oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER
9J60-5.00
Proposed Guidelines for Cleanup of
Clandestine ^ru Laboratories
APPROVAL DATE:
6/2/89 -
ECTIVE DATE: 90-day comment period thru
ORIGINATING OFFICE:
D FINAL °RRR/ERD
D DRAFT
•
STATUS:
[ I
t ]
REFERENCE (other document*):
A- Pending OMB approval
Pending AA-OSWER approval
For review &/or comment
In development or circulating
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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United States Environmental Protection Agency
Washington. DC 20460
OSWER Directive Initiation Request
1. Directive Number
9360.5-00
2. Originator Information
Name of Contact Person
Betti C. VanEpps
Mail Code
OS-240
Office
OERR
Telephone Code
475-8864
3. Title
Proposed Guidelines for Cleanup of Clandestine Drug Laboratories
4. Summary of Directive (include brief statement of purpose)
Proposal developed by Joint Federal Task Force to address drug
lab cleanups - document currently out for comment, 90-day period
extending through 8/24/89.
5. Keywords
6a. Does This Directive Supersede Previous Directive(s)?
b. Does It Supplement Previous Directive(s)?
No
No
Yes What directive (number, title)
Yes What directive (number, title)
7. Draft Level
A - Signed by AA/DAA
B - Signed by Office Director
C - For Review & Comment
D - In Development
8. Document to be distributed to States by Headquarters?
Yes
X
No
This Request Meats OSWER Directives System Format Standards.
9. Signature of Lead Office Directives Coordinator
Betti C. VAnEpps
10. Name and Title of Approving Official
.Trmafhan 7. Cannon. Acting AA
Date
6/21/89
Date
6/2/89
EPA Form 1315-17 (Rtv. 5-87) Previous editions are obsolete.
OSWER OSWER OSWER 0
VE DIRECTIVE DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
JUN 2
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Proposed Guidelines for the Cleanup of Clandestine Drug
Laboratories (OSWER Directive No. 9360.5-00)
FROM: yjonathan Z.
Assistant
TO: Waste Management Division Directors, Regions I-X
Environmental Services Division Directors, Regions I, VI, and VII ,
> t
Attached are two copies of the proposed Guidelines for the Cleanup of
Clandestine Drug Laboratories which were prepared by a Joint Federal Task
Force comprised of the U.S. Environmental Protection Agency and the Drug
Enforcement Administration. A Notice of Availability of the Guidelines was
published in the Federal Register on May 24, 1989.
The Guidelines recommend that State and local law enforcement and
environmental and health agencies implement a comprehensive approach to the
cleanup of clandestine drug laboratories. A 90-day comment period has been
established for the proposed Guidelines which ends on August 24, 1989.
Please review the proposed Guidelines and offer any comments you may have.
Your comments are essential to the development of a useful set of final cleanup
guidelines. You should also take the opportunity to share this guidance with
State and local representatives to the Regional Response Team for their review
and comments. All comments should be addressed to: Sidney A. Hayakawa, Drug
Enforcement Administration, Office of Forensic Sciences, Hazardous Waste
Disposal Unit, Washington, D.C. 20537, ATTN: AFSH.
If you have any questions or need further clarification regarding the
proposed Guidelines, please contact Hans Crump, Deputy Director, Emergency
Response Division, at FTS 382-2551.
Attachments
cc: Sidney A. Hayakawa, DEA
Henry Longest, OERR
Bruce Diamond, OWPE
Sylvia Lowrance, OSW
Hans Crump, OERR
Betti VanEpps, OERR
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PROPOSED
GUIDELINES FOR THE CLEANUP
i
OF
CLANDESTINE
DRUG LABORATORIES
PREPARED BT:
THE JOINT FEDERAL TASK FORCE or
THE DRUG ENFORCEMENT ADMINISTRATION,
THE US ENVIRONMENTAL PROTECTION AGENCY,
THE US COAST GUARD
MAT 18, 1989
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TABLE OF CONTENTS
SECTION PAGE
Introduction iii
What is the Problem? 1
DEA's Clandestine Drug Laboratory Safety Certification Program 4
Developing a State or Local Clandestine Drug Laboratory Program 6
Cleanup of Residual Contamination 11
Summary of Joint DEA/USEPA Task Force Recommendations 15
References 16
List of Acronyms 17
Glossary 18
Appendicies 20
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ACKNOWLEDGEMENTS
The Joint Federal Task Force consisted of members from the U.S. Drug Enforcement
Administration (DEA), 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 waste at clandestine drug laboratories.
Co-chairmen
John W. Gunn, Jr., DEA, Washington, DC
Jonathan Z. Cannon, USEPA, Washington, DC
USEPA
Hans J. Crump-Wiesner, Washington, DC
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
Jorge Acevedo, Houston, TX
Richard Fox, Washington, DC
Lanny Hall, Dallas, TX
James Hannon, Washington, DC
Sidney A. Hayakawa, 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
ii
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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 (DEA) 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
•lie DEA/USEPA Task Force prepared these guidelines for state and local law enforcement and health agencies to provide
? 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.
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 DEA 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 exist In the absence of proper safety procedures
and cleanup guidelines, enforcement agents, state and local law enforcement personnel, and the public 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 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 drug laboratory, the law enforcement agency will probably 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 transportation of hazardous materials
promulgated by the Department of Transportation (DOT).
These Task^orce guidelines were designed to be flexible and provide guidance for addressing typical problems encountered
Klandestine drug laboratories. The guidelines should not be used as a training manual References are made throughout
document to pertinent federal regulations, guidance documents relevant to the evaluation and cleanup of hazardous waste
s, 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.
ill
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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 technologically
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, and commercial establishments. Often these laboratories are hidden
in nondescript houses or bams 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
DEA
Seizures
TSL *82 "83 "84 "85 136
Fiscal Years
Actual
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
; stimulants and hallucinogens. This increase is attributed to the availability of precursor chemicals and the increasing
larity, ease of manufacture, low production costs, and high profits of the drugs. DEA enforcement actions against these
Oratories have increased dramatically throughout the 1980s by 22 - 25 % per year (See graph on this page). According
to DEA statistics, 184 laboratories were seized in FY1981, but projections indicate that more than 1,000 laboratories will be
seized in FY1989. 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 DEA in FY 1988:
.California (44%), Texas (19%), and Oregon and Washington (15% combined).
FY 1988 Clandestine Drug Laboratory Seizures
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.) his-
torically have manufactured and distributed amphetamines
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
Bde with easily obtainable chemicals, and equipment that
"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 drugs. Therefore,
anyone motivated by the high profit potential can get in-
volved in the illegal drug manufacturing business.
WHAT ARE THE DRUGS AND
HAZARDOUS WASTES PRODUCED?
DEA statistics indicate that the majority of the laboratories
produce three drugs: methamphetamine (82%), ampheta-
mine (10%), and PCP (2.5%). Laboratories which manufac-
ture these drugs account for approximately 9*% of the total
number of laboratories seized in FY 1988. However, many
different substances are also produced by clandestine drug
laboratories. The number is constantly growing as new con-
trolled substance analogs ("designer drugs") are developed in
an attempt to circumvent controlled substance laws.
When a clandestine drug laboratory is seized, hazardous
waste/materials, such as chemicals and contaminated glass-
ware and equipment, must be disposed of properly. These
materials weigh from a few pounds to several tons and include
solvents, reagents, precursors, by-products, and the drug
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WHAT Is THE PROBLEM?
products themselves. Many of these materials are
reactive, explosive, flammaWe^corrosive, and/or
Joxic. Table 1 provides examples of representative
chemicals associated withmethamphetamine labo-
ratories and lists some of their hazardous proper-
ties. Additional listings of the health effects from
exposure to the most :ommonly encountered
chemicals associated with clandestine drug labo-
ratory types are presented in Appendix A. This
listing includes most of the laboratory types and
represents the broad spectrum of chemical haz-
ards. For more detailed information on health ef-
fects and other properties of hazardous chemicals,
refer to references 1 to 9.
