methamphetamine: information for community leaders and … · health effects of use and exposure,...

Methamphetamine:InformationforCommunityLeadersandConcernedCitizens

Credits from top left: Crystal methamphetamine, National Association of CountiesCar trunk lab, Georgia Environmental Protection Division Laboratory take-down, National Association of Counties

EPA 600/XXX/XXXMay 2007

Methamphetamine:InformationforCommunityLeaders

andConcernedCitizens

National Risk Management Research LaboratoryOffice of Research and DevelopmentU.S. Environmental Protection Agency

Cincinnati, OH 45268

i

Notice

This document is a final draft. It has not been formally released by the U.S. Environmental Protection Agency and should not at this stage be construed to represent Agency policy. It is being circulated for comments on its technical merit and policy implications. Mention of trade names or commercial products does not constitute endorsement or recommendation for use.

ii

Preface

This report was developed as a general information resource for individuals involved in problems stemming from the illegal manufacture and use of methamphetamine. It provides a general description of the occurrence and methods of manufacture, the health effects of use and exposure, government programs addressing all aspects of use and manufacture, the regulatory setting for methamphetamine laboratory cleanup, approaches to cleanup, and effects of illegal drug manufacturing on property values and redevelopment. An Appendix contains information on the health effects and environmental fate and transport of chemicals commonly used in the manufacture of methamphetamine. The report is not intended as a “how-to” guide, but rather as a general reference with an extensive set of Internet links to sources of more detailed information. The methamphetamine arena is rapidly changing in terms of regulatory setting, in programs designed to assist individuals and government agencies in coping with the problems stemming from methamphetamine manufacture and use, and in developing appropriate cleanup approaches and health guidelines. For the most up-to-date information, readers are encouraged to consult the identified Internet resources.

iii

Foreword

The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the Nation’s land, air, and water resources. Under a mandate of national environmental laws, the Agency strives to formulate and implement actions leading to a compatible balance between human activities and the ability of natural systems to support and nurture life. To meet this mandate, EPA’s research program is providing data and technical support for solving environmental problems today and building a science knowledge base necessary to manage our ecological resources wisely, understand how pollutants affect our health, and prevent or reduce environmental risks in the future.

The National Risk Management Research Laboratory (NRMRL) is the Agency’s center for investigation of technological and management approaches for preventing and reducing risks from pollution that threaten human health and the environment. The focus of the Laboratory’s research program is on methods and their cost-effectiveness for prevention and control of pollution to air, land, water, and subsurface resources; protection of water quality in public water systems; remediation of contaminated sites, sediments, and ground water; prevention and control of indoor air pollution; and restoration of ecosystems. NRMRL collaborates with both public and private sector partners to foster technologies that reduce the cost of compliance and to anticipate emerging problems. NRMRL’s research provides solutions to environmental problems by developing and promoting technologies that protect and improve the environment, advancing scientific and engineering information to support regulatory and policy decisions, and providing the technical support and information transfer to ensure implementation of environmental regulations and strategies at the national, state, and community levels. This publication has been produced as part of the Laboratory’s strategic long-term research plan. It is published and made available by EPA’s Office of Research and Development to assist the environmental, public health, and law enforcement communities and to link researchers with their clients.

Sally C. Gutierrez, Director National Risk Management Research Laboratory

v

TableofContents

Notice………………………………………………………………………………………….....iPreface……………………………………………………………………………………….....iiForeword…………………………………………………………………………………........iiiListofFigures………………………………………………………………………………...viiListofTables………………………………………………………………………………....viiiAcronymsandAbbreviations……………………………………………………………....ixExecutiveSummary……………………………………………………………………….....xi1.0Introduction………………………………………………………………………….........1

1.1 Methamphetamine Production…………………………………………………........11.2 Trends in Occurrence………………………………………………………………… 21.3 Methamphetamine Lab Settings………………………………………………….....5

2.0RolesandResponsibilities…………………………………………………………......82.1 Federal Level Agencies…………………………………………………………........82.2 Tribal………………………………………………………………………………….....112.3 State………………………………………………………………………………….....122.4 Local…………………………………………………………………………………....122.5 Private…………………………………………………………………………………..12

3.0MethamphetamineManufacturingProcesses………………………………….....133.1 Birch Method……………………………………………………………………….....143.2 Red Phosphorus/Phosphorus Method……………………………………….......153.3 Emde Method………………………………………………………………………....163.4 Phenyl-2-Propanone………………………………………………………………....173.5 Appearance……………………………………………………………………….......173.6 Health Effects………………………………………………………………………....18

3.6.1Users……………………………………………………………………………....183.6.2Cookers……………………………………………………………………….......193.6.3CookerFamilies……………………………………………………………….....213.6.4Neighbors……………………………………………………………………….. .233.6.5LawEnforcement/FirstResponders………………………………………....233.6.6HospitalWorkersandEmergencyMedicalServicesPersonnel………...24

4.0RegulatorySetting……………………………………………………………………....244.1 Federal……………………………………………………………………………….....24

4.1.1CERCLA…………………………………………………………………………...254.1.2RCRA……………………………………………………………………………....264.1.3DEA……………………………………………………………………………......294.1.4EmergingDevelopments……………………………………………………....29

4.2 States………………………………………………………………………………......294.2.1PrecursorChemicals…………………………………………………………....304.2.2CleanupandRemovalProcessesandStandards…………………….......314.2.3VictimProtection……………………………………………………………......324.2.4ComplianceandEnforcement………………………………………………...33

5.0Removal…………………………………………………………………………………...34

vi

5.1 Active Lab……………………………………………………………………….........355.2 Inactive Lab……………………………………………………………………….......385.3 Discarded Materials……………………………………………………………........38

6.0Cleanup………………………………………………………………………….……......396.1 Cleanup Levels…………………………………………………………………….....406.2 Cleanup Guidance and Requirements for Structures………………………....426.3 Cleanup of Septic Systems…………………………………………………….......456.4 On-site Dumping and Open Air Labs……………………………………..……....466.5 Cleanup and Property Values………………………………………………..........47

7.0References………………………………………………………………………..........488.0AppendixA:PropertiesofChemicalsAssociatedwithMethamphetamine. . .A-1

vii

ListofFigures

Figure1. Total of All Clandestine Laboratory Incidents Including Labs, Dumpsites, Chem/Glass/Equipment Calendar Year 2005………………………………………………..4Figure2. Meth Lab in a Suitcase……………………………………………………………..5Figure 3. “Mom and Pop” Meth Lab…………………………………………………………13Figure 4. Skin Lesions from Excessive Scratching of Imaginary Mites…………………19Figure 5. Meth Mouth……………………………………………………………………......19Figure 6. The Wasting Process of Meth Use………………………………………..........19Figure 7. Chemical Burns………………………………………………………………......20Figure 8. Meth Kitchen Fire………………………………………………………………....22Figure 9. Motel Lab………………………………………………………………..... . . . . . . . .34Figure 10. Neutralizing Soil………………………………………………………………....38Figure 11. HCL Generator……………………………………………………………….....39Figure 12. Iodine Stained Wall……………………………………………………………...42Figure 13. Open Dumping of Meth Wastes…………………………………………….....46

viii

ListofTables

Table1. Reported Meth Laboratory Seizures, 1997-2005…………………………….......3Table2. Selected Products Containing Pseudoephedrine…………………………........14Table3. Cleanup of Meth Labs………………………………………………………….......41

ix

AcronymsandAbbreviations

ACMD Advisory Council on the Misuse of Drugs AHRO Agency for Healthcare Research and QualityAPR Air purifying respiratorARAR Applicable or relevant and appropriate requirementBIA Bureau of Indian AffairsBLM Bureau of Land ManagementCDC Centers for Disease Control and PreventionCERCLA Comprehensive Environmental Response, Compensation, and Liability ActCESQG Conditionally exempt small quantity generatorCFR Code of Federal RegulationsCOPS Office of Community Oriented Policing ServicesDEA Drug Enforcement AdministrationDOJ Department of JusticeDTO Drug trafficking organizationDTSC Department of Toxic Substances Control (California)EPA U. S. Environmental Protection AgencyFS Forest ServiceFBI Federal Bureau of InvestigationFID Flame ionization detectorFS Forest ServiceHHS Department of Health and Human ServicesIDLH Immediately dangerous to life or healthIHS Indian Health Service Lab LaboratoryMCTFT Multi-Jurisdictional Counterdrug Task Force Training Program meth MethamphetamineNCP National Oil and Hazardous Substances Pollution Contingency PlanNCLSS National Clandestine Laboratory Seizure System NDIC National Drug Intelligence CenterNFS National Forest SystemNIDA National Institute on Drug AbuseONDCP Office of National Drug Control PolicyPID Photo ionization detectorPOTW Publicly owned treatment worksPPE Personal protective equipmentPSA Preliminary site assessmentRCRA Resource Conservation and Recovery ActSAMHSA Substance Abuse and Mental Health Services AdministrationSCBA Self contained breathing apparatusSQG Small quantity generatorTSD Treatment, storage, or disposal facility

xi

ExecutiveSummary

History and Occurrence

Amphetamines, including methamphetamine, were first synthesized in the early part of the 20th century. They were available as over-the-counter drugs during the 1950s and ‘60s to treat obesity and depression and to enhance endurance. The increasing abuse of amphetamines during these decades led to their classification under Schedule II of the U.S. Drug Abuse Regulation and Control Act of 1970, which means they are available only by prescription.

Until the late 1980s, the illegal manufacture of methamphetamine (or meth) in the United States was mostly confined to California and associated with outlaw biker gangs and Mexican criminal organizations. Meth production started to change significantly in the 1990s with the proliferation of small laboratories (meth labs) in which small amounts of the drug were made from legally purchased household goods. Clandestine meth labs are generally classified as either “mom and pop” shops capable of producing an ounce or two per run or as highly organized “super labs” that can produce 10 pounds or more product per day. The mom and pop labs can be likened to a cottage industry in which the “cook” or “cooker” produces enough of the drug for personal use, with a little left over to sell to buy new supplies. Super labs, which are found primarily in California and Mexico, are organized criminal enterprises with large distribution networks.

