United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9360.5-OOFS
June 1990
FDTF\ Joint Federal Task Force on
Clandestine (Illegal) Drug
Laboratories
Office of Emergency and Remedial Response
Emergency Response Division OS210
Quick Reference Fact Sheet
INTRODUCTION
Under the Anti-Drug Abuse Act of 1988, Congress
directed a Joint Federal Task Force on Clandestine Drug
Laboratories to establish a program to clean up and dispose
of hazardous wastes produced by clandestine (illegal) drug
laboratories. Appointed Task Force members come from
the U. S. Drug Enforcement Administration (DEA) and the
U.S. Environmental Protection Agency (EPA). Because the
U.S. Coast Guard (USCG) has jurisdiction over coastal
waterways that may be contaminated as the result of
operations at illegal drug laboratories, the USCG is a
participating agency with representatives on the Task Force.
This Fact Sheet for EPA staff describes the problem
that gave rise to the need for a program to clean up hazardous
wastes and hazardous materials at clandestine drug
laboratories, and briefly outlines the content of Task Force
guidelines developed to address the problem. The Fact
Sheet is based on the Joint Task Force Guidelines for the
Cleanup of Clandestine Drug Laboratories, March 1990.
To obtain a copy of this publication, send a written request
on your organization's letterhead to the Emergency Response
Division, OS-210, U.S. EPA, Washington, D.C., 20460,
Re/DEA Guidelines.
IDENTIFYING THE PROBLEM
What is a Clandestine Drug Laboratory?
A clandestine drug laboratory is a facility where
operators manufacture stimulants, depressants,
hallucinogens, and narcotics in violation of the Controlled
Substances Act. These laboratories can be crude, makeshift
operations or highly sophisticated, advanced facilities. An
operator can set up a clandestine drug laboratory in a private
residence or apartment; a motel or hotel room; a trailer or
houseboat; or at a campground, factory, warehouse, or
commercial establishment. Violators often hide these
laboratories in nondescript houses and barns in remote rural
areas. Manyof these facilities have sophisticated surveillance
equipment and booby-traps, both to prevent intruders and
law enforcement personnel from entering, and to destroy
evidence if someone discovers the facility.
How Many Clandestine Drug Laboratories Are There?
Throughout the 1980s, DEA increased its enforcement
actions against clandestine drug laboratories by 22% to 25 %
a year, seizing 184 laboratories in FY 1981 and 810 in FY
1988. Additional laboratories were seized by State and
local law enforcement agencies. Because more clandestine
drug laboratories are operating in the U.S. than ever before,
there are more drugs illegally available.
Who Operates Clandestine Drug Laboratories?
The "recipes" for most illegal drugs are relatively
simple and available from legal and illegal sources.
Consequently, an operator can be a novice with little or no
knowledge of chemistry or a Ph.D. chemist. Anyone
motivated by the high profit potential can manufacture
illegal drugs.
What Drugs Do These Laboratories Produce?
According to DEA statistics, most clandestine
laboratories produce three drugs: methamphetamine(82%),
amphetamine (10%), and PCP (about 3%). Ninety-five
percent of the laboratories that DEA seized in 1988
manufactured one of these drugs. There are other substances
produced in clandestine drug laboratories, and the number
is constantly growing as operators develop new substances
(designer drugs) to circumvent controlled substance laws.
What Kinds of Hazardous Wastes Are Generated by
These Laboratories?
When DEA or some other authority se: zes a clandestine
drug laboratory, there may be anywhere from a few pounds
Printed on Recycled Paper
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to several tons of hazardous wastes and hazardous materials
that need to be disposed of properly. These wastes and
materials include the drug products themselves, contaminated
glassware and equipment, solvents, reagents, precursors,
and by-products. Many of the materials are reactive,
explosive, flammable, corrosive, or toxic. They may
contaminate the laboratory site, or may migrate off-site.
Storing chemicals off the laboratory site increases the
prospect of accident and exposure. If an operator stores
substances in a rental locker, the lack of proper ventilation
and temperature controls at this location adds to the potential
for fire, explosion, and human exposure. Compared to a
hazardous waste site, the quantities of hazardous material at
a typical clandestine operation may be small, but the public
health concern is very real.
Who is Exposed to These Hazards?
Clandestine drug laboratories present both acute and
chronic health risks to law enforcement personnel who seize
the facility, workers involved in clean-up, people who live
or work nearby, and laboratory operators.
The people who operate these laboratories generally
have little regard for quality control or safety. For example,
to avoid detection, an operator may indiscriminately dispose
of raw chemical materials and the by-products of the
manufacturing process. It is common practice to spill
chemicals on the floor; to dump hazardous waste into
bathtubs, sinks, and toilets inside the facility; or to dump
waste on the ground surrounding the laboratory and along
roads and creeks. These practices may result in contaminated
surface and drinking water supplies, and potentially may
affect a large number of people.