Although the quantities of hazardous materials
found at a typical clandestine drug laboratory arc
relatively small when compared to a typical indus-
trial hazardous waste site, the substances to which
law enforcement personnel and others may be
exposed present very real public health concerns.
andestine drug laboratories may contaminate
ter sources and/or soil. In some cases, contami-
nation may spread off-site. Careless or intentional
dumping by the illegal laboratory operator is not
the only source of contamination. 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 indiscrimi-
nately by the outlaw-laboratory operator to avoid detection.
can pose a significant human health or environmental
i. The operators of these laboratories have little regard
^quality control or safety. Spilling chemicals on the floor
or dumping waste into bathtubs, sinks, toilets, or on the
grounds surrounding the laboratories, and along roads and
creeks are common practices. Surface and groundwater
TABLE 1: SOME TYPICAL CHEMICALS FOUND IN
CLANDESTINE METHAMPHETAMINE LABORATORIES
Chemical Acute Toxicitv*
Acetic anhydride
Benzene
Chloroform
Elhanol
Hydrogen Cyanide
Hydrochloric Acid
Hydriodic Add
Lithium Aluminum
Hydride
Mercury Chloride
Methyfamine
Petroleum Ether
Phosphine
Red Phosphorus
Sodium (metal)
Tnionyl Chloride
• Based primarily on
Moderate
Moderate-High
Moderate
Low
Extreme
High
High
Moderate
High
High
Low
High
Low
High
High
National Fire Protection
Flammabilitv* Other Propertiesj
Moderate Irritant, Corrosive i
Htgti
Low
High
Low
Low
Low
High
Low
Extreme
Extreme
Extreme
Low
Low
Low
Association Standards
Blood Disorders,
Carcinogen
Incoodination,
Carcinogen
-
Rapid asphyxia
Vritant, Corrosive
Irritant, Corrosive
Water reactive
Explosive
Irritant, Corrosive
Corrosive
Incoordination
Reactive
Rapid asphyxia
Reactive &
Explosive
Water reactive
Corrosive
Water reactive
Corrosive
drinking supplies could be contaminated, potentially affect-
ing 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.
WHAT ARE THE HAZARDS To LAW
ENFORCEMENT PERSONNEL?
The primary health concerns at a clandestine drug laboratory
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., ir-
ritant, corrosive, depressant, or asphyxiating). Further, many
of these solvents and reagents are explosive or flammable.
Law enforcement personnel engaged in clandestine drug
laboratory investigations and seizures should have special-
ized training in the investigation of clandestine drug labora-
tories, in appropriate health and safety procedures, and in the
use of personal protective equipment
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
ARE THERE PROCEDURES FOR
DEALING WITH CLANDESTINE
DRUG LABORATORY HAZARDS?
DEA and its predecessor agencies have been involved in
seizing clandestine dmg 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 approach
is presented as a general model for state and local law enforce-
ment agencies for the development of their own programs/
procedures.
DEA's CLANDESTINE DRUG
LABORATORY SAFETY
CERTIFICATION PROGRAM
The investigation of clandestine drug laboratories presents
unique challenges to law enforcement personnel and requires
specialized training. DEA's program consists of two separate
TOM 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 witfrescape SCBA
- Fully encapsulating chemical-resistant suit
- Inner chemical-resistant gloves
- Chemical-resistant safety boots/shoes
- Two-way radidoornmunications
Level B ?*~
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 pres-
sure-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)
schools: (1) Clandestine Laboratory Investigative School
and (2) Clandestine Laboratory Safety School. Each of these
schools is approximately one week in length, and the Inves-
tigative 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 accordance
with regulations promulgated by the Occupational Safety and
Health Administration (OSHA) in Tide 29 of the Code of
Federal Regulations and with recommendations from the Na-
tional Institute of Occupational Safety and Health (NIOSH).
All agents and chemists involved in these courses must com-
plete a medical screening (See Appendix Q. Without this
medical screening and training, neither agents nor chem-
ists can participate in the entry, assessment, or processing
phases of a laboratory seizure. ,
i
The DEA program also addresses the protection of the public
health and safety and the environment by employing a quali-
fied hazardous waste disposal firm to properly manage and
dispose of hazardous wastes.
- 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-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: "'': -• ""':v''-[: ,••;•./•• •••• •
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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WHAT Is THE PROBLEM?
AN OVERVIEW OF DEA's
CLANDESTINE DRUG LABORATORY
SEIZURE PROTOCOL
When the DEA begins the investigation, routine investiga-
tive techniques are employed to gather sufficient probable
cause to substantiate that a drug laboratory isoperating on the
premises. The law enforcement personnel then request a
search warrant. If necessary, authority todestroy any hazard-
ous bulk chemicals and equipment used in the manufacturing
of illegal, dangerous drugs may be requested in the warrant.
A DEA clandestine drug laboratory seizure usually proceeds
in six steps: planning, entry, assessment, processing, exit,
and follow-up.
Planning The Raid
In planning the raid, the case agents first make an assessment
of the hazards likely to be encountered and determine who
needs to be notified before the raid (i.e., local police, fire
department, emergency rooms, and hazardous waste con-
tractor). Once the potential hazards have been considered,
the law enforcement personnel assign certified teams to
jponduct the raid. These teams include a forensic chemist and
*a site safety officer who are trained and equipped with
requisite 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 mo-
bib'ty. This may significantly interfere with an agent's ability
to defend themselves 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 deter-
mine what, if any, immediate health and safety risks (i.e.,
potential for fire and explosion, toxic vapors, booby-traps,
^tc.) exist. The team then takes appropriate steps to reduce
Eminent risks (i.e., properly shutting down active "cook-
W'g" processes, ventilating the premises, etc.). After the as-
sessment team determines the level of risk and establishes the
appropriate level of protection required, the processing
phase can begin.
Processing
During the processing phase, law enforcement personnel
photograph and videotape everything in the laboratory and
then gather evidence. No materials or apparatus arc moved
until the certified chemist and agent have inspected and
inventoried each piece of evidence. The certified chemist,
under the direction of the agent, takes samples as needed for
evidence. All samples are labeled, initialed, packaged, and
sealed for transportation to a DEA laboratory. The recom-
mended one-ounce sample size is typically sufficient for
DEA drug analysis and, if necessary, a reanalysis. The team
does not take possession of, or transport any chemicals,
glassware, or apparatus used in the laboratory other
than the samples taken for evidence. A qualified hazard-
ous waste disposal contractor is used to remove.all remain-
ing chemicals (liquids and powders), and laboratory glass-
ware and equipment '
DEA considers all of these materials to be contaminated
and, therefore, manages them as hazardous waste. When
the processing has been completed, the law enforcement
team leader authorizes the disposal contractor to remove and
dispose of all hazardous waste. The team leader verifies and
accounts for all hazardous wastes to be removed and remains
at the site until the disposal contractor has completely re-
moved the hazardous waste. Any contaminated protective
clothing and equipment that cannot be decontaminated and
reused is removed by the disposal contractor. (See Sidebar:
Hazardous Waste Statutes and Regulations, page 6.)
Exit
When the removal of these hazardous wastes has been com-
pleted, the law enforcement team leader 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.
Follow-up
Notification letters are sent by the Special Agent in Charge
(SAQ 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 re-
quested.