Since 1995, law enforcement has tracked the spread of mom and pop labs eastward. In recent years, the greatest number of lab seizures has occurred in states with large rural areas, such as Missouri, Iowa, Illinois, Indiana, and Tennessee. The number of labs seized peaked in 2003 and has since begun to decline. This trend is generally attributed to state laws that restrict access to the precursors pseudoephedrine and ephedrine, which are common ingredients in over-the-counter cold and allergy medicines used in many of the meth recipes. While lab seizures are decreasing, meth availability and abuse are increasing due to the amount of product smuggled into the United States and distributed by criminal organizations. This upward trend in use is very apparent in some vulnerable populations, such as Tribal Lands, where meth use was described in 2006 as reaching crisis proportions.

Roles and Responsibilities

Government response to meth labs and abuse of the drug can be divided into three major areas of activity: criminal prosecution, substance-abuse treatment, and cleanup of hazardous conditions created by lab operations. The unlicensed manufacture and use of meth is a criminal activity under federal and state laws. The lead agencies at the federal level are the Drug Enforcement Administration (DEA) and the Federal Bureau of Investigation (FBI). State and local law enforcement officials can act alone but are often involved with the federal agencies in arresting users and taking down labs. The FBI has the lead criminal investigation role for meth labs in Tribal Lands, and the Bureau of Land Management and Forest Service are responsible for drug activities on the government lands they manage.

xii

Substance abuse programs for the prevention and treatment of meth-related problems exist at all levels of government and in the private sector. The Department of Health and Human Services (HHS) is the lead federal agency involved in the prevention and treatment of meth abuse. Agencies involved with meth issues within HHS include the National Institutes of Health, Substance Abuse and Mental Health Services Administration, Agency for Healthcare Research and Quality, and the Indian Health Service. The Justice Department also sponsors public awareness efforts and funds state and local government projects. State and local departments of health are charged with overseeing the direct administration of programs, as well as private and public medical delivery organizations, such as hospitals and treatment clinics.

The cleanup of hazardous conditions created by meth labs is generally accomplished in two stages. The first is a removal stage. The removal stage is a law enforcement activity during which suspects, if present, are arrested, the lab activities are stopped, criminal evidence is gathered, and lab equipment and most, if not all, hazardous chemicals are removed. The removal is the responsibility of the lead (federal or state/local) law enforcement agency.

Once the evidence has been collected and the materials immediately hazardous to human health and the environment have been removed, the remediation or cleanup stage of the process can begin. Setting cleanup standards and procedures for meth-contaminated structures is generally the responsibility of the state or local department of health. In some states, it may be the responsibility of the state natural resources or environmental protection agency. In other states, the department of health has jurisdiction inside the structure, while outdoor contamination is the responsibility of the environmental agency. The responsibility of actually having the cleanup performed belongs in all cases to the property owner.

Methamphetamine Manufacturing Processes

The manufacture of meth is a relatively straight forward procedure that does not require any advanced skills in chemistry. The equipment and chemicals required are commonly available and very portable. Meth labs have been found in suitcases, car trunks, mobile homes, hotel rooms, home kitchens and bathrooms, and park camp sites.

There are four main techniques for producing meth. They are the Birch, red phosphorus/phosphorus, Emde, and phenyl-2-propanone methods. The first three require pseudoephedrine or ephedrine as precursors, the last does not. The Birch method is associated with anhydrous ammonia—a common farming chemical for which thefts associated with meth production have been reported. The red phosphorus/ phosphorus method is associated with match strikers or phosphorus flakes and hydriodic acid. Its production can produce poisonous phosphine gas. The Emde method uses thionyl chloride and highly flammable hydrogen gas as process chemicals. One of the phenyl-2-propanone methods uses formic acid and formamide as the basis chemicals. The Birch, red phosphorus, and Emde methods all make use of strong bases and acids as well as solvents (Coleman fuel, naphtha, ethanol, chloroform, mineral spirits) in meth production.

xiii

Meth is available on the street in basically three forms: tablet, powder, or crystal. Tablets are produced mainly in Southeast Asia and are typically green or red-orange in color. Powder, which is the most common form, is crystalline in texture, bitter tasting, and white, pink, red, tan, or brown, depending upon the production method employed. Crystal or ice meth resembles shards of ice, is highly addictive, and pure.

Health Effects

The chronic use of meth can result in violent behavior, anxiety, confusion, paranoia, insomnia, hallucinations, and delusions, such as the feeling that there are insects crawling on the skin, which results in incessant scratching and skin damage. The drug also causes wakefulness and depressed appetite. The user frequently remains awake for days on end and forgets to eat during this period, which results in physical deterioration. Homemade meth often contains corrosive impurities that cause the teeth to decay into black stubs—a condition now referred to as “meth mouth.”

Cooks who are also users generally do not take safety precautions when handling and heating the chemicals. Meth production can result in the inhalation of toxic fumes and burns from chemical explosions that are flammable or corrosive or both.

Mom and pop labs often are in homes occupied by family members. Children are especially susceptible to the chemical vapors, and these vapors, which include meth, will move throughout the structure and settle on furniture, floors, and rugs. Children’s hand-to-mouth behavior causes them to ingest these materials. The meth users also may become violent, forget to feed the children, or leave chemicals and byproducts in containers that are improperly labeled, such as acid labeled as fruit juice.

Meth labs that are in single family units or out in the country will seldom have an effect on the health of neighbors; however, vapors from production have been known to travel in common air ducts in apartment buildings, and there is danger of a fire or explosion.

Law enforcement officials are vulnerable to inhalation of toxic fumes, especially when taking down an active cook. Because they may face armed and violent individuals, the officers often do not wear respiratory equipment that could hamper their ability to defend themselves in an expedient fashion. Of individuals involved in lab raids, police officers are most likely to have complaints of respiratory problems and headaches following the raid. Taking down a lab after the arrest of the cooker requires special safety equipment and should not be attempted without it. Firefighter turn-out gear is not considered adequate. Healthcare workers, such as emergency services (ambulance personnel) and emergency room attendants, have reported health problems from treating cooks contaminated by a lab accident, and reports of violent behavior on the part of meth-affected patients are common.

xiv

Regulatory Setting

The primary, non-criminal, federal regulations that apply to meth lab cleanup are the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Resource Conservation and Recovery Act (RCRA), which are administered by the U.S. Environmental Protection Agency (EPA). CERCLA allows for government action to remove and/or remediate releases of hazardous substances to the environment. While CERCLA could be applied to meth labs, these labs generally are not big enough to warrant EPA involvement and are usually handled by state personnel. Under the brownfields section of CERCLA, the government is authorized to provide grants and loans to qualified government or non-profit organizations for assessing and cleaning up properties that have become contaminated by clandestine drug manufacturing activities. RCRA governs the storage, treatment, and disposal of hazardous wastes, among other things. These regulations and their state counterparts can have an impact on how meth lab-related wastes are handled and disposed of.

Cleanup standards for properties contaminated by meth lab operations are generally set by the state or local public health departments. There are no federal standards specifically for meth lab remediation. Cleanup in an outdoor environment is treated like any other chemical release, and state and/or federal guidance applies.

Removal Actions

Removal actions involve the collection and proper disposal of meth lab equipment, chemicals, and wastes that are deemed by the law enforcement agency or their contractor to be sufficiently hazardous to warrant removal from the property. The responsibility for disposal of these items is very action and state specific. For example, if DEA is the lead enforcement agency in the raid, their hazardous waste contractor will collect the hazardous materials for disposal at a hazardous waste facility. If the raid is a state or local action, those officials will be responsible for the lab equipment and chemicals’ proper disposal, which may or may not be in a hazardous waste facility. Because of federal funding grants, some state/local law enforcement agencies have access to DEA contractors, while others do not. In California, removal actions by state/local authorities are performed by the state’s Department of Toxic Substance Control’s contractors. Paying for the removals has been a problem for some state jurisdictions.

Very little of a meth lab’s chemicals or waste products require disposal in a commercial hazardous waste landfill. Most are household chemicals, and the waste products are combinations of these household chemicals that display corrosive or flammable characteristics. These wastes may be treatable at the site. The problem facing removal crews in evaluating treatment and disposal options is the uncertainty of what chemicals were actually used at the site and whether the container labels accurately reflect the contents. If these uncertainties can be resolved without having to test every waste and container, disposal at a municipal landfill (as a regular waste or household hazardous waste) or on-site treatment may be an option. On the other hand, DEA and EPA recommend treating these materials as hazardous wastes as a matter of expediency and any removal carried out by a DEA contractor will treat the materials as hazardous wastes (Joint Federal Task Force 1990 and DEA 2005).

xv

If there are a sufficient number of meth lab seizures, it may be more cost-effective to set up a system similar to the one in Missouri whereby chemicals and wastes seized in a meth lab raid are brought to centrally located, permitted storage areas for subsequent sorting and disposal. Consolidating the wastes and chemicals saves money on transporting hazardous wastes to a hazardous waste landfill, which must be done by a licensed transporter.

Cleanup

Cleanup occurs after law enforcement officials or their agents have removed most of the obvious bulk contaminants. This process involves making the structure fit for reoccupancy by actions for which the need will vary from site to site. These actions usually involve one or more of the following:

• Reduce all chemical residues on all surfaces (walls, appliances, furniture, sinks/tubs, textiles) to safe levels.

• Replace the walls, appliances, furniture, sinks/tubs, and textiles (carpets, drapes, clothing).

• Apply a paint or sealer that will prevent contact with the contaminants.

The acute health effects of most of the chemicals used in meth production are well characterized; however, the chronic health effects of exposure in a residential setting to low levels of these chemicals, their production byproducts, and meth residues are not well known. This lack of knowledge poses a problem for the health department that tries to set cleanup levels for reoccupancy. In addition to actual level determinations, the degree of contaminant diffusion into porous media, such as painted walls or wooden floors, and its back-diffusion potential has not been studied (especially for a long-term working lab), and the ability of an oil paint to seal it in or a detergent to remove it are also unknowns. This uncertainty with regard to risk has led to a range of assumptions and approaches by various state and local health departments, including the decision to do nothing.

The minimal active approach assumes the property owner is a responsible person and provides decontamination guidance for the owner to follow. One such guidance suggests the following actions:

• Air out the building while heating it to vent any remaining volatile organics.