Perhaps the greatest risk of long-term exposure is to
people who inhabit buildings that once were the sites of
clandestine drug laboratories, and that may have residual
contamination.
What Are the Hazards to Law Enforcement
Personnel?
Law enforcement personnel may face acute health
hazards when they carry out a raid at a clandestine drug
laboratory. During a raid, officers may be exposed to a
solvent, reagent, precursor drug product, or by-product that
is acutely toxic (i.e., an irritant, corrosive, depressant, or
asphyxiant). Many solvents and reagents are also explosive
or flammable.
Law enforcement personnel who investigate and seize
clandestine drug laboratories should have special training in
investigation, in taking appropriate health and safety
measures, and in the proper use of personal protective
equipment.
GUIDELINES FOR CLEANING UP I
CLANDESTINE DRUG LABORATORIES |
Introduction
The Joint Task Force developed Guidelines for the
Cleanup of Clandestine Drug Laboratories as a framework
for State and local law enforcement, environmental
protection, and public health agencies to use for cleaning up
clandestine drug laboratories. These Guidelines are flexible,
allowing local agencies to apply them to local situations.
They contain an overview of recommended procedures for
enforcement, safe disposal of contaminated materials, and
cleaning up residual contamination. Keep in mind, however,
that the Guidelines document is not a training manual. The
Task Force encourages State and local agencies to develop
and implement clandestine drug laboratory programs that
are more extensive than the model program outlined in the
Guidelines.
What is Typically Involved in Cleaning Up a Clandestine
Drug Laboratory Site?
Although only a few clandestine drug laboratories pose
a public health or environmental risk sufficient to justify a
response action under Superfund, these sites may contain
residual contamination sufficient to require some degree of
clean-up. In the rare case where a site may pose an imminent
and substantial hazard to public health, welfare, or the
environment, law enforcement officials should contact
appropriate State agencies and the National Response Center
(NRC). The NRC's number is 800-424-8802.
What is the Purpose of a Site Evaluation?
In the Guidelines, the Joint Task Force recommends
that States designate a lead agency responsible for cleaning
up clandestine drug laboratories. After the lead agency
receives notice that law enforcement officials have seized a
laboratory, the lead agency should conduct a site evaluation.
Its purpose is to:
• Ensure that problem sites are identified properly;
• Determine whether any further release of a
hazardous substance from the site may pose a hazard or
threat to public health;
• Determine whether a residual clean-up or
decontamination action is warranted; and
• Develop the necessary site data base in the event that
there is a serious, long-term threat to public health or
the environment.
The National Oil and Hazardous Substances Pollution
Contingency Plan (NCP, 40 CFR Pan 300) describes the site
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evaluation process in detail. EPA also has published several
guidance documents on evaluating and documenting a site.
A State or locality can scale down these approaches to fit the
requirements of a particular clandestine drug laboratory
site.
What Are the Steps in Conducting a Site Evaluation?
The Joint TaskForce recommends that trained technical
personnel conduct the site evaluation and necessary
clean-up actions. Engmeers, chemists, industrialhygienists,
and lexicologists all are professionals who may assist in the
conduct of these activities. The basic steps in evaluating a
site may include:
• Collecting and reviewing existing data from law
enforcement agencies, the disposal contractor, and
from other appropriate information sources to
characterize the operation, location, and population
near the site. These information sources should
include hazardous waste manifests and chemical
inventory information compiled by the law
enforcement agency.
• Interviewing people (e.g., law enforcement officers,
code enforcement officers, and people who live
near the site) who may provide useful information
on site history.
• Visually inspecting the site perimeter to confirm or
update the data file regarding site safety and
potential hazards.
• Surveying the site to identify suspected
contaminated areas, and sampling these areas to
determine whether there are hazardous chemicals
present. The Guidelines suggest areas from which
clean-up professionals might take samples, and
recommend some sampling procedures.
• Surveying off-site areas to identify surrounding
land use, population, and water supplies; and to
determine who might be affected if there is a
hazardous substance release off-site. Again, the
Guidelines suggest appropriate sampling
procedures.
• Documenting the evaluation results (1) to give the
site history; (2) to identify contaminated areas, the
nature and concentration of contaminants, and
toxicity and chemical characteristics of the
materials; and (3) to identify possible routes of
chemical contamination, transport, and human
exposure.
What Are the Primary and Secondary Areas of
Contamination?
Irrespective of where you find a clandestine drug
laboratory — whether in a residence, factory, or boat —
certain primary or secondary areas within these structures
usually contain most of the contaminants. Knowing these
typical contamination areas helps evaluators design a
sampling protocol and clean-up strategy. Typical primary
contamination areas are:
• Processing (cooking) areas near water or sewers.
The causes of contamination in processing areas
are spills, boil-overs, explosions, distillation,
extraction, and purification procedures.
• Dumping (disposal) areas.
• Storage areas. The causes of contamination in
storage areas are spills and leaks.
