division
1880 Regal Row
Dallas, TX 75235
(214) 767-7151
Denver Field Division
721 19th St., Room 316
P.O. Box 1860
Denver, CO 80201
(303) 844-3951
Detroit Field Division
357 Federal Building
231 West Lafayette
Detroit, MI 48226
(313) 226-7290
Houston Field Division
Suite 300
333 West Loop North
Houston, TX 77024
(713) 681-1771
Los Angeles Field Division
Suite 800
350 South Figueroa St.
Los Angeles, CA 90071
(213 894-2650
Miami Field Division
8400 N.W. 53rd St.
Miami, FL 33166
(305) 591-4870
Newark Field Division
806 Federal Office Building
970 Broad St.
Newark, NJ 07102
(201) 645-6060
New Orleans Field Division
Suite 2200
1661 Canal St.
New Orleans, LA 70112
(504) 589-3894
New York Field Division
Suite 1900
555 W. 57th St.
New York, NY 10019
(212) 399-5151
Philadelphia Field Division
10224 William J. Green Federal Building
600 Arch Street
Philadelphia, PA 19106
(215) 597-9530
Phoenix Field Division
Suite 301
3010 N. 2nd Street
Phoenix, AZ 85012
(602) 640-5700
San Diego Field Division
402 W. 35th St.
National City, CA 92050
(619) 585-4200
San Francisco Field Division
Room 12215
450 Golden Gate Ave.
P.O. Box 36035
San Francisco, CA 94102
(415) 556-6771
Seattle Field Division
Suite 301
220 West Mercer
Seattle, WA 98119
(206) 442-5443
St. Louis Field Division
Suite 500
7911 Forsythe Blvd.
United Missouri Bank Bldg.
St. Louis, MO 63105
(314)425-3241
Washington Field Division
Room 2558
400 Sixth St., S.W.
Washington, DC 20024
(202) 724-7834
41
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX J
EPA Hazardous Waste Regional Contacts
Region I (CT, ME, MA, NH, RI, VT)
Director
Waste Management Division
US EPA Region I (HAA-1903)
JFK Federal Building, Rm 2203
Boston, MA 02203
(617) 565-3698
Region II (NJ, NY, Puerto Rico, Virgin Islands)
Director
Air & Waste Management Division
US EPA Region H (AWM)
26 Federal Plaza, Room 900
New York, NY 10278
(212) 264-2302
Region IH (DE, DC, MD, PA, VA, WV)
Director
Hazardous Waste Management Division
US EPA Region III (3HW)
841 Chestnut St.
Philadelphia, PA 19107
(215) 597-8131
Region IV (AL, FL, GA, KY, MS, NC, SC, TN)
Director
Waste Management Division
US EPA Region IV
345 Courtland St., N.E.
Atlanta, GA 30365
(404) 347-3454
Region V (IL, IN, MI, MN, OH, WI)
Director
Waste Management Division
US EPA Region V (5H-12)
230 South Dearborn St.
Chicago, IL 60604
(312) 886-7579
Region VI (AR, LA, NM, OK, TX)
Director
Air & Waste Management Division
US EPA Region VI (6H)
First Interstate Bank Tower
1445 Ross Avenue
Dallas, TX 75202
(214) 655-2100
Region VH (IA, KS, MO, NE)
Director
Waste Management Division
US EPA Region VII (WSTM)
726 Minnesota Ave.
Kansas City, KS 66101
(913) 236-2850
Region VBLT (CO, MT, ND, SD, UT, WY)
Director
Waste Management Division
US EPA Region VIII (8HWM)
999 18th St., Suite 500
Denver, CO 80202
(303)293-1719
Region IX (AZ, CA, HI, NV, American
Somoa, Guam)
Director
Waste Management Division
US EPA Region IX (T-l)
215 Fremont Street
San Francisco, CA 94105
(415) 974-7460
Region X (AK, ID, OR, WA)
Director
Hazardous Waste Division
US EPA Region X (HW-111)
1200 Sixth Avenue
Seattle, WA 98101
(206) 399-1352
43
GPO : 1990 O - 267-238 : QL 3
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