• Dispose of all visibly stained items in a landfill.

• Dispose of carpeting, drapes, and clothing, especially if visibly stained.

• Clean walls and other surfaces using normal household cleaning methods.

• Clean ventilation system, if present.

• Paint cleaned surfaces to provide a contact barrier.

xvi

The guidance assumes the cleaning will be effective in removing all harmful chemicals as it does not require confirmation sampling or government inspection.

At the other end of the reoccupancy cleanup requirement scale, the government entity sets cleanup goals for several contaminants (including meth), requires the engagement of professional state-certified expertise, and assumes a need for close government oversight. This approach closely approximates a conventional environmental site investigation. The property owner's consultant prepares a contaminant history of the site and does a walkthrough to determine which surfaces need to be sampled and which do not. One option is to assume that everything needs cleaning to avoid sampling and analysis costs. A preliminary site assessment report is then submitted to the government for approval. The report will identify the surfaces to be sampled (analysis to be done and laboratory qualifications), material to be disposed of (rugs, drywall), and cleaning procedures proposed for items not disposed of. After approval, the consultant prepares a remediation plan that includes a timeline, a plan for post-remediation assessment, remediation procedures, and a waste disposal plan. The remediation plan should follow the government entity's written guidance on meth cleanup requirements. The work plan is submitted for approval, and following approval, the work begins. The consultant must submit a final remediation report that describes the results of the work and indicates through the chemical analysis results that the cleanup has met the cleanup goals. Also submitted with the final report is an inventory of the items identified for disposal in the work plan and a receipt from the facility that received them.

Meth labs also can cause environmental damage when the wastes are dumped onto the ground or flushed into a septic system. The property owner is responsible for checking for dumped or buried wastes. In some jurisdictions, if a septic system is involved, the owner must test the tank contents to determine if they contain hazardous levels of meth lab chemicals (primarily solvents or mercury).

While meth lab activities rarely reach a scale where they affect redevelopment activities of a neighborhood, their cleanup can be expensive and their presence may affect the resale value of the property. Cleanup costs for a 1,500 square foot rambler typically run between $5,000 to $15,000 but can be much higher. A simple way to envision what drives the cleanup costs is to think of washing down all of the house's inside surfaces, replacing all the rugs and furniture, and, depending upon the damage done, completely remodeling the bathrooms and kitchens.

Property Values and Resale

A potential buyer of a home or rental property with former meth lab operations may focus on whether the cleanup procedure truly cleaned the property, especially in a jurisdiction where confirmation sampling is not required. If the property is not clean, the owner may incur costs to remediate beyond work previously performed to achieve a sale. The concept of clean is also problematic because of the lack of health-based standards for chronic exposure to meth residues.

xvii

On a nationwide basis, this is a relatively complex issue because the impact on both the property containing the lab and its neighbors depends primarily on a given state’s laws and to some extent the socioeconomic class of the neighborhood. Where cleanups are voluntary, there may be no guarantee that anything was done. There is also the issue of listing and disclosure laws, which range from no listing or disclosure to a requirement that the owner must always disclose to potential buyers or renters that the property was formerly a meth lab. Buyer or renter views of the risks associated with meth production will also affect whether or not the former presence of a lab presents a stigma.

An issue may arise in areas where the authorities rule that a property is unfit for use until it is cleaned up, but cannot compel cleanup. This situation sometimes results in the property being abandoned by the owners. Abandoned properties will deter potential buyers and depress property values of surrounding buildings.

This Report

Because this report is intended for individuals that must deal with the universe of methamphetamine issues and not subject matter experts, it is necessarily broadly drawn. The Internet resources have been provided when available to allow the reader to easily find more in-depth material if needed. The Internet websites were live at the time of the review of the document (December 2006).

1

1.0Introduction

Methamphetamine (meth) is a synthetic drug and a powerful central nervous system stimulant. It has dozens of street names—e.g., speed, ice, chalk, crystal, crank, glass—with many regional and local variations. Meth is a controlled substance that is easily manufactured in clandestine laboratories (labs) throughout the United States; anyone who can read and measure can make it (Guevara 2003). The drug can be snorted, swallowed, injected, or smoked. Typically, meth is a powder that easily dissolves in water, but it is also manufactured in the form of small, brightly colored tablets or as clear chunky crystals. Though the initial side effects of meth use are pleasurable, it is highly addictive, and the drug itself can cause mental confusion, severe anxiety, paranoia, irritability, insomnia, nausea, depression, and brain damage. Meth users can be very aggressive and paranoid, which often results in violent behavior (NDIC 2002).

Amphetamines, including meth, were first synthesized in the early part of the 20th century, but were not administered for medical uses until the 1930s. During World War II, the drug was distributed to soldiers to keep them on the move. In the years after the war, both Dexedrine® (dextroamphetamine) and Methedrine® (methamphetamine) became available as over-the-counter products. In the 1950s and ‘60s, amphetamines were routinely prescribed as a medication for obesity and depression (Anglin et al. 2000). As usage expanded, long-haul truckers took them to stay awake, dieters consumed them to lose weight, and athletes used them to extend their abilities (NACo 2005). The increasing abuse of amphetamines/methamphetamine due to legal availability and easy access in these decades led to the classification of the drugs as Schedule II substances under the U.S. Drug Abuse Regulation and Control Act of 1970. Amphetamine products are now legally available only by prescription.

1.1 Methamphetamine Production

Manufacture of amphetamines/methamphetamine in illegal laboratories increased as a result of continuing black market demand. Large amounts of meth have been illicitly smuggled into the United States from Mexico (DEA 2005) for many years, and more recently from Canada, China, and Southeast Asia. Until the late 1980s, the illegal manufacture of meth in the United States was limited mostly to California, and its manufacture was associated primarily with outlaw biker gangs and Mexican criminal organizations. Meth production started to change significantly about 10 years ago when local law enforcement officials began seeing a proliferation of small labs in which small amounts of meth were produced from legally purchased household goods using one of more than 150 recipes. Since 1995, the illegal use and manufacture of meth has mushroomed (Hargreaves 2000). There are generally two types of clandestine drug labs: “superlabs” and “mom-and-pop” labs. According to the U.S. Drug Enforcement Administration (DEA), superlabs are highly organized shops that are capable of producing 10 pounds or more product in a 24-hour period; they account for approximately 80 percent of all meth produced. Mom-and-pop labs are much more common and typically manufacture a much smaller amount of meth, often producing

2

only enough for the cooks and their close associates. Though these labs account for only a small portion of all meth produced, they account for most of the explosions, fires, and hazardous waste dumping (Hunt et al. 2006). In addition to causing serious short- and long-term health effects in users, the nature of the illicit manufacturing process poses inherent dangers for the cook, other inhabitants of the premises (especially children), the first responders, and the environment.

For approximately $100 worth of common products purchased in a hardware or grocery store, a cook can manufacture $1,000 worth of meth (Fleming 2005). The precursor ingredients used by mom-and-pop labs to make illegal meth have been obtained in large part from over-the-counter cough/cold and allergy products containing pseudoephedrine. These products are purchased or stolen from stores with retail pharmacies or from convenience stores, supermarkets, or discount outlets, or ordered over the Internet. Superlabs, however, obtain supplies of precursor chemicals mainly from other sources, including large-lot quantities of pseudoephedrine and ephedrine illegally diverted from legitimate distributors (GMDC 2005).

Meth labs are, by far, the most frequently encountered clandestine laboratories in the United States (DEA 2005). At the local level, meth abuse causes legal, medical, environmental, and social problems. Local governments and their citizens must often pay for investigating and closing meth labs, making arrests, holding lawbreakers in detention centers and trying them, providing treatment for those addicted to the drug, and cleaning up lab sites. According to the National Association of Counties (NACo), 58 percent of counties report that meth has become their top anti-drug priority for law enforcement. In many areas, meth cases are swamping hospital emergency rooms. In one NACo survey, 47 percent of hospitals said meth is the top illicit drug involved in patient presentation. The great majority of these patients are uninsured, placing a tremendous added burden on already strained emergency rooms (NACo 2005).

According to the 2005 National Survey on Drug Use and Health, meth use among the civilian non-institutional population aged 12 or older remained stable between 2002 and 2004 with a slight downward trend in 2005. In 2005, an estimated 10.4 million persons (4.3 percent of persons aged 12 or older) had used meth at least once in their lifetime, 1.3 million (0.5 percent) had used it in the past year, and 512,000 (0.2 percent) had used it in the past month (SAMHSA 2006).

In previous decades, meth was viewed as a “poor man’s cocaine” abused predominantly by Caucasian individuals of low socioeconomic status in rural areas. While Caucasian males (78 percent of users are white and 78 percent are male) are still the predominant group (Doyle 2006), meth abusers are found in all ethnic groups, levels of socioeconomic status, and regions of the country.

1.2 Trends in Occurrence

On the retail level, meth represents a new market in some areas and an established market in others. Although about 80 percent of the meth used in the United States is

3

the product of “superlabs” established in Mexico and California (DEA [undated]), an analysis of meth retail data suggests that the meth retail market is different from other drug markets in many respects. The small mom-and-pop labs that produce about 20 percent of the illicit meth might be said to reflect a “cottage industry” model of drug distribution. Cottage industry drug distribution is characterized by a large number of small groups, weak or little organizational structure, and fluid group membership. In contrast to the larger, more organized market, the cottage industry drug market handles relatively small amounts of the drug at a time and does not use sophisticated technology or distribution routes. This model for meth production appears in rural locales and in areas where demand is still low, where meth is generally produced by local cooks and distributed “hand to hand” by people who know one another. In well-established markets with high demand, more organized networks of producers and distributors appear to operate (Hunt et al. 2006). While organized, large-scale criminal activity and superlabs contribute more significantly to the problem of illegal meth supply and abuse, each of the much greater number of small labs poses its own threat to human health and the environment.

According to the National Drug Intelligence Center’s 2006 National Drug Threat Assessment report, domestic meth production appears to be decreasing; however, increased production by Mexican drug trafficking organizations (DTOs) and criminal groups in Mexico—the principal foreign source of meth—is sustaining or slightly increasing domestic wholesale supplies. Data from the National Clandestine Laboratory Seizure System (NCLSS), a voluntary reporting system for most state and local agencies, show that the number of reported meth laboratory seizures decreased slightly from 2003 (10,199) to 2004 (9,895). Preliminary NCLSS data indicate a decrease in meth lab seizures in 2005, with a sharp decrease in seizures of meth superlabs since 2001 (Table 1).

