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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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. ------- 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). _ ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 , ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. 27 ------- 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 ------- 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 ------- 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 30 ------- 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 ------- 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 33 ------- 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 34 ------- |