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
DEVELOPING
A STATE OR LOCAL CLANDESTINE DRUG
LABORATORY PROGRAM
The DEA program just outlined provides a basic framework
which each state or local law enforcement agency can use as
guidance to develop and implement its own program. As the
resources and particular needs of each state vary, exact
duplication of the DEA program may not necessarily be
possible or desirable. However, the state or local program
should reflect the basic principles and considerations devel-
oped by the DEA.
pie Congressional mandate to address the clandestine drug
laboratory problem is based on the recognition that hazard-
ous materials generated by these laboratories pose a signifi-
cant health threat to law enforcement personnel as well as to
the general public and the environment. It is essential that
cooperative interaction be established between law enforce-
ment and other state or local agencies to effectively address
the clandestine laboratory problem in their jurisdiction. Al-
though law enforcement agencies can initiate the cleanup ac-
tivities through the bulk removal effort, more extensive
cleanup activities should be the responsibility of non-law en-
forcement groups designated by the state or local governing
body. -
You Need to Know
Hazardous Waste StituUs and Regulations
The DEA/USEPA Task Force recommends that each
state appoint a lead agency to assume responsibility for
the residual cleanup efforts. The designated 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 pri-
mary goal of a clandestine drug laboratory program, the cost
of the cleanup process is also a concern. Just as USEPA
imposes cleanup costs for removing hazardous substances on
responsible parties, the state or local agency should recover
costs primarily through the responsible parties involved in
clandestine laboratory activites or the owners of the site.
USEPA has outlined its general approach to cost recovery and
cleanup procedures in the National Contingency Plan (NCP)
(Reference 10) and in the EPA Superfund Removal Proce-
dures Manual (Reference 11).
Finally, it is essential that the guidelines which are developed
within each state are consistent with federal and state regula-
tions and, where applicable, local regulations relating to the
handling and disposal of hazardous wastes. (See the Sidebar.
Hazardous Waste Statutes and Regulations, this page.)
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 fol'cwing 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 transporters)
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).
. The Hazardous Materials Transportation Act regulates packaging, marking, labeling, and transportation of hazardous
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 Parts 1910 and
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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DEVELOPING A STATE OR LOCAL PROGRAM
Clandestine Drug Laboratory Safety
Certification
Personnel involved in the investigation and seizure of clan-
destine drug laboratories must receive medical screening and
specialized training.
The DEA/USEPA Task Force recommends that the
medical screening and the training program should be
considered an essential part of any clandestine drug
laboratory program.
Planning a Clandestine Drug Laboratory
Seizure
Clandestine laboratories, by the very nature of their activi-
ties, present a unique scries of hazards and risks to law en-
forcement personnel. The degree of hazard depends on ihc
specific site, chemicals present, their concentrations, condi-
tions 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
• booby-traps
• physical injury resulting from close quarters
The following safety procedures should be considered when
planning the raid:
• Notify fire department and police bomb squad, de-
pending 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 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 cool-
ing 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.
• Use only electronic strobes and cameras; flashbulbs
can cause flammable solvents or fumes to ignite.
Do not smoke at the site.
Do not eat or drink at the site.
Do not touch your mouth, eyes, or other mucous
membranes wiih your hands.
Decontaminate clothing and equipment before leav-
ing the laboratory site,
Initial Entry
The initial entry teams should be specially trained law en-
forcement officers who arrest the illegal laboratory operators
and secure the site. After securing the premises, everyone is
evacuated and the assessment step begins.
The DEA/USEPA Task Force recommends the initial
entry team wear protective clothing such as ballistic vests
and fire retardant suits.
t
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
enforcementofficer 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. appropri-
ate monitoring instrumentation, such as air-sampling pumps,
explosimeters, oxygen meters, organic-vapor analyzers, or
other air-monitoring instruments that are used to determine
the lower explosive limit (LEL) and the concentration of or-
ganic vapors in the laboratory atmosphere. All monitoring
devices must be intrinsically safe (i.e., designed to suppress
sparks that may ignite explosive atmospheres).
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 intrinsically safe
(i.e., explosion proof), fans should not be used because
sparks from the fan motor can cause flammable solvents or
fumes to ignite.
The DEA/USEPA Task Force recommends that some
laboratories, ( i.e., those producing LSD, fentanyl,
f
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
You Need to Know
Conditions Requiring Ventilation
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) o<
their respective components, or generally greater
than 5 parts per million if the compounds are not
known.
Caution: See recommendation on page 7 and 8 re-
garding LSD. fentanyt, alphaprodine, and MPPP
laboratories.
alphaprodine, MPPP, and other analogs) should not be
ventilated because of the potential for human exposure to
the extremely toxic dusts or vapors if they are released
Imto 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 investigation
shall noti fy the National Response Center (NRC). (See Side-
bar: What Information Should Be Reported to the NRC?,
page 11). The NRC notifies appropriate agencies (i.e., the
USEPA/USCG, state, and local government) in accordance
with established procedures. After notification, the cogni-
zant agency initiates appropriate response actions to protect
the public health and the environment.
Laboratory Deactlvation
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 dis-
mantle the laboratory must be familiar with the chemicals
involved, their properties, and the drug manufacturing proc-
K:s. For example, extreme care should be taken if any
al hydrides (i.e., lithium aluminum hydride which ignites
n contact with water) are present Before deactivation, it
is also necessary to determine that none of the apparatus is
booby-trapped.
Procedures for Deactivation
The following are examples of procedures used in laboratory
deaciivation:
• Examine the setup to determine whether processing
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 stopping the
water or turning off any stirrers or shakers.
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 priats 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
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, this page). If the atmos-
pheric safety criteria are not met, begin or continue ventilat-
ing and monitoring every half hour. Ventilation should con-
tinue until the safety criteria are met If this is impractical, the
next step, laboratory processing, can be accomplished with
Level B protection (SCBA). If appropriate, 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 identifing labels, making a complete in-
ventory, taking evidentiary samples, and disposing of the
bulk chcmincals and apparatus.
Photographs
• Photograph everything in place
- General overviews
- Close ups
- Specific items during inventory
- Evidentiary samples and original containers
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DEVELOPING A STATE OR LOCAL PROGRAM
- Visible contamination
• site after removal bulk materials
Inventory
Inventory all equipment and paraphernalia present
in terms of:
- Quantity
- Size
- Manufacturer 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 com pressed-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 labdt
• Maintain chain of custody
The DEA/EPA Task Force recommends that 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 evalu-
ation process.
The findings of the contamination report are not intended to
>ly that all contaminated sites have been located or that the
; have been decontaminated. It is meant as an aid to the
subsequent cleanup process, if necessary.
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 he al th and safe ty protocols, as discussed earlier, should
be applied throughout the disposal phase.
Except for evidentiary samples, no glassware or equipmen'
should be retained by law enforcement personnel. If neces-
sary, a prctrial 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 access
to \he laboratory for dismantling, packaging, marking, label-
ing, transporting, storing, and disposing of all .remaining
laboratory and obviously contaminated materials.
The DEAyUSEPA Task Force recommends'that law en-
forcement agencies select a properly qualified disposal
contractor. (See Sidebar Disposal Contractor Qualifica-
tions, this page.)
A law enforcement officer must be present to direct the entire
processing operation. The contractor should prepare mani-
fests and adhere to all applicable federal, state, and local laws
and regulations. (See Sidebar. Federal Hazardous Waste
Generator and Transporter Requirements, page 10.) Either
the disposal contractor or the law enforcement officer must
sign the appropriate manifest forms for the disposal of any
hazardous waste. The disposal contractor or law enforce-
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, materials,
personnel
Reasonable response time
• Use of a RCRA permitted or interim status dis-
posal facility
The knowledge and experience necessary to
manage and dispose of the hazardous materials
properly
ment officer may be given the authority to sign the manifest
on behalf of the designated agency. Once the laboratory has
been processed and the disposal contractor has left the site,
the law enforcement officer prepares to exit the laboratory
sue.