Table1.Reported Methamphetamine Laboratory Seizures, 1997-2005

TotalLaboratories Superlabs1997 2,806 *1998 3,802 *1999 6,750 *2000 7,021 *2001 8,542 2452002 9,282 1422003 10,199 1302004 9,895 55

2005** 5,249 37Source: El Paso Intelligence Center National Clandestine Laboratory Seizure System

* Laboratory capacity data were not collected prior to 2001** 2005 data are preliminary.

4

Meth availability will most likely increase in the near term, particularly in eastern states. Significant decreases in wholesale production in domestic laboratories have not reduced domestic availability of the drug because the reductions have been offset by meth produced in Mexico and smuggled to domestic markets. Intelligence reports indicate that Mexican DTOs will likely offset any further declines in domestic meth production by increasing production levels at laboratories in Mexico, which have not yet reached full capacity (NDIC 2006b).

The National Drug Intelligence Center (NDIC) divides the country into seven regions: Pacific, Southwest, West Central, Southeast, Florida/Caribbean, Great Lakes, and Northeast. Most meth lab seizures occur in the West Central Region, followed by the Pacific Region. Caucasian independent dealers are the main producers in the West Central Region; Mexican criminal groups dominate production in the Pacific Region. Criminal groups and Mexican DTOs are primary smugglers from Mexico in the Southwest Region.

Meth trafficking and abuse—a major drug threat in western states since the early 1990s—have gradually expanded eastward, reaching the point where the drug now affects every region of the country, though to a much lesser extent in the Northeast Region (Figure 1). The eastward expansion of the drug has been most notable in the central states, such as Illinois, Indiana, Iowa, Missouri, Kentucky, and Tennessee. Nationally, Missouri has reported the highest number of clandestine laboratory seizures of all the states since 2001.

Figure1.Total of All Clandestine Laboratory Incidents including Labs, Dumpsites, Chem/Glass/Equipment Calendar Year 2005 (National Clandestine Laboratory Database Total: 12,226, States Reporting Dates: 01/01/05 to 12/31/05)

5

The eastward expansion of meth trafficking and abuse has slowed recently. This decrease is attributed to increasing state regulation of the sale and use of chemicals used in meth production, particularly ephedrine and pseudoephedrine. Well over half the states have passed legislation that restricts sales of products containing ephedrine or pseudoephedrine, either by requiring the products to be placed out of sight so that customers must ask for them, requiring the products to be placed a certain distance from the register, limiting the amounts that can be purchased, and/or requiring customers to sign a registry. These measures seem to have affected domestic production substantially; however, Mexican DTOs and criminal groups are expected to make up the decreases in domestic production with meth produced in Mexico.

Meth labs are a problem in Tribal Lands; however, the abuse of the drug is a far more serious issue. In testimony before Congress, Gregory Pyle (2006), Chief of the Choctaw Nation of Oklahoma, stated that meth use, abuse, and dependency have soared since 2002 and tribes are reporting staggering cases of crime, domestic violence, and drug and alcohol abuse that are attributable to meth in their communities. Testifying at a different hearing, Gary Edwards (2006), Chief Executive Officer, National Native American Law Enforcement Association, reported that research suggests that the majority of meth distributed in tribal communities is smuggled through the U.S. borders with Mexico and Canada and that Indian tribes are prime targets for the Mexican drug cartels.

1.3 Methamphetamine Lab Settings

A typical meth lab is a collection of chemical bottles, hoses, and pressurized cylinders. Small meth labs can be set up nearly anywhere—in fields, campgrounds, rest areas, vehicles, and buildings of all types—but roughly two-thirds are found in homes in rural and residential areas, making these labs difficult for police to detect. As shown in Figure 2, a makeshift lab can even fit into a suitcase. Because the labs use equipment that is easily obtained and transported, they are also easily dismantled, stored, moved, abandoned.

Aside from the dangers to human health presented by meth abuse, the manufacturing process presents its own hazards. Of approximately 32 chemicals that can be used in different combinations to produce meth, one-third are extremely toxic and many are reactive, flammable, and corrosive. Vapors that result from chemical reaction during manufacture attack mucous membranes, skin, eyes, and the respiratory tract. Some chemicals react dangerously with water, and some can cause fire or explosion. In fact, nearly one in five of the 1,654 labs seized nationwide in 1998 (mostly in the western states) was found because of fire or explosion

Figure2.Meth Lab in a Suitcase (Source City of Houston)Figure2.Meth Lab in a Suitcase (Source City of Houston)

6

(Snell 2001). These accidents have the potential to injure or kill not only those involved in the manufacture of the drug, but the law enforcement officers and the fire fighters who respond as well.

During use and production, meth and other harmful chemicals are released into the air and distributed throughout the surrounding area. In residential settings, these chemicals collect on countertops and floors, and they are absorbed into furnishings, carpets, and walls (Committee on Science 20051 and Martyny 2004a-c, 2005 a&b)). Meth manufacturing also creates hazardous waste. According to the Department of Justice, the clandestine manufacture of one pound of finished product results in five or more pounds of waste comprising corrosive liquids, acid vapors, heavy metals, solvents, and other harmful materials. Some of these materials can be fatal when they contact the skin or are breathed into the lungs. Lab operators routinely dump this waste illegally in ways that damage the environment (U.S. DOJ 1993).

Law enforcement reporting shows that meth labs have been discovered on federal lands throughout the United States. Meth labs often are discovered in or near caves, cabins, recreational areas, abandoned mines, and private vehicles located on or adjacent to federal lands. These labs vary in size from small, mobile, low-capacity units operated by independent producers to high-capacity superlabs capable of producing 10 or more pounds of meth in a single production cycle. Hazardous chemical waste from the labs usually is dumped near production sites, along remote roads, and in abandoned mine shafts, polluting waterways, killing vegetation and wildlife, and rendering areas unsafe for visitors and employees. Moreover, since meth labs are prone to fires and explosions, they pose a significant forest fire risk. In addition to posing a threat to the environment, these labs contribute to the threat of violence against law enforcement and private individuals. Meth producers on federal lands often are armed, and meth labs frequently are booby-trapped. Law enforcement officers have seized shotguns, handguns, automatic weapons, pipe bombs, grenades, and night vision equipment from drug producers and smugglers on federal lands (NDIC 2005).

States and localities have different statutes and regulations relating to the removal and cleanup of meth labs, but generally removal and cleanup occur in distinct phases. The first phase is the initial removal of gross contamination, which includes the removal of illicit laboratory equipment and chemicals. Because meth labs are crime scenes, law enforcement is typically first to respond, securing evidence and overseeing phase one cleanup activities. The cost of these cleanup activities is borne by the government. After a site has been secured and is no longer part of a criminal investigation, the second phase of the remediation begins—the cleanup of residual contamination to prepare the property for reoccupancy or reuse. In this phase, property owners are notified and

1 Testimony of Sherry L. Green, Executive Director, National Alliance for Model State Drug Laws; John W. Martyny, Senior Industrial Hygienist, Division of Environmental and Occupational Health Sciences, National Jewish Medical and Research Center; Henry L. Hamilton, Assistant Commissioner, Public Protection, NYS Department of Environmental Conservation Center; and Robert R. Bell, President, Tennessee Technological University before the Committee on Science, House of Representatives.

7

responsibility and expense passes to them, often with a recommendation to contact a contractor. There are no national guidelines or regulations on how to clean up a residential meth lab for reoccupation. States strive both to protect the public and to find an answer that is practical for property owners; their responses range from doing very little to complete demolition.

Some states have established by statute, regulation, or guideline a decontamination standard specific to meth (Committee on Science 2005). State-specified remediation levels for meth range from 0.1 µg/100cm2 to 10 µg/ft2. These differences in cleanup levels reflect the absence of any scientifically valid health-based standard, which forces states to use either detection levels or levels that appear to be practical (ASTHO 2005).

There is considerable debate over what constitutes an appropriate standard. Should the standard be based on risk to human health (what level of risk is appropriate?), or be based on the feasibility of cleaning up a site, or some combination of the two? These questions are further complicated by the lack of research on the long-term health effects of chronic exposure to low levels of meth. Little is also known about the consequences of long-term exposure to the trace concentrations of chemicals that individuals, including children, may receive from living in a former meth lab, though cases of lingering health effects from such exposures have been reported (Committee on Science 2005).

Even where state and local regulations or ordinances exist, states and localities may do little to enforce remediation rules. Some public health officials try to force reluctant owners to clean up by threatening condemnation of the property. Cleanup is expensive; the cost to remediate a 1,500 square foot rambler can range from $5,000 to $15,000 or more depending upon the extent of the contamination and what is required to be disposed of and replaced (e.g., rugs, furniture, dry wall, appliances). Most insurance companies will not cover “contamination” and “felony activities” for private homes and some commercial properties. Individuals buying or moving into a property that was previously a meth lab may have no way of knowing its history (Committee on Science 2005). Though some state and local governments maintain a list of former meth lab properties, not all of them do so.

To address the problem of clandestine meth manufacture at the federal level, the Combat Methamphetamine Epidemic Act of 2005, Title VII of the USA Patriot Act, was signed by President Bush on March 9, 2006. The Act provides minimum standards for retailers across the country that sell products containing the meth precursor chemicals ephedrine, pseudoephedrine, or phenyl-2-propanolamine, collectively referred to as PSE products. The law limits retail sales to 3.6 grams of the PSE products per day and consumer purchases to 9 grams per 30 days, and requires that purchasers provide identification and sign a sales log. Also, sellers must now keep these products behind the counter or in a locked case and register on line with the U.S. Attorney General (DEA 2006).

8

2.0RolesandResponsibilitiesControlling the production and use of meth directly involves a large number of public and private entities. Meth production is an illegal activity at both the federal and state level. This section briefly explores their roles and responsibilities.