Typical secondary contamination areas are:
• Places where contamination has migrated (e.g.,
where a person's shoes may carry materials from
a processing area into a hallway).
• The atmosphere around the laboratory
(contaminated by venting or by air releases from
processing equipment).
• Surfaces on which vented material comes to rest
(e.g., curtains, blinds, light fixtures).
• Ventilation systems common to the laboratory's
system (e.g., adjoining rooms in a hotel or motel).
Professionals evaluating a site should also consider the
following conditions affecting the nature or extent of
contamination:
• Fire. Incomplete combustion products or
contaminated ash material may come to rest on
various surfaces or structures.
• Weather. For example, heat may make some
substances volatile, and result in the release of gas
vapors. Wind may disperse dust or vapors, increasing
the probability of human exposure.
• Humidity. Humidity may influence the degradation
and disposition of various hazardous substances.
• Ground temperature and water table depth. These
conditions influence indoor air concentrations of
hazardous substances in basements or other rooms
in a building.
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What Are the Possible Courses of Action?
Once the S tate lead agency has conducted an evaluation,
it will generally determine either that no further action is
required, or that residual clean-up or decontamination is
required. In considering whether there is a need for residual
clean-up or decontamination, a good question to ask is
whether these actions can make the structure suitable for
rehabilitation or use. When there is sufficient concern that
a release or potential release of a hazardous substance
threatens the public health, welfare, or the environment, the
designated lead S tate agency should conduct a more detailed
evaluation.
A more extensive site evaluation and sampling
protocol may be warranted, for example, when
indiscriminate hazardous waste dumping results in
significant well-water or groundwater contamination. A
proper evaluation may require assessing both acute and
chronic health risks to the surrounding inhabitants —
especially if the inhabitants include a sensitive population
(children or elderly people, for example). The Guidelines
reference several EPA documents that can help responsible
officials conduct detailed assessments.
The lead State agency should develop a Safety and
Emergency Response Plan for a response team to follow
during clean-up operations. Although each plan should be
site-specific, a plan can follow a generic model. The U.S.
Occupational Safety and Health Administration has issued
requirements for emergency response planning for certain
hazardous waste operations and emergency response. You
can find these requirements at 29 CFR 1910.120. The
National Institute of Occupational Safety and Health and
EPA also have published standard operating procedures,
guidelines, and factors to consider. The Guidelines reference
several of these documents.
When Should Responsible Officials Determine That
No Further Action is Required?
Responsible authorities may decide that no further
action is required when the hazardous substance
concentrations present in samples taken on-site and off-site
are below Federal or State action levels; or when there is
reasonable evidence to suggest that contamination on-site
or off-site poses neither a short-term nor long-term threat to
public health, welfare, or the environment.
What Should Responsible Officials Do If Residual
Clean-up or Decontamination Action Is Required?
If there is reasonable evidence that residual chemical
contamination — either in a structure or on the grounds
around a clandestine drug laboratory — may result in a
health hazard, the lead State agency may determine that a
clean-up action is necessary. If the clean-up operation
generates hazardous wastes, responsible officials should
follow EPA and Department of Transportation regulations
in managing hazardous waste disposal (49 CFR Parts 100-
199 and 40 CFR Parts 261-263).
Responsible clean-up authorities can take several
approaches to reducing or eliminating residual chemical
contamination in the laboratory structure or on the grounds
around the laboratory site. These approaches may include
removal, decontamination, venting, neutralizing, detergent-
water washing, and encapsulating or sealing.
If there is outdoor contamination to soil, surface water,
or ground water, clean-up authorities may consider one of
several approaches, depending on the type and extent of
contamination. These approaches may include:
• Controlling access to the site.
• Removing containers of hazardous materials.
• Controlling drainage.
• Removing or treating contaminated soil and water.
• Providing alternate water supplies for people
exposed to contaminated well-water.
Extensive outdoor contamination is among the
conditions that may present a potential acute or chronic
health hazard. Law enforcement personnel and State or
local health agency officials should coordinate clean-up
strategies to ensure that public health and welfare receive
appropriate consideration.
The National In stitute of Environmental Health Sciences
(NIEHS) has approved grants to 11 organizations to train
workers engaged in hazardous waste operations and
emergency response. For more information on these
organizations, call Denny Dobbin at 919-541-0752.
EPA also sponsors training courses. The Hazardous
Materials IncidentResponse Training program is comprised
of 13 courses, and is available tuition-free to any government
worker. For more information, call Art Ball or Ellery
Savage at 513-569-7537.
CONCLUSION
Each State should assume some responsibility for
developing a comprehensive clandestine drug laboratory
program that addresses law enforcement, environmental,
and health and safety concerns. State and local authorities
must recognize that each clandestine drug laboratory is
different, and that before they seize or secure one of these
laboratories, the responsible authorites should take account
of the differences in deciding what actions are appropriate.
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