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
You Need to Know
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 determining
if wastes are hazardous, preparing waste for shipment, and transporting hazardous waste. States authorized by USEPA to administer the RCRA
program may have requirements goverm'i ^ 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.) .
Step 1. Determining H a waste Is hazardous:
Determine if the waste meets the definition of hazardous waste ac-
cording to 40 CFR 261. The waste may incfude listed" wastes (F-
List, K-List, U-List, or P-List) or may exhftst 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 OEA/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 (LOR) 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:
Acute Hazardous Waste-The "P-Lisr in40 CFR Part26i .33(e)
identifies commercial chemical products classified as acute haz-
ardous waste and subject to the requirements and quantities
determinations of Part 2615{e)w
Conditionally Exempt Waste — tf the total quantity of non-
acute hazardous waste on-site is less than 100 kilograms (and
the state also consttrs the small quantity generator waste con-
ditionally exemptpB»V40 CFR Part 261.5 requirements may
apply. CorKJitJon»:«empt waste may be disposed of in a
facility licensed by mi state-to manage municipal or industrial
solid waste as described in 40 CFR 2615(g)(3) (If all hazardous
waste on-site is conditionally exempt, Steps 2-7 are not re-
quired). :•'•"•
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 10 Number
Call the USEPA Regional Office or state environmentalagency for
a 'Provisional EPA Identification Number.* The number you are
given is site specific, for use only in connection with/hat site.
Step 3. Preparing Manifest and LOR 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 included with the manifest, 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 26232 (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
C as well as other requirements). (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 7. Placarding
Each shipment of hazardous waste must be placarded, or the initial
transporter m ust be offered the appropriate placards, in accordance
with DOT regulations for hazardous materials (See 49 CFR Part 172
Subpart F). :';•
jNote: To ensure the safety of DEA employees and to provide for a uniform, consistent policy, DEA contracts for the services of a qualified hazardous
•aste disposal company to safely and legally dispose of all non-evidentiary items as contaminated and, therefore treats them as hazardous wastes.
BEA's policy requires that the hazardous waste disposal company incinerate, whenever possible, all hazardous waste to minimize potential liability.
DEA recognizes the RCRA provisions (40 CFR Part 261 .'5) for conditionally exempt small quantity generators; however, based on safety and liability
considerations, DEA elects to manage their hazardous waste under the more stringent generator requirements under RCRA (40 CFR Part 262), which
minimizes liability.
10
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DEVELOPING A STATE OR LOCAL PROGRAM
Exiting the Site
Before exiting, the site must be secured and posted. The
posting should consist of a "hazardous materials" warning
"ign 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). All law enforcement
personnel and reusable equipment should be decontami-
nated before leaving the site.
Follow-up
A notice of the raid and seizure must be sent to the property
owner and/or rental agent by certified mail, with return
receipt requested. Copies of the notice letter, the contamina-
tion report, the drum packing lists, and a copy of the hazard-
ous waste manifest are also sent to the state and local health
and environmental protection agencies (See Appendix G).
These notification letters should be sent within a specified
time frame established by the agency.
The law enforcement agency's responsibilities end here.
Oversight of the cleanup of residual contamination should
be the responsibility of the lead state agency.
Cleanup of Residual Contamination
This section provides guidance for cleaning up residual con-
tamination remaining after the initial bulk disposal of haz-
ardous wastes which occurs as part of the seizure of a clan-
destine drug laboratory. This includes the disposal or decon-
tamination 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, guid-
ance 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. Refer-
ences are cited in appropriate sections and listed at the end of
document. Many can be readily obtained through the
mal Technical Information Service (NTIS), 5285 Port
al Road, Springfield, VA 22161. (703) 487-4600.
Few clandestine drug laboratory sites will pose a public
health or environmental risk justifying designation as a
Superfund removal site. However, there may be low levels
of residual contamination which necessitate some degree of
cleanup. Therefore, USEPA and state guidance related to
hazardous waste site evaluation may be helpful
In rare cases, a raided site may pose an imminent and substan-
tial hazard to the public health, welfare or environment, and
require an emergency response. Such situations would likely
be discovered during the laboratory seizure. In such cases,
appropriate state and federal agencies should be contacted
via the National Response Center (NRC) as stated on ttas
page.
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 whether additional releases of hazardous
substances from the site, which could pose a hazard
or threat to the public health, may occur.
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 labora-
tory seizure)
• Date and time the incident occurred or was
discovered ;
• Name(s) of material(s) spilled or released
• Cause of the release
• Total quantity discharged
• Whether material was released to ai., ground,
water, or subsurface
• Amount spilled into water
• 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 j
n
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
• 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-terrh public health or environ-
mental threat exists.
The DEA/USEPA Task Force recommends that the
state lead agency initiate the site evaluation process
after notification oy the law enforcement agency. This
process should commence within a specified time frame
established 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 Con-
tingency 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 documentation require-
ments (References lOand 12-15). These approaches can be
scaled down to fit the requirements of a particular clandes-
tine drug laboratory site.
•Vhat 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, industrial
hygienists, and lexicologists.
The basic steps for conducting the site evaluation process
are as follows:
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 lawenforcement 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-
12
lamination areas. Samples from potentially contami-
nated 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 groundwater, and vegetation samples
should be taken if it is suspected that outdoor dump-
ing occurred. Proper sampling technique and sample
identification procedures should be employed. The
types of chemical analyses to be conducted should be
based on a knowledge of the type of clandestine drug
laboratory operation. If on-site sampling is under-
taken, the state lead agency may need appropriate
authorization to enter the property and take samples.
Off-site survey/sampling - Identify surrounding land
use, population, and water supplies to determine who
might be affected should hazardous substances be re-
leased from the site. Identify sensitive human popu-
lations or wildlife habitats. Appropriate 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, contaminated 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 concen-
tration of contaminants, toxicity and chemical char-
acteristics of the materials, possible routes of chemi-
cal 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
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 con-
tamination will be useful in designing sampling protocols
and cleanup strategies. Primary areas of contamination are
as follows:
r ,
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DEVELOPING A STATE OR LOCAL PROGRAM
Processing ("cooking") areas near water or sewer
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), groundwatcr (sur-
face or artesian well), sewer or storm-water system,
septic system, cesspools, caves, mines
• Storage areas
Causes: spills, leaks
Secondary areas of contamination are as follows:
Locations where contamination has migrated (e.g.,
hallway where materials have been carried on shoes)
• Atmospheric emissions: venting, air releases from
processing equipment
• Surfaces on which vented materials could be depos-
ited (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, result-
ing 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 there-
fore influence indoor air concentrations in base-
ments or other rooms in a building.
_What Are the Possible Courses
Action?
In considering the need for residual cleanup or decontamina-
tion actions at clandestine laboratory sites, it is likely that
primary emphasis will be placed on the suitability of the
13
building structure for rehabitation. When there is sufficient
concern that a release or potential release of hazardous
substances threatens the public health, welfare, or the envi-
ronment, 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 significant
contamination of well water or groundwater from indis-
criminant dumping of hazardous substances has occurred.
Furthermore, both acute and chronic health risks to sur-
rounding inhabitants, particularly sensitive populations such
as children or the elderly, need to be assessed. Guidance for
conducting these more detailed assessments are found in
USEPA documents (References 16-19).
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. OSH A
requirements arc outlined in 29 CFR 1910.120and standard
operating procedures, guidelines and factors to consider are
found in NIOSH and USEPA documents (References 20-22).
One of the following types of actions will generally be
appropriate:
No further action required
Residual cleanup/decontamination
No Further Action Required
This decision is made when it is determined that (a) the
concentration of hazardous substances present in the samples
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 problem.
Additional cleanup activities are therefore necessary to make
the building safe for rehabitation and to reduce the health risk
and aesthetic nuisance to local residents in the surrounding
area.