2.1 Federal Level AgenciesAt the federal level, the Federal Bureau of Investigation (FBI) and the DEA have responsibility for investigating the criminal aspects of meth production and use. The FBI is the lead federal agency for conducting investigations of organized crime, including drug gangs, and its jurisdiction extends over Tribal Lands. Drug use and prevention are part of the FBI’s community outreach program. DEA is charged with enforcing the federal controlled substances laws and regulations and often investigates or teams with the FBI to investigate drug-related organized crime. The Hazardous Waste Disposal Unit of the DEA Office of Forensic Sciences is responsible for administration and oversight of contractors that clean up meth labs shut down by the DEA.

The Office of Community Oriented Policing Services (COPS) within the Department of Justice administers the Congressionally mandated Methamphetamine Initiative. The primary purpose of the Methamphetamine Initiative is to combat the production, distribution, and use of meth through grants issued to state and local law enforcement agencies for such uses as training and equipment, and to reimburse the DEA for the proper removal and disposal of hazardous substances from clandestine meth laboratories (U.S. DOJ 2006). The grants support a variety of activities, including laboratory/environmental cleanups by state and local law enforcement agencies. Between 1998 and 2005, about $214 million has been made available for grant funds. Approximately 84 percent of the appropriated funds for the Methamphetamine Initiative was congressionally earmarked for specific entities and locales (U.S. DOJ 2006).

Established in 1993 within DOJ, the National Drug Intelligence Center (NDIC) collects strategic domestic drug intelligence and supports Intelligence Community counterdrug efforts. It also produces national, regional, and state drug threat assessments (NDIC 2006).

The mission of the Bureau of Indian Affairs (BIA) is to enhance the quality of life and promote economic opportunity while protecting and improving the trust resources of American Indians, Indian tribes, and Alaska Natives (BIA 2005). The BIA administers or funds programs related to the management of resources, education, law enforcement, and social services on Tribal Lands. Managing drug-related issues is a part of these programs. In testimony before the Senate Indian Affairs Committee, William Ragsdale, the Director of the Bureau of Indian Affairs, describes the increasing problem of meth abuse in Tribal Lands Country and actions the Bureau is taking to help tribes combat it (Ragsdale 2006).

9

The Department of Health and Human Services (HHS) supports programs to prevent and mitigate the effects of meth on users and their community. The descriptions below are taken from the mission statements on the agencies’ Web pages.

The Center for Substance Abuse Treatment of the Substance Abuse and Mental Health Services Administration (SAMHSA) promotes the quality and availability of community-based substance abuse treatment services for individuals and families who need them. The Center works with states and community-based groups to improve and expand existing substance abuse treatment services under the Substance Abuse Prevention and Treatment Block Grant Program.

The Center for Substance Abuse Prevention of SAMHSA works with states and communities to develop comprehensive prevention systems that create healthy communities with a good quality of life. This program includes supportive work to school environments, neighborhoods, and families.

The Center for Mental Health Services of SAMHSA helps states improve and increase the quality and range of their treatment, rehabilitation, and support services for people with mental illness, their families, and communities (meth abuse is considered a mental illness).

The Indian Health Service (IHS) is responsible for providing federal health services to American Indians and Alaska Natives. The provision of health services to members of federally-recognized tribes grew out of the special government-to-government relationship between the federal government and Indian tribes. The IHS is the principal federal health care provider and health advocate for Indian people, and its goal is to raise their health status to the highest possible level. Treatment for drug abuse is part of its mission. In testimony before the Senate Indian Affairs Committee, Robert McSwain, the Deputy Director of Indian Health Service, described meth abuse in Tribal Lands as reaching crisis levels, with patient contacts increasing 2.5-fold between 2002 and 2005 (McSwain 2006).

The Agency for Healthcare Research and Quality (AHRQ) is the lead federal agency charged with improving the quality, safety, efficiency, and effectiveness of health care for all Americans. AHRQ supports health services research that improves the quality of health care and promotes evidence-based decisionmaking through grants and contracts. The agency has supported some projects related to health care for meth affected people.

The National Institute on Drug Abuse (NIDA) supports over 85 percent of the world’s research on the health aspects of drug abuse and addiction. NIDA-supported science addresses the most fundamental and essential questions about drug abuse, ranging from molecular level to managed care, and from DNA to community outreach. Besides research, NIDA provides educational pamphlets and outreach materials on meth-related problems and symptoms.

10

The Administration for Native Americans, a part of the Administration for Children and Families, provides grant funding that can include meth substance abuse assistance.

The Office of National Drug Control Policy (ONDCP), which was established in 1988 in the Executive Office of the President, establishes policies, priorities, and objectives for the nation’s drug control program. The goals of the program are to reduce illicit drug use, manufacturing, and trafficking, drug-related crime and violence, and drug-related health consequences. To achieve these goals, the Director of ONDCP is charged with producing a National Drug Control Strategy that directs the Nation’s anti-drug efforts and establishes a program, budget, and guidelines for cooperation among federal, state, and local entities (ONDCP 2006a). In June 2006, the Office released a document entitled Synthetic Drug Control Strategy: A Focus on Methamphetamine and Prescription Drug Abuse. This document lays out a strategy for reducing methamphetamine use and reducing the number of operating labs by 25 percent over a three year period. It also asks the EPA to develop a “Laboratory Aftermeth” research strategy that will identify the types of research needed to support Federal health based guidelines for remediating meth labs among other remediation and cleanup issues (ONDCP 2006b). The ONDCP website contains Internet hyperlinks to a variety of drug related programs, including those associated with the states.

While the U.S. EPA has the authority under CERCLA (see below) to clean up hazardous substances releases at meth laboratories and to regulate the disposal of those substances under RCRA, it generally defers the actual response action to state and local officials. EPA has an Environmental Response Team made up of experts in response actions available for actual response work, assistance, or consultation with EPA regional, state, or local response officials needing advice (U.S. EPA 2006). With the 2002 signing of the Brownfields law (Small Business Liability Relief and Brownfields Revitalization Act), sites contaminated with controlled substances, such as meth labs, were added to the list of brownfields eligible for grant funding to assess or clean properties. Also provided was some liability relief to property owners and potential buyers of property where meth labs are located.

The Occupational Safety and Health Administration (OSHA) has set safety and health requirements for hazardous substances response actions (OSHA 2006). These can be found in 29 CFR1910.120. Any personnel responding to a hazardous substance release must have at a minimum 40 hours of training on procedures and equipment used in these response actions.

The Bureau of Land Management’s (BLM) law enforcement program is responsible for protecting public safety and resources across the nation’s 264 million acres of BLM-managed public land, which it does in partnership with state and local law enforcement agencies. BLM law enforcement personnel perform a wide variety of tasks that include locating and eradicating drug-manufacturing laboratories on BLM land.

The Forest Service’s (FS) Law Enforcement and Investigations Office is charged with performing drug enforcement duties on National Forest System (NFS) lands or in areas with a nexus to NFS lands. These duties include removal and cleanup of meth labs (FS undated).

11

The Department of Defense (DoD) sponsors the Multijurisdictional Counterdrug Task Force Training Program (MCTFT) in a partnership with the Florida National Guard and St. Petersburg College. MCTFT provides courses aimed primarily at training law enforcement personnel, especially those assigned to a drug task force or narcotics investigations. Some courses are designed for an expanded audience, including elected and appointed officials, business and banking personnel, and school and community representatives. The combined effort of many law enforcement agencies toward the development of the MCTFT program has resulted in the most comprehensive counterdrug program available, encompassing the latest techniques and technologies (MCTFT 2006).

The Department of Homeland Security has several programs that train emergency response personnel. The Office of State and Local Training within the Federal Law Enforcement Training Center offers drug enforcement and first responder training programs for law enforcement and emergency response personnel. The Federal Emergency Management Agency’s Emergency Management Institute offers emergency response personnel training programs in hazardous materials response. The National Fire Academy, a part of the Federal Emergency Management Agency’s U.S. Fire Administration, offers courses in hazardous materials response and mitigation for first responders. The Fire Administration also has a grant program in which state and local departments can apply for aid in purchasing equipment, including safety equipment needed to respond to a clandestine drug laboratory.

2.2 TribalIndian tribes have primary responsibility for law enforcement, emergency response, and medical care/drug abuse issues. While a tribe can assume direct financial responsibility for medical care/drug abuse issues, they usually choose either to assume direct administration and operation of health services provided by the federal Department of Health and Human Services’ IHS or to remain within the IHS-administered direct health program. The IHS role in Tribal Lands is to:

• Assist tribes in developing their health programs through activities, such as health management training, technical assistance, and human resource development.

• Assist tribes in coordinating health planning; obtaining and using health resources available through federal, state, and local programs; and operating comprehensive health care services and health programs.

• Provide comprehensive health care services, including hospital and ambulatory medical care, preventive and rehabilitative services, and development of community sanitation facilities.

• Serve as the principal federal advocate in the health field for Indians to ensure comprehensive health services for Indian people (IHS 2006).

12

In 2000, American Indian tribes operated 171 law enforcement agencies and the U.S. Bureau of Indian Affairs operated 37 agencies. Criminal jurisdiction in Tribal Lands is divided among federal, state, and tribal authorities. Jurisdiction depends upon the particular offense, the offender, the victim, and the offense location (Bureau of Justice Statistics 2003). Because the manufacture and distribution of controlled substances falls within the jurisdiction of the FBI, an emergency response cleanup of a meth lab likely will be handled by the FBI using a DEA contractor. The National Tribal Justice Resource Center (undated) provides information on meth abuse in Tribal Lands and actions to prevent it.

2.3 State

The state police may share responsibility for drug criminal enforcement with local authorities and often take part in federal actions. When the state police raid a meth lab, they generally ensure that any materials on site that are immediately hazardous to human health and the environment are collected and disposed of properly. State health departments are usually responsible for setting cleanup values and regulations, though it varies by state, and local health departments generally have direct oversight. Some of the states, such as Montana, Washington, and Oregon, require certification of contractors cleaning up meth labs.

2.4 Local

Local and state law enforcement officers are usually responsible for seizing and restricting access to a property and conducting initial removal activities. In many instances, they are joined by other emergency and health personnel for removal actions. The health departments generally regulate and oversee the process of cleaning up buildings, may determine reoccupancy standards, and sometimes, in conjunction with environmental protection or natural resources departments, participate in outside cleanups.