The disposal of all wastes generated during the cleanup/
f
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
decontamination activities should be managed in compliance
with USEPA and USDOT regulations outlined on page 10.
Compliance with these regulations is the responsibility of the
party managing the cleanup/dffcontamination 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 possible,
all furnishings, draperies, carpeting, paneling, wood trim,
wallpaper, wallboard (anything easily dismantled or dis-
assembled) that have been contaminated. These materi-
als should be disposed of through a qualified disposal
contractor either by incineration or landfilling in properly
permitted facilities. The procedures for proper waste dis-
posal outlined on page 10 should be folio wed. If removal
methods are impractical, decontamination methods may
be useful.
• Decontamination — Decontamination is the process of
physically removing the contaminant from the contami-
nated object/material, limiting access to the contaminant,
or changing the chemical nature of the contaminant to
render it harmless.
Venting — Where solvents are slowly vaporizing in-
doors, proper ventilation and air monitoring/surveillance
techniques discussed in the "assessment" phase will, in
many cases, effectively reduce air concentrations of va-
pors and decrease odor. Removal or washing 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 Cook for signs of corro-
sion), neutralization with sodium bicarbonate solution
for acids or weakly acidic wash solutions (e.g., vinegar,
acetic acid) for basewespectively, may be useful. Use of
strong alkaline or acidic wash solutions on contaminated
surfaces or objects flUy result in exothermic reactions
and the release of toxic fumes.
• Detergent-Water Washing — Nonporous surfaces, such
as floors and tiles, may be decontaminated with detergent
(or surfactant) and water solutions. Steam cleaning or
high pressure washers may be useful for larger areas of
contamination.
Encapsulating or Sealing — Where no other alternatives
are available, sealing the contaminated surface with poly-
u re thane, or with materials like those used to contain as-
bestos may be considered.
In the event of outdoor contamination (i.e., soils, surface or
You Need to Remember
The most important things you should re-
member 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 clandestine drug laboratory pro-
grams need special medical certification
and regular medical monitoring..
3) Law enforcement personnel n,eed spe-
cialized training regarding the investiga-
tion and seizure of clandestine drug labo-
ratories.
4) The clandestine drug laboratory raiding
team needs specialized equipment and
training in its use.
5) Only representative samples are needed
for evidence. All other materials, equip-
ment, and glassware should be disposed
of for environmental and health and safety
reasons.
6) Only qualified hazardous waste disposal
contractors should be used to dispose of
waste.
7) The proper state health, safety, and envi-
ronmental agency should be notified
about the laboratory seizure.
groundwatcr), several actions may be considered depending
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 processing
• Drainage control
• Removal or treatment of contaminated soils and water
Provision of alternative water supplies for those exposed
to contaminated wellwater
The presence of extensive outdoor contamination may pres-
ent a potential acute or chronic health hazard. Geanup strate-
gies should be coordinated with state or local health agency
to ensure that the public health and welfare is being addressed.
14
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SUMMARY OF
JOINT DEA/USEPA
TASK FORCE
RECOMMENDATIONS
1. Each state should appoint a lead agency to assume responsibility for developing and.
implementing a program for the cleanup of clandestine drug laboratories. The
designated lead agency may wish to transfer authority to local agencies which have
the capability to respond to these situations.
2. Personnel medical screening and training programs should be considered an essential
part of a clandestine drug laboratory program.
3. State or local law enforcement agencies should require that their personnel wear
protective clothing such as ballistic vests and fire retardant suits, when seizing
clandestine drug laboratories (initial entry).
4. Some clandestine drug laboratories (i.e., those producing LSD, fentanyl, alphapro-
dine, MPPP, and other analogs) should not be ventilated after seizure because of the
potential for human exposure to the extremely toxic dusts and /or vapors.
5. The law enforcement agency should prepare a contamination report that will assist
the state lead agency in carrying out its site evaluation process.
6. All chemicals and associated glassware, equipment, and contaminated materials in
the clandestine drug laboratory should be managed as if they are hazardous wastes.
7. Law enforcement agencies should select a qualified disposal contractor to remove all
chemicals and associated glassware, equipment, and contaminated materials from the
clandestine drug laboratory site.
8. The state lead agency responsible for cleaning up clandestine drug laboratories
should 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.
15
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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 Publications,
Davis, CA.
3 Clayton, G.D. and Clayton, F.E. (eds.). 1981. Patty's
Industrial Hygiene and Toxicology, 3rd Ed., John
Wiley and Sons, New York, NY.
4 Gosselin, R.E., Smith, R.F., Hoage, H.C., and I.E.
Braddock, 1984. Clinical Toxicology of Commercial
Products, 5th Ed., Williams and Wilkins, Baltimore,
MD.
Klaassen, C.D., Amdur, M.O., and J. Doull, 1985.
Casarett and Doulfs 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 Publica-
tions, Park Ridge, IL.
8 Verschueren, K., 1983. Handbook of Environmental
Data on Organic Chemicals, Van Nostrand Reinhold
Co., New York, NY.
9 Windholz, M. (ed.), |f83. The Merck Index, 10th Ed.,
Merck and Co., Rahwty, NJ.
1 0 National Oil and Hai&dous Substances Pollution
Contingency Plan, 40 GFR 300, Nov. 20, 1985.*
1 1 Superfund Removal Procedures (Revision Number
Three), Feb., 1988. OSWER Directive 9360.03B.
U.S. EPA, Office of Emergency and Remedial Re-
sponse, Washington, DC.
12 Preliminary Assessment Form Guidance, EPA Form
Potential Hazardous Waste Site Preliminary
reliminary Assessment Guidance FY 1988, (U.S.
EPA Document No. 934.0-01).*
14 Expanded Site Inspection Transitional Guidance FY
1988, (U.S. EPA Document No. 9345.1-02).*
15 Site Inspection Form Guidance (EPA Form 2070-13),
Potential Hazardous Waste Site Report*
16 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 , US
EPA, Washington, DC.
17 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.*
18 Superfund Exposure Assessment Manual, Office of
Emergency and Remedial Response, Office of Solid
Waste and Emergency Response, US EPA, Washing-
ton, DC.*
19 U.S. EPA Toxicology Handbook, Principles Related to
Hazardous Waste Investigations, 1985.*
20 Standard Operating Safety Guide, 1988, U.S. EPA,
Office of Emergency and Remedial Response, Wash-
ington, DC.*
21 Protecting Health and Safety at Hazardous Waste
Sites: An Overview, EPA/625/9-85/006, U.S. EPA,
Cincinnati, OH.*
22 Occupation Safety and Health Guidance Manual for
Hazardous Waste Site Activities (DHHS/NIOSH
Publication No. 85-115).*
23 The Report of the Oregon State Health Division's
Clandestine Drug Laboratory Committee "Chemical
and Toxicity Assessment of Illicit Methamphetamine
Manufacture." April, 1988.
24 Understanding The Small Quantity Generator Haz-
ardous Waste Rules: A Handbook for Small Business,
EPA/530-SW-86-019. Office of Solid Waste and
Emergency Response, U.S. EPA, Washington, DC.*
* These publications may be obtained from the National Technical
Information Service (NTIS). 5285 Port Royal Road. Springfield, VA
22161, (703) 487-4600
16
r
-------
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
MOV Memorandum of Understanding
NCP National Oil and Hazardous Substances Pollution Contingency
Plan; National Contingency Plan
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
17
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
GLOSSARY
Acute Wxicity. Adverse health effects resulting from a brief exposure
to a chemical substance or mixture. The effects may be reversible
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 enforcement
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 ID a permitted waste disposal facility.
Chronic toxidty. Adverse health 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 PL91-513.
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 decontami-
nating their surfaces.
Combustible. A term used by the National Fire Protection Association
(NFPA), Department of Transportation (DOT), and the Occupa-
tional Safety and Health Administration (OSHA) to denote sub-
stances that will burn, usually with a flashpoint greater than 100
degrees F (38 degrees Celsius).
Condemnation. The legal act of declaring a property unfa for use by
the public.
Contamination report. A report completed by the law enforcement
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 enfomment in (he Untied States and establishes
regulations and activities governing controlled substances.
Controlled substance analog. A chemical derivative of a known
illicit drug; "designer" drugs.
Corrosive. Under RCRA regulations (40 CFR 261.22), a substance is
corrosive if it corrodes metal (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.
Deactivation. Sec "Dismantling."
ntamination. The process of removing chemical contamination
from surfaces by washing or by chemical treatment.
Signer 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 appropriately
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, and quamitate by 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. The process, initiated by calling the National
Response Center (NRC), of evaluating, and if necessary, taking
actions to reduce or prevent the release of a hazardous1 substance into
ihc environment that may pose an imminent and substantial threat
to the public health or environment.
Entry. Apprehension and removal of clandestine drug laboratory opera-
tors by law enforcement agents.
E videnciary Samples. Samples of drugs and other items collected by
a certified chemist at a clandestine laboratory site- to be used as
evidence against the perpetrator(s). Samples are taken prior to bulk
disposal of the chemicals and other materials.
Explosive. A material producing a sudden, almost instantaneous release
of pressure, gas, and heat when subjected to abrupt shock, pressure
or high temperature.
Exit. Final inspection of the laboratory after processing and posting of (he
premise.
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 bum. 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 panicles 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 haza*u-
ous waste identified or listed in Pan 261 of RCRA regulations or
whose act first causes a hazardous waste to become subject to
regulation.
Hazardous substance. Chemical substances, elements, mixtures, or
solutions variously defined or listed under a number of federal and
state regulations. Some of (he pertinent federal regulations are:
CERCLA (Section 101.102); RCRA (Sections 3001.3002); TSCA
(Section 7); Federal Water Pollution Control Act (Sections 307 [a].
3ll(b] [2] [A]); and the Clean Water Act (Section 112).
Hazardous waste. A hazardous waste as defined in 40 CFR Pan 261
of RCRA regulations or pertinent state regulations.
18
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX A
Chemical properties and Health Hazards Associated with Chemicals Commonly Found at Clandestine Drug Laboratory Sites.
Tables were adapted with permission of the Oregon State Health Division (see Reference 23).
TABLE A-l CYANIDES
i
i
Substance
1
Sodium Cyanide
Potassium Cyanide
Benzyl Cyanide
Hydrogen Cyanide
Form
Solid
Solid
Liquid
Gas, Liquid
Exposure
Skin, Eyes, Ingestion
Skin, Eyes, Ingestion
Skin, Eyes, Inhalation, Ingestion
Inhalation
EPA Hazardous
Ws^te Numbers* !
P106
P098
P063
Health Effects:
Highly toxic substances. If solid salt forms come in contact with acid, hydrogen cyanide gas will be released. Inhalation of
hydrogen cyanide may result in rapid progression of symptoms to respiratory failure, coma and death. Ingestion of the salts
mav also lead to these symptoms, but hydrogen cvanide gas poses the greatest exposure risk.
TABLE A-2 IRRITANTS AND CORROSIVES
Form
Substance
Exposure
EPA Hazardous
Waste Numbers*
Acetic Acid*
Acetic Anhydride*
Ikceryl Chloride
Ammonia
Ammonium Hydroxide
Benzyl Chloride*
Dimethylsulfate
Formaldehyde
Formic Acid
Hydrogen Chloride/
Hydrochloric Acid
Hydrobromic Acid
Hydriodic Acid
Hydroxylamine**
Methylamine*
Methylene Dichloride*
Methyl Methacrylate
Nirroethane**
Oxalylchloride"
Perchloric Acid
Phenylmagnesium Bromidea '
Phosphine*
Phosphorus Oxychloride
Phosphorus Pentoxide
Sodium Amide (Sodamide)"
Sodium Metal
Sodium Hydroxide
Klfur Trioxide
Ifuric Acid
trahydrofuran'-"
Thionyl Chloride
• Refer to 40 CFR 261.33 for i detailed listing.
Liquid
Liquid
Liquid
Gas
Liquid
Liquid
Liquid
Gas, Liquid
Liquid
Gas, Liquid
Liquid
Liquid
Liquid, Solid
_Gas, Liquid, Solid
Skin, Eyes,
Skin, Eyes,
Skin, Eyes,
Skin, Eyes,
Skin, Eyes,
Skin, Eyes,
Skin, Eyes,
Skin, Eyes,
Skin, Eyes,
Skin, Eyes,
Inhalation
Inhalation
Inhalation
Inhalation
Inhalation
Inhalation
Inhalation
Inhalation
Inhalation
Inhalation
Liquid
Liquid
Liquid
Liquid
Liquid
Gas
Solid
Solid
Solid
Solid
Liquid, Solid
Liquid, Solid
Liquid
Liquid
Liquid
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin, Eyes, Inhalation
Skin
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
U006
P026
U103
U122
U123
U162
P096
U213
20
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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 comeal injury.
Inhalation may 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
kconcentrations of vapor may cause skin irritation. Additional symptoms of vapor inhalation may include headache, nausea,
Dizziness and anxiety. Phosphine may detoivate, and has the odor of decaying fish. Direct contact with corrosives may result
in severe eye or skin bums. Methyl methacrylate skin exposure may result in contact dermatitis and sensitization.
Formaldehyde 13 a suspected human carcinogen. Formic acid ingestion or inhalation may result in kidney or liver damage.
Sodium metals react violently with water. Tetrahydroforan and Perchloric Acid can form explosive crystals.
1 Flammable
b Explosive
TABLE A-3 SOLVENTS
i
'Solvents
Acetone*
Acetonitrile*
Aniline
Benzene1
Benzylchloride*
Carbon Tetrachloride
Chloroform
Cyclohexanone*
Dioxane
Knol'
1 Acetate*
, 1 Ether*
Freon 11
(trichloromonofluromethane)
Hexane*
Isopropanol*
Methanol*
Methylene Chloride
(dichloromethane)
Petroleum Ether*
Pyridine*
Toluene*
o-Toluidine*6
Form
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
Liquid
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
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
• Refer to 40 GFR 26133 for a dcUiltd Itottng.
Health Effects:
•f-'~'
Inhalation of vapors at low concentrations may result in mild eye, nose and throat irritation. Symptoms of intoxication
(drowsiness and incoordination) or loss of consciousness may occur a t high concentrations. Liver and kidney impairment may
also occur at high doses, or with prolonged exposure. Benzene is a known human carcinogen. Chloroform, carbon
tetrachloride, dioxane, o-toluidine, and methylene chloride are probable human carcinogens. Spilling of freon on the skin
may result in freezing injury. 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.
taunable
(plosive
21
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
Table A-4 Metals/Salts
Substance
1
Aluminum Chloride
Magnesium
Palladium
Red Phosphorus6
Iodine
Mercuric Chloride
Lead Acetate
Lithium Aluminum Hydride*11
Lithium Hydroxide
Raney Nickel'6
Sodium Acetate
Sodium Hydroxide
Sodium Metal1"
Potassium Metal*b
Thorium Salts
Form
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid
Solid in kerosene
Solid in kerosene
Solid
EPA Hazardous
Exposure Waste Numbers*
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
• Refer to 40 CFR 261.33 for a detailed listing. Currently, none of that 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
un the presence of moisture. Lithium aluminum hydride, and sodium and potassium metal are extremely reactive with air
|bnd 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 exposure 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.