2.5 Private

The private sector includes property owners, cleanup contractors, private health care facilities, and testing laboratories. Property owners are usually held responsible for funding the cleanup of a meth site. Although many states allow owners to conduct cleanup, private hazardous materials contractors are traditionally responsible for preparing cleanup work plans and performing cleanup in accordance with approved plans. Private health and laboratory facilities are generally employed in cases where sampling and testing are required. Hospital personnel who treat meth-related complaints due to, for example, a fire or explosion at a meth lab, are often exposed to the chemicals on the patients, and many hospitals are developing special procedures for handling meth-exposed patients.

13

3.0MethamphetamineManufacturingProcessesOver 150 methods are available to manufacture meth, and recipes are commonly available on the Internet and in books (Committee on Science 2005). Unlike some other clandestine drugs, making meth is fairly simple and requires no special knowledge or skill in chemistry (Figure 3). Many of the chemicals required for the manufacture of meth can be purchased at a local grocery or hardware store, and they fall into three general categories: precursors or ingredients to make them, chemicals to modify the precursors, and chemicals to extract and purify the final product.

Currently, the Birch or Nazi method is very popular for small labs, but other processes such as red phosphorus/phosphorus, Emde, and phenyl-2-propanone are also encountered. The Birch, red phosphorus/phosphorus, and Emde methods start with ephedrine or pseudoephedrine as precursors. These two chemicals are the active ingredients in a number of over-the-counter cold medicines (Table 2).

As of September 30, 2006, stores are required to keep all non-prescription products containing pseudoephedrine, ephedrine, and phenylpropanolamine behind the counter or in a locked cabinet, and consumers are required to show proper identification and sign a logbook for each purchase. The logbook will contain the name, address, date and time of sale, name and quantity of the product sold, and the signature of the customer. The Combat Methamphetamine Epidemic Act of 2005 also limits daily sales and monthly purchases of these products (DEA 2006c).

The products found in Table 2 do not constitute a census of all the products available that contain ephedrine or pseudoephedrine, but rather are those that could be verified on manufacturer’s websites or on the websites of companies selling the products on line as of December 21, 2006. Many manufacturers are reformulating their products and substituting phenylephrine HCl for pseudoephedrine to allow the product to continue to be displayed on open counters. A lengthy list of products that contained ephedrine and pseudoephedrine before the law took effect can be found in the Methodology Used in Developing Preliminary Estimates of Ephedrine and Pseudoephedrine 2005 Legitimate Use (DEA 2006b).

Figure3.Mom-and-Pop Meth Lab (Source: Jerrod Wright/Putham and White Countries (TN) Department of Health)

Figure3.Mom-and-Pop Meth Lab (Source: Jerrod Wright/Putham and White Countries (TN) Department of Health)

14

Table2. Selected Products Containing Ephedrine or Pseudoephedrine1

666 Maximum Strength Cold Preparation

Bronkaid Drixoral Cold & Allergy, Sustained-Action Tablets

Actagen Bromfed Syrup Motrin Cold and SinusActifed Cold & Sinus Caplet 666 Caplets, Maximum Strength

Allergy & Cold ReliefMucinex D Expectorant, Nasal Decongestant Extended Release

Advil Allergy Sinus *Claritin-D 12 hour Nurofen Cold & FluAdvil Cold and Sinus Claritin-D 24 Hour Ornex Maximum Strength Nasal

Decongestant and Analgesic, Caplets

Advil Flu and Body Ache Children’s Motrin Cold Primatene Bronchial Asthma Relief, Tablets

Alavert Allergy & Sinus, D-12 Hour Extended Release Tablets

Comtrex Deep Chest Cold Sinutab® Sinus Allergy Maximum Strength Caplet

Aleve Cold and Sinus Aleve Sinus and Headache

Comtrex® Cold & Cough Day/Night

Sinutab® Non-Drying Liquid Caps

Aleve Sinus and Headache Comtrex® Acute Head Cold *Sudafed 12 Hr Relief*Allerest Allergy & Sinus Relief Comtrex® Flu Therapy Sudafed Congestion & Sinus

Pain ReliefAllerest Maximum Strengh Congestac Nasal Decongestant-

Expectorant, Caplets Sudafed Daytime Nightime

Allerfed Contac Cold, Non-Drowsy 12 Hour, Caplets

Sudafed Pain & Allergy

All-Night Cold Formula Dimetapp Cold Cough & Flu Sudafed Sinus PainBenadryl-D Allergy & Sinus Tablet

Dimetapp Cold Cough & Sinus *Tylenol Cold Severe Congestion Daytime

Benadryl Allergy and Sinus Headache

Dristan Sinus Pain formula with Ibuprofen, Coated Caplets

Tylenol Sinus Severe Congestion Daytime CoolBurst Caplets

1 Products on this list were selected because as of December 21, 2006, their ephedrine or pseudoephedrine content could be verified either by manufacturer’s website or by an online company selling the product.

* Similarly named products containing phenylephrine HCl are available.

3.1 Birch Method

The Birch method uses sodium or lithium metal in anhydrous ammonia to reduce ephedrine or pseudoephedrine to meth. This method is useful for producing gram quantities of meth per run. One recipe (White 2004) contains the following ingredients:

• Lithium obtained from AA lithium-based batteries

• Ammonia gas synthesized from ammonium salt fertilizer and sodium hydroxide (drain cleaner) or, alternatively, anhydrous ammonia from an agricultural supply house (more commonly stolen from an active farm)

15

• Diethyl ether (car-starting fluid)

• Sodium chloride (salt)

• Sulfuric acid (Liquid Fire Drain Cleaner)

The above materials are the basic ingredients for making meth by the Birch method; however, a Birch method lab can use substitutes (except for the precursors and sodium or lithium), such as the following materials (UDEQ 2005):

isopropyl alcohol naphtha hydrochloric acidethanol Freon muriatic acidmethanol chloroform methyl ethyl ketonetoluene hydrogen chloride gas

Crushed tablets containing pseudoephedrine are combined in a bottle with ammonium nitrate fertilizer, a small amount of water, Red Devil drain cleaner, car-starter fluid (diethyl ether), and lithium from batteries. After several hours, the pseudoephedrine is converted to meth base, an oily liquid dissolved in the ether. The liquid is filtered and hydrogen chloride gas is bubbled through it, causing white crystals of meth hydrochloride to form. The ethyl ether is decanted and the crystals are allowed to dry.

3.2 Red Phosphorus/Phosphorus Method

Vona (2003) describes the basic red phosphorus method as follows:

In the Ephedrine/Red P/HI method of manufacture there are three major phases or reaction “stages.” The first is the synthetic stage in which the pre-cursor (ephedrine) is combined with iodine, red phosphorus, and water. These precursor chemicals will form hydriodic acid when combined, although, it is not uncommon for hydriodic acid to be added as a precursor chemical. This initial stage will be referred to as the “cook” stage. The heating and agitation which results from boiling the reaction mixture causes significant emissions to occur during the cook stage. It is this stage where phosphine gas, phenyl-2-propanone, iodine, di-methyl aziridine, and naphthalene by-products are emitted. Interestingly, meth was the only non-detected compound during the cook stage.

The second stage involves meth extraction from the reaction mixture into a non-polar solvent. This is commonly referred to as the “base-out” stage, because a strong base (e.g., Red Devil Lye) is added to the acidic reaction mixture produced in the first stage to convert meth into its base form. The strong base thereby drives the meth out of the aqueous solution and into a non-polar solvent (e.g., Coleman Fuel© or toluene). The second stage is highly exothermic because it involves adding a strong base (e.g., sodium hydroxide) to the highly acidic first stage. Therefore, significant heat and vapors are generated during this stage.

16

The third and final stage is typically referred to as the “salt-out” stage, which involves bubbling hydrogen chloride gas through the non-polar solvent from the “base-out” stage. It is during the third stage that the base form of meth is converted into its water soluble ‘salt’ form as meth hydrochloride (meth HCl). Meth HCl is precipitated out as whitish-tan crystals in final product form.

As with the Birch method, other chemicals can be substituted for the given extraction and purifying ingredients. UDEQ (2005) lists the following materials:

benzene isopropanol mineral spiritsmuriatic acid acetic acid methyl ethyl ketonemethanol naphtha chloroformhydrogen peroxide charcoal lighter fluid

Note that during this process, phosphine gas can evolve at dangerous concentrations when the mixture is overheated. Phosphine gas is both flammable and poisonous.

Red phosphorus is a stable form of phosphorus and can be obtained from matchbox strikers and various incendiary devices, such as road flares. White phosphorus can also be used, but it is highly reactive and spontaneously ignites when exposed to air.

An alternative method for obtaining hydriodic acid is to combine iron sulfide and hydrochloric acid to obtain hydrogen sulfide gas, which is poisonous. The hydrogen sulfide gas is bubbled through a suspension of iodine to produce hydriodic acid.

A variation of this method involves substituting hypophosphorous acid for red phosphorus (phosphorous acid can also be used). Iodine is reacted with the hypophosphorus acid to provide hydriodoic acid, phosphorous acid, and phosphine gas. The temperature at which the phosphine gas is formed is much lower than that required for red phosphorus.

A second, and more recent variation, is the use of phosphorus flakes. As an initial step, water is added to the flakes to obtain hypophosphorous acid and the above method is then followed. This variation is of particular concern because of the accessibility of phosphorous flakes from fertilizers (Martyny et al. 2005b).

3.3 Emde MethodIn the Emde process, ephredrine is converted to chloroephedrine using thionyl chloride or phosphorous pentachloride in chloroform. The chloroephedrine is then converted to meth using hydrogen gas with a palladium catalyst in a sodium acetate buffer solution (White 2004). The Salt Lake Valley Health Department (2001) refers to this method as hydrogenation and adds the following chemicals as potential reactants.

perchloric acid lead anode and cathode methanol mineral spiritsplatinum lithium aluminum hydride methanolplatinum chloride sulfuric acid ethanolethyl ether acetic acid

17

3.4 Phenyl-2-Propanone

Meth can be made from phenyl-2-propanone through a Leuckart reaction or by reductive amination. In the Leuckart reaction, phenyl-2-propanone, formamide, and formic acid are heated together to produce N-formylamphetamine, which can be hydrolyzed with hydrochloric acid to yield meth. Alternatively, the N-formylamphetamine can be reduced with lithium aluminum hydride to produce meth (White 2004).