• Flammable
b Explosive
Table A-5 Other Hazardous Precursors, Solvents, Reagents, Drug Products and By-Products Found in Clandestine Druj;
Laboratories :
Substance " Form Exposure Health Hazard
Cyclohexanone . Liquid Skin Irritant
Fentanyl Solid Inhalation, Skin, Eyes Narcotic drug product causing respritatory
failure at extremely low doses (i.e., a few
grains of dust)
Hydrogen Gas Inhalation Flammable, Explosive
Lysergic Acid Diethylamide Powder Ingestion, Inhalation Hallucination at extremely low doses
MPTP, MPPP Solids Inhalation, Skin By-product or intermediates of alpha-
prodine laboratories. (Extremely low doses
may cause irreversible Parkinson's disease.)
Methylfentanyl Solid Inhalation, Skin, Eyes See "Fentanyl"
Phenylaceric Acid Solid Skin, Eyes Irritant
Aenyl-2-Propanone Liquid Skin, Inhalation Irritant; few toxicity data available
(phenylacetone)
Piperidine Liquid Skin, Inhalation Irritant; few toxicity data available
• MPTP (l-methyl-4-phenyl-l, 2,3,6-tetrahydropyridine); MPPP (l-methyl-4-phenyl-4-propionoxypiperidine)
22
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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 attend-
ing the Safety School.
CLANDESTINE LABORATORY INVESTIGA-
TIVE SCHOOL CURRICULUM (26-36 Hours)
Course Title
Introduction to & History of
Clandestine Laboratories
Initiation and Development of
Gandestine Laboratories
Role of the Chemist
Role of the Prosecutor
Search Warrants
I Raid Planning
iLaboratory Syntheses
•financial Aspects
Bombs and Booby Traps
Drug Analogs
Hours
2
6-8
1-2
1-2
2-4
1-2
6-8
1-2
3-4
2
CLANDESTINE LABORATORY SAFETY
SCHOOL CURRICULUM (32-36 Hours)
Course Title Hour$
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, DEA has also developed the
Advanced Clandestine Laboratory Safety School in
response to the OSHA requirement for 24 hours of
annual refresher training which an individual needs to
maintain in order to enter hazardous laboratory sites.
ADVANCED CLANDESTINE LABORATORY
SAFETY SCHOOL CURRICULUM (28-32 Hours)
Course Title Hour;
Review of Clandestine Laboratory 3
Safety School
SCBA Review 3-4
Air Monitoring Review 3-4
SCBA Instrument Lab 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:
DEA/FBI Academy
Bldgl2TRDF
Quantico, VA 22135
Attn: Domestic Field Training Unit
23
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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 laborato-
ries. In addition to traditional law enforcement activities, the examinee will be required to use personal protective equip-
ment 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 ncoprene boots, chemically resistant
gloves, and a chemically resistant (vapor barrier) suit of Tyvck or Sarancx.
Type of Work: Includes pursuit, confrontation, control and arrest of suspects which may involve strenuous physical
ctivity. Includes light to moderate exertion while wearing personal protective equipment with increased work of breath-
, 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, rcactants and by-products of chemical reactions,
controlled substances in solution or powdered form. Includes work indoors and outdoors in extremes of seasonal envi-
ronmental temperatures and humidity. Prior acclimatization 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
Medical Certification
I examined ; on and
(Name) (Date)
»d the individual to be medically able to perform the duties described above without unusual medical risk of harm to
individual or others.
Physician's Signature Date
Physician's Name
24
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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 considered
for a medical clearance to work in clandestine drug laboratories. Additional elements nay 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 claus-
trophobic reactions.
History of heat injury.
Medications, smoking history, alcohol use
Reproductive history
"Exercise Capacity
Occupational and Exposure History
II. General Medical Examination:
Vital signs. Examination with emphasis on the skin, respiratory, cardiovascular, hepatic and neurologic sys-
tems.
IH. 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.
Ikrcise stress test, chest radiograph and other medical tests if medically indicated.
25
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX D
Contamination Report
A. LABORATORY TYPE AND HAZARDS
Labc-atory Type (Check)
-] Methamphetamine
~ Cocaine
-P2P
-LSD
i-
™
Amphetamine
Fentanyl
PCP
Other (Specify)
Production Method:
Potential Chemical Hazards (Check)
-
~
~
Respiratory Tox.
Systemic Tox.
External Tox.
Carcinogens
Corrosives
-
Flammables
Explosives
Oxidizers
Pyrophortcs
Water Reactives
Specific High HazafcTchemical:
Other Potential Hazards (Check)
r-|
M
Com Gas Cyldr
Heat Stress
Cold Stress
Confined Space
Limited Egress
Poor Visibility
i-
~
—
Sllp/Trlp/Fall Haz.
Electrical Shock
Bum Hazard
Leaking Containers
Damaged Structure
Excavation
Other:
.
B. SITE DESCRIPTION
LAB ADDRESS
SITE LOCATION AND DESCRIPTION
STRUCTURE DESCRIPTION
Location of Laboratory Processing Area
(i.e., Kitchen, Bathroom, Basement, etc.)
Estimated Lab Size
Small Med. Large
• Approximate square footage
C. HAZARD ASSESSMENT FINDINGS
LEL
% OXYGEN
PPM
LOCATION IN LABORATORY
DRAEGER TUBES RESUIJS Factor Adjusted
Check all used/tested (eteta) COLOR (changed to) LEVEL pPM * Conversion - Reading
Maximum
Value
Acetic Add - 5/a __•»•-
Acetone -100b ---: * - '
Benzene - .5/a ..._*-
Carbon OisuHide • .04" «. -
Ethyl Acetate - 200/a «• •
Formic Acid • 1/a •»• -
Hydrocyanic Acid - 5/ + -
Methanol - 50/a •*• -
0-Toluidine • 1/a •»• •
Trichloroethane - 50/d + •
Triethylamine • 5/a * -
^COMMENTS (Include additional information, such as poor walking surfaces, limited work space, obstacles, limited egress, etc.;
26
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APPENDIX D
SECTION E. POSSIBLE CONTAMINATION FOUND INDOORS:
floors
walls
ceilings,
Attach diagram of room(s), 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 chemincals, including container type, size, contents (write "UNK" if
unknown) and describe color or appearance of contents, if possible volume of mass. Include compressed gas
cylinders, and include equipment and paraphernalia present.
Attach a copy of the hazardaous 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
Laboratory Type: Write in ihe production method if known or sutpect (example: rnethampheumine via red phosphonis/hydriodic acid).
Potential Chemical Hazards: List any specific highly hazardous chemicals known or suspected of being present (example: ether, thionyl chloride,
red phosphonis. etc.)
Other Potential Hazards: Check all boxes indicating known or impeded hazards. List any other known or suspected hazards (example: low
overhead, unstable container storage, booby traps, etc.)
SECTION 0 SITE DESCRIPTION
Site Location and Description: (Example: detached girage 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 bam, no windows; small warehouse, fire
damaged with opposing roll upltoon).
SECTION C HAZARD ASSESSMENT FINDINGS. During initial assessment, measure and record findings as indicated.
LEL • (Lower cxpisyiv* limit level) (Example: 1%. 15%, etc.)
% Oxvaen - (penMl ostygen) (Example: 21%, 18%. etc.)
PPM • (pans pwJflMort (Example: 100 ppm, 350 ppm)
Location in, tfffl Mi" P«»cribt each location where a series of three measurement* were taken. (Example: front door, southeast comer of bathroom)
Draeter Tubes - Q_Mk name of each tube to be usedAested.
After the teat, cireh + for color changes, and circle - for no color change.
Describe color change (example: dark brown, etc.).
Record the ppm level reading from lube.
Write in the conversion factor, if necessary, according to instructions with the tubes for substances related to those for which the tube is specifically
designed (Example: 2,3, 4).
Calculate an adjusted reading, Le,, ppm x conversion faaor (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.
ON G INVENTORY • self explanatory.
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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. 1 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.
28
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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 of 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
29
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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
i
(Address Including Zip Code), on (Date of Seizure). A clandestine drug
laboratory was seized and hazardous chemicals and/or waste were found at the
said property. Hazardous chemicals and substances were seized by (Agency
Making Seizure) and have been disposed of 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 fetter 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
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX H
UNIFORM HAZARDOUS
WASTE MANIFEST
1 Generator'* US EPA ID No.
Manilas!
I Document No.
2. Pago 1
ol
3. Generators Nam* «nO Mailing AdoTtu
Anyplace State Police
111 State Street, Hometown, CA 00932
*. Generator-* Phone
A. Slate Manila*! Document Number
87133329
8. Stale Gereratorl 10
H|Y|H|A|8|3|8|9|7|7|2|0|
5. Transporter 1 Company Name 6. US EPA 10 Number
Anyplace Environmental Management Cor^j flj p| 9| fl| Q| gj 4[ jl 8 J3
C. State Transporter1! 10 6001
0. Transporter* Pnone 916/985-6666
7. Transporter 2 Company Nam*
8. US EPA 10 Number
6. Stale Transporter* IfJ
11
f. Transporter1* Phone
». Designated Facility Nam* and S»e Address 10. US EPA 10 Number
Anyplace Environmental Management Corp.
11855 White Rock Rd. .
Smithville, CA 95670 1 C ND I9 i8 1° I8 I4
G. State Facrfity'* 10
|c|AlD|9|8|8|a|4|l|8|3
n. Pacimy'ft Vtion*
II 18 13
916/985-6666
11. US DOT Oeaehption (including Proper Shipping Name. Hazard Oats, and 10 Number)
12. Container*
NO Type
13. Total
Quantity
14.
UrU
Wl. Vol.
R.Q., Waste Ethyl Ether, (D001J
Flammable Liquid, UN 1155
Stna
212
ojoli
D|M
lalolo
EPA/Oner
D001
Waste Poison B, Solid, N.O.S,
Poison B, UN 2811
Sate
331
o|o|i
D|M
hlolo
EPA/Otnsr
SUM
EPA/Other
Slate
EPA/Other
J. Aoanona! Deaoiplions lor Matenaii LJsied Above
11. b. contains ephedrine
K. Handling CoOet lor Wattes Lisiefl Above
a. b.
is. Special Handing inavvemra and Additional information
Inhalation hazard - wear proper respirator
Avoid skin Contact - wear boots, gloves, goggles
16.
GENERATOR'S CERTIFICATION: ITwfepy declare that the content* ol ini* contignmeni are fully and accurately Oeacrtbed above by proper thipping name and
are n»«fj«««i pactud. meAed. end Hbetert. and are « all nnpecit in proper condHan lor transport by highway according 10 applicable international and national
K I am i large quamly gerevuor. I eertty thai I have a program in place to reduce the volume and toiicity ol waai* generated to ine degree I nave determined to be
econommly pnwMfee) and trw I have Mlected the praeticabi* mMnoa ol treatment, norage. or dispoaal currently available to me wricn mimmuee tne preeen
and future trraal l*.IHMn haMh and tne emrrenmert; OR. 1 1 am a (mall quantity generator. I have made a good larth ettofl to rmrumae my wade generation and
uiect the beet «Me) •Mrngimiri method that k available to mttM that I can afford.
Primed/Typed Harm J<}hn joneSr «on behalf of
Anyplace State Police"
Signaturi
Uanm Oty Vear
17. Transporter 1 Acxnow»edoerneni ot Receipt ot Material*
PrlmeoVTyped Nam*
Signature
Monm Oty Vear
I I I I I I
it. Tramponer 2 Ackfiowtedgemeni of Receipt ol Material*
Printed/Typed N«m»
Signature
Montt Oar Vear
I I I I M
19. Discrepancy Indication Soaee
20. Facility Owner or Operator Certification ol receipt of hazardous maienaM covered by thi* manifest eieept a* noted In Mm 19
Primed/Typed Nam*
Signature
MonOI D*Y r*«r
II I I I 1
32
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APPENDIX I
Drug Enforcement Administration
Division Offices
Atlanta Field Division
Richard B. Russell Federal Building
75 Spring St., SW, Room 740
Atlanta, G A 30303
(404) 331-4401
Boston Field Division
50 Stamford SL, Suite 200
Boston, MA 02114
(617) 565-2800
Chicago Field Division
500 Dirksen Federal Building
219 S. Dearborn SL
Chicago, IL 60604
(312)353-7875
Dallas Field Division
1880 Regal Row
Dallas. TX 75235
(214) 767-7151
Denver Field Division
721 19th SL, Room 316 (ZIP 80202)
P.O. Box 1860 (ZIP 80201)
Denver, CO
(303) 844-3951
Detroit Field Division
357 Federal Building
231 West Lafayette
Detroit, MI 48226
(313) 226-7290
Houston Field Division
Suite 300
3 33 West Loop North
Houston, TX 77024
(713)681-1771 .-•
Los Angeles Field Division
Suite 800
350 South Figueroa SL
Los Angeles, CA 90071 _
(213894-2650
Miami Field Division
8400 N.W. 53rd SL
Miami. FL 33166
(305) 591-4870
Newark Field Division
806 Federal Office Building
970 Broad SL
Newark, NJ 07102
(201) 645-6060
New Orleans Field Division
Suite 2200
1661 Canal SL
New Orleans, LA 70112
(504) 589-3894
New York Field Division
Suite 1900
555 W. 57th SL
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 201
One North First St.
Phoenix, AZ 85004
(602) 261-4866
San Diego Field Division
402 W. 35th SL
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, W A 98119
(206) 442-5443
St. Louis Field Division
Suite 500
791 IForsythe Blvd.
United Missouri Bank Bldg.
St. Louis, MO 63105
(314)425-3241
Washington Field Division
Room 2558
400 Sixth SL, S.W.
Washington, DC 20024
(202) 724-7834
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GUIDELINES ON CLANDESTINE DRUG LABORATORIES
APPENDIX J
EPA Hazardous Waste Regional Contacts
Region I
Director
Waste Management Division
US EPA Region I (HAA-1903)
JFK Federal Building, Rm 2203
Boston, MA 02203
(617) 565-3698
Region II
Director
Air & Waste Management Division
US EPA Region II (AWM)
26 Federal Plaza, Room 900
New York, NY 10278
(212) 264-2302
Region in
Director
Waste Management Division
US EPA Region III (3HWOO)
841 Chestnut St.
Philadelphia, PA 19107
(215)597-8131
Region IV ,
Director
Waste Management Division
US EPA Region IV
345 Courtland Su N.E.
Atlanta, GA 30365
(404) 347-3454
Region V
Director
Waste Management Division
US EPA Region V
230 South Dearborn St.
Chicago, IL 60604
(312)886-7579
Region VI
Director
Air & Waste Management Division
US EPA Region VI (6H)
First Interstate Bank Tower
1445 Ross Avenue
Dallas, TX 75202
(214)655-2100
Region VII
Director
Waste Management Division
US EPA Region VII
726 Minnesota Ave.
Kansas City, KS 66101
(913) 236-2850
Region V1H
Director
Waste Management Division
US EPA Region VIII
999 18th St., Suite 500
Denver, CO 80202
(303)293-1719
Region IX
Director
Waste Management Division
US EPA Region DC (T-1)
215 Fremont Street
San Francisco, CA 94105
(415) 974-7460
Region X
Director
Hazardous Waste Division
US EPA Region X (HW-111)
1200 Sixth Avenue
Seattle, WA 98101
(206)399-1352
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