In reductive amination, phenyl-2-propanone is combined with methylamine in alcohol to produce a Schiff’s base, which can be reduced to meth using aluminum amalgam (aluminum foil) with a small amount of mercuric chloride. The reaction is highly exothermic. Nitromethane can be used in place of methylamine, as can ammonia or hydroxylamine, but the yields are typically lower (White 2004). White (2004) also identified sodium borohydride, sodium cyanohydridoborate, sodium metal, and hydrogen with a platinum, palladium or Raney nickel catalyst as reducing agents.

3.5 Appearance

Meth appears on the streets in basically three forms: tablet, powder, or crystal.

Tablet. Meth tablets are produced primarily in Burma and usually contain a combination of powdered meth and caffeine. Meth tablets found in the United States typically are green or orange-red in color, imprinted with a

variety of symbols (most commonly WY or R) and are approximately the size of a pencil eraser. Meth tablets typically are ingested orally, so they are sometimes flavored and scented like candy (grape, orange, or vanilla). Tablets also are smoked by placing the tablet on a piece of aluminum foil and passing a heat source underneath the foil until the tablet melts and vapors are released. Meth tablets also can be crushed and snorted or mixed with a solvent and injected (NDIC 2004).

Powdered. Powered meth, also called crystal meth or crank, is the most common form of the drug encountered in the United States. Clandestinely produced powdered meth is crystalline in texture, bitter-tasting, soluble in water, and produced in several colors (white, pink, red, tan, and brown),

depending on the production method employed. Powdered meth usually is injected or snorted, but can also be ingested or smoked (NDIC 2004).

Ice. Ice meth, also known as glass, shabu, or batu, is a pure, highly addictive form of meth resembling shards of ice. Produced primarily in Guam, Hawaii, and Mexico, ice is the product of the process of recrystallizing powdered meth in a solvent, such as water, methanol,

ethanol, isopropanol, or acetone, to remove impurities. Ice typically is smoked using either a glass pipe, an empty aluminum can, a piece of aluminum foil, or a light bulb (NDIC 2004).

18

3.6 Health Effects

The health effects of meth are taken in the context of this paper to mean all aspects of exposure to meth production and use. Health effects will vary depending upon when in the process exposure occurs. For example, a user, but not a cooker, will be exposed only to the direct effects of taking meth, whereas the cooker is exposed not only to the drug through use, but also to the effects of any chemicals used to manufacture the meth, plus the byproducts and wastes. The children of cookers may not be using meth, but they are exposed to a chemical soup in the air they breathe, the surfaces they touch, and potentially careless storage practices for process chemicals and wastes. Law enforcement officials, in addition to facing the hazard of booby traps and assault with a variety of weapons, may walk into an ongoing cook when hazards from chemicals are at their height. Chemical vapors from cooks can be distributed via common air ducts to other apartments in multi-unit buildings, affecting other inhabitants. Abandoned waste is a hazard to whoever comes upon it. Incidents have been reported in which hospital workers have become ill while administering to a cooker seeking medical care due to injuries sustained in a production accident (Burgess 1997).

Appendix A contains a table of many of the chemicals that may be found in meth labs along with associated hazard, health effects, and fate and transport information (when available). Salocks and Kaley (2003) present data on meth in the format of a material safety data sheet that includes chemical properties, appearance, acute and chronic health effects, and fate and transport information.

3.6.1 Users

Even in small doses, meth can increase wakefulness and physical activity and decrease appetite. According to Goldfrank’s Toxicologic Emergencies, as cited in Chesley (1999) the acute physical effects of meth can include the following:

• Hypertension • Headache• Rapid pulse • Euphoria• Abnormal heart rhythms • Anorexia• Heart muscle oxygen deprivation • Teeth grinding• Heart inflammation • Paranoid psychosis• Hyperthermia (temperatures to 108o F) • Sweating• Nausea • Rapid breathing• Agitation • Dilation of pupils• Seizures • Tremors• Intracerebral hemorrhage • Abnormal uncontrolled body

movements NIDA (2002) reports that the symptoms of chronic abuse can include violent behavior, anxiety, confusion, and insomnia. Chronic use may include a number of psychotic

Figure4.Skin Lesions from Excessive Scratching of Imaginary Mites (Source: NACo)


19

features, such as paranoia, auditory hallucinations, mood disturbances, and delusions. One type of delusion is the feeling that there are insects crawling on the skin, which results in the user trying to scratch them. Figure 4 shows skin lesions from excessive scratching. Exposure of a fetus to meth during pregnancy may result in premature delivery; an altered neonatal pattern, such as extreme irritability; and congenital deformities.

Another aspect of the long-term effects of smoking meth is the severe effect it has on oral health. This effect has led to the coining of the phrase “meth mouth.” In its most severe

form, the user is left with little more than blackened stubs for teeth. Figure 5 shows a mild case of meth mouth, which is believed to be caused by corrosion from the release of production contaminants (muriatic acid, phosphorous, and sodium hydroxide) into the smoke. A dry-mouth effect leaves less saliva to cleanse the teeth. Tooth grinding and poor oral hygiene over long periods also contribute to the effect (Cecil 2006).

In addition to the direct effects of meth on the body, the pattern of use often results in prolonged periods of neglect of body needs, such as food and sleep. This behavior tends to have a wasting effect on the body, as illustrated in Figure 6.

3.6.2 Cookers

Most small meth labs are crude. They often lack the equipment to determine the exact temperatures of the cooking mixtures, which can result in fire, explosion, and production of poisonous gases. The equipment usually is not specifically designed for use in meth production, and unless it is done outside, the cooking area is generally poorly ventilated. An examination of the chemicals used in the cooking processes shows that most of them are either toxic, corrosive, flammable, or a combination of these characteristics.

Figure5. Meth Mouth (Source: Goddard 2006)Figure5. Meth Mouth (Source: Goddard 2006)

Age 31 Age 41

Figure6.The Wasting Process of Meth Use (Source: NACo)

Age 31 Age 41

Figure6.The Wasting Process of Meth Use (Source: NACo)

3.6 Health Effects

The health effects of meth are taken in the context of this paper to mean all aspects of exposure to meth production and use. Health effects will vary depending upon when in the process exposure occurs. For example, a user, but not a cooker, will be exposed only to the direct effects of taking meth, whereas the cooker is exposed not only to the drug through use, but also to the effects of any chemicals used to manufacture the meth, plus the byproducts and wastes. The children of cookers may not be using meth, but they are exposed to a chemical soup in the air they breathe, the surfaces they touch, and potentially careless storage practices for process chemicals and wastes. Law enforcement officials, in addition to facing the hazard of booby traps and assault with a variety of weapons, may walk into an ongoing cook when hazards from chemicals are at their height. Chemical vapors from cooks can be distributed via common air ducts to other apartments in multi-unit buildings, affecting other inhabitants. Abandoned waste is a hazard to whoever comes upon it. Incidents have been reported in which hospital workers have become ill while administering to a cooker seeking medical care due to injuries sustained in a production accident (Burgess 1997).

Appendix A contains a table of many of the chemicals that may be found in meth labs along with associated hazard, health effects, and fate and transport information (when available). Salocks and Kaley (2003) present data on meth in the format of a material safety data sheet that includes chemical properties, appearance, acute and chronic health effects, and fate and transport information.

3.6.1 Users

Even in small doses, meth can increase wakefulness and physical activity and decrease appetite. According to Goldfrank’s Toxicologic Emergencies, as cited in Chesley (1999) the acute physical effects of meth can include the following:

• Hypertension • Headache• Rapid pulse • Euphoria• Abnormal heart rhythms • Anorexia• Heart muscle oxygen deprivation • Teeth grinding• Heart inflammation • Paranoid psychosis• Hyperthermia (temperatures to 108o F) • Sweating• Nausea • Rapid breathing• Agitation • Dilation of pupils• Seizures • Tremors• Intracerebral hemorrhage • Abnormal uncontrolled body

movements NIDA (2002) reports that the symptoms of chronic abuse can include violent behavior, anxiety, confusion, and insomnia. Chronic use may include a number of psychotic



20

Combine the crudeness of the lab with the characteristics of the chemicals and there is a high probability of spills, splashes, toxic fumes, fire, and explosion. Close to 20 percent of meth labs are discovered because of fire and/or explosion (Committee on Science 2005). Also, cooks rarely have any regard for or knowledge of the use of personal protective equipment. Figure 7 shows corrosive burns on a cook’s forearm. While chemical fumes, including those of meth itself, will permeate through most, if not all, of the living quarters, the highest concentrations are in the cook area, as are the largest number of open chemical containers.

Martyny et al. (2004 a&b and 2005 a&b) have done several analyses to determine ambient concentrations of chemicals in meth labs during and after cooking. Although studies do not cover all processes or all chemicals that could be used, they do provide representative concentrations.

Anhydrous Ammonia Process (Martyny et al 2004b). Within five minutes of beginning the cook, the ammonia levels exceeded the range of the instrument (maximum reading of 3,348 ppm), and the average concentration in the cook area at one site was 410 ppm. Note that the NIOSH immediate danger to life and health (IDLH) standard for ammonia is 300 ppm. Inhalation of low levels of ammonia causes upper respiratory tract irritation. Inhalation of moderate to high levels of ammonia may result in swelling of nasal and upper respiratory tissues (burns in some cases) and fluid buildup in the lungs. Dermal contact may result in blistering and deep penetrating burns. Chronic exposure may cause chronic skin, eye, and respiratory irritation (Kaley and Salocks 2003a). Hydrogen chloride (HCl) analyses were affected by the high ammonia levels and were considered unreliable. HCl fumes were visually observed during the cook, which suggests a relatively high level. The NIOSH IDLH for HCL fumes is 50 ppm. HCl exposure to the skin causes irritation and possible burns. Splashing of the liquid onto the skin causes burns. Long-term exposure can lead to permanent lung and respiratory tract damage. Meth levels, especially during the salting-out phase, ranged from 7.6 µg/m3 to >680 µg/m3. These concentrations resulted in a meth coating on most of the building surfaces. Organic vapors were not tested.

Hypophosphorus and Phosphorous Flake (Martyny et al. 2005b). Phosphine gas was produced during the two cooks at levels measured as high as 13 ppm, which are below the NIOSH IDLH of 50 ppm. It should be noted, however, that considerably higher levels can be generated if the cook mixture is overheated. Several cookers have died from exposure to phosphine gas (Willers-Russo 1999). Inhalation of phosphine at non-lethal doses may cause dizziness, drowsiness, nausea, chest pressure, tremors, convulsions, and central nervous system damage (Kaley and Salocks 2003b). Iodine vapors were

Figure7.Chemical Burns (Source: NACo)Figure7.Chemical Burns (Source: NACo)

21

also detected but at very low concentrations (a high of 5 ppb). The IDLH of iodine is 2 ppm, and inhalation may result in severe irritation and burns to the respiratory tract. Inhalation of concentrated vapors may be fatal. Hydrogen chloride vapors were detected at levels up to 400 ppm. Coleman fuel was used as the solvent, and several hydrocarbon species were detected at levels over those found in ambient outdoor air. Their concentrations ranged from 890 to 11,000 ppb. The hydrocarbons detected were not considered harmful at the levels found. Meth vapors were found at concentrations up to 4,000 ug/m3 and were primarily released during the salting-out phase. Low levels of meth were found on surfaces throughout the building.

Red Phosphorus (Martyny et al. 2005a). In this test, hydrogen chloride vapors were relatively low (high of 0.42 ppm); however, the authors have seen values as high as 150 ppm in other red phosphorus cooks. The highest iodine level detected was 0.12 ppm. Hydrocarbons, alcohols, and some chlorinated hydrocarbons associated with the extraction solvent were found at levels under ppm. Meth vapors at concentrations up to 780 µg/m3 were detected in the cook area.

These analyses show that cookers are exposing themselves to potentially damaging levels of phosphine, hydrogen chloride, and ammonia. The detection of hydrocarbons during a cook indicates that they do vaporize and will be present. The solvent used in these experiments was Coleman fuel, a mid-boiling range mixture of hydrocarbons. Other solvents of varied toxicity can be used in the meth production process, and several of them have a much lower boiling point than Coleman fuel. These solvents are likely to be found in much higher concentrations than those found in the described experiments. Unlike law enforcement personnel, whose exposure to these chemicals is generally infrequent, the cooker’s chronic exposure usually results in more permanent long-term health problems.

3.6.3 Cooker Families

The term “cooker families” is used in this context to mean those individuals who live with or visit the individual(s) operating the meth lab. It may include family members who live in a domicile and are unaware that the basement is being used for a lab. As was shown in the Martyny studies described above, the airborne concentrations of various chemicals a person is exposed to during a cook and afterwards are directly related to the distance from the cook and how well the cook area is ventilated. A remote rural lab, located in a house where there is little chance of neighbors or passersby smelling chemical odors, can be vented to reduce exposure to the cookers and children. On the other hand, a cooker in a small apartment or house in the city or suburb needs to prevent any fumes from escaping the building to avoid discovery. Suppressing ventilation increases inhalation exposures. At the very least, living in a dwelling where cooking is taking place subjects the non-user to low-level chronic exposures to meth and other chemicals.

22

Another consideration, if the cooker is also a user, is how the meth is consumed. Snorting and smoking will not necessarily occur in the cooking room, but both methods will spread meth to other parts of a domicile or room in concentrations that a cook alone would not. In a 2004 study, Martyny et al. simulated smoking meth in a hotel room. In their experiment, they found that multiple smokes were capable of depositing from 32 to 35 µg/100 cm2 on bathroom tiles. The amount deposited depended upon the number of smokes and the absorption rates of the individuals smoking and could be higher than recorded if done over a long period of time. The deposition levels, while not as high as those encountered in a domicile where meth was cooked, were still moderately high. The authors concluded if meth has been smoked in a residence, it is likely that all other people present will be exposed to meth vapors during the smoke and to surface-deposited meth after the smoke.

Children, who are present in approximately 30 to 35 percent of lab seizures (Peed 2004), are an especially vulnerable group. In the lab seizures that occurred in 2005, 1,660 children were involved, two of whom died (U.S. White House Office of National Drug Control Policy 2006). Children living in domiciles where meth is cooked are exposed to meth through inhalation and ingestion (hand-to-mouth behavior). In addition, numerous other chemicals may be found in the air, especially during and immediately after a cook (Swetlow 2003). Ferguson (2000) describes ingestion dangers at meth labs as follows: “[I]t is not unusual to observe that drugs and chemicals in these illicit labs have been stored in unlabeled or inappropriately labeled containers (meth solution in “Snapple” bottles, solvents in soft drink containers, etc). This situation is further exacerbated by the fact that these mislabeled food containers may be stored in food preparation areas or even in the refrigerator.” In addition to chemical hazards, children living in meth homes are at increased risk of severe neglect by parents who are too high or too fatigued to give them proper attention. Raided meth homes, more often than not, have very little food in them (meth is an appetite suppressant). Meth use also is associated with increased domestic violence toward both children, if present, and partners.

People visiting or living in a domicile where meth is manufactured are also subject to fire and explosion dangers. As noted above, 20 percent or more of meth labs are discovered because of fires and/or explosions (Figure 8). In one incident, a cooking flask cracked, causing its contents to explode into a fire ball that killed one of the cooks and severely burned a visitor. There were 15 people in the home when the explosion occurred, including the cook’s two children (Miller 2002).

Figure8.Meth Kitchen Fire (Source: Boulder County CO)Figure8.Meth Kitchen Fire (Source: Boulder County CO)

23

3.6.4 Neighbors

Proximity governs how a neighbor may be affected by meth lab activity. A survey conducted by the California Department of Toxic Substances Control (CDTSC 2004) of various law enforcement agencies across the country indicated that 49 percent of the labs encountered were in single family homes, 16 percent in vehicles, 14 percent in apartment complexes, 11 percent in motel/hotel settings, 6 percent in duplexes, and 17 percent in “other” locations.

People living in single family neighborhoods are unlikely to be affected directly by cooks (i.e., direct exposure to meth or byproduct vapors). Depending upon how the cooker disposes of the wastes, there may be some possibility of contact with wastes, especially by children.

Apartment buildings, duplexes, and hotel/motel settings pose a different situation. Generally, when a lab is taken down by law enforcement, only the rooms directly open to the cook are quarantined. This is probably due to the fact that cooks generally make every effort to hide their operations, especially by preventing vapors from escaping the premises. There may, however, be problems in buildings where the units share ventilation ductwork. In these cases, exposure to low levels of meth and other chemicals is possible. Fire and explosion in a meth lab present a real danger to neighbors with common walls. For example, a fire started in a meth lab at an apartment complex in West Valley City, Utah, completely destroyed 12 units, damaged 12 others, and displaced 40 people (UDPS 2004). The Centers for Disease Control and Prevention (CDC 2005) reports that between January 2000 and June 2004, 255 meth events resulted in ordered evacuations, with the length of the evacuation ranging from 1 to 96 hours.

3.6.5 Law Enforcement/First Responders

Law enforcement officials are nearly always the first responders to enter a suspected meth lab property. Because the operator of a mom-and-pop lab is considered likely to be armed, paranoid, and violent, police generally make the entry without respiratory protection so as not to restrict vision or handicap their ability to defend themselves. This entrance, brief though it may be, will often expose them to toxic vapors and the potential for fire and explosion. Meth lab operators also may booby-trap the premises using explosives and trip-wire devices. Burgess et al. (2002) in a study of law enforcement officers involved with drug labs reported a general decline in forced expiratory volume (a lung function test) in those not using respiratory protection. General complaints were primarily headache and respiratory, mucous membrane, and skin irritation (Burgess 1997).

Firefighters who have not had training in hazardous materials/meth lab responses often do not realize that their structural firefighting gear (e.g., turnout coats) does not offer protection against the toxic gases, chemicals, or explosions that can be associated with meth labs (IAFF 1995). In 1999, an Oregon firefighter who was wearing turnout gear

24

received chemical burns from hydrochloric acid during a fire at a meth lab (CDC 2000). Many of the firefighter injuries reported in Washington State between 1995 and 2000 were related to meth labs, and complaints included shortness of breath, respiratory irritation, gastro-intestinal irritation, and headache (WSDH 2002).

3.6.6 Hospital Workers and Emergency Medical Services Personnel

Hospital workers and emergency medical services (EMS) personnel are often called upon to treat people suffering from meth abuse or who have been involved in a lab accident. NACo (2006) reports that more emergency room visits are related to meth than to any other drug. Medical personnel face two major hazards from meth-involved patients. In the first case, meth users tend to be physically abusive, and medical personnel often have to tend to the medical needs of the patient while at the same time protecting themselves from violence. In the second case, the bodies and clothing of meth lab operators may be highly contaminated by exposure to chemicals during normal meth manufacturing or by a meth production accident.

Several hospital incidents are described in the literature. In one (Peterson 2000), an oven exploded, sending chemicals onto one of the cooks, who was taken to a hospital for treatment. Attending hospital employees became ill when exposed to the chemicals on the patient. In addition, three ambulance personnel and two police officers reported eye and respiratory irritation. Burgess (1999) describes another burn case resulting from a lab explosion; several hospital staff members attending the victim were affected by the chemicals on him.

A newspaper article in the Winston-Salem Journal (Mitchell and Shaffrey 2006) reports that one local hospital has instituted formal protocols for handling patients who have been exposed to meth manufacturing. These protocols include decontamination procedures upon admittance and the requirement that staff don protective gear—a fluid-resistant suit, mask, goggles, and rubber boots—when attending the patient.

4.0RegulatorySettingAll levels of government have regulated the response to meth labs. At the state level, responsibility for setting standards has generally fallen to public health authorities, although state environmental agencies are generally charged with enforcing the state equivalent of CERCLA and RCRA. In addition to or in place of state regulations, the local public health authorities may have their own rules and regulations.

4.1 Federal

At the federal level, the primary laws governing response and cleanup are CERCLA and RCRA. The DEA also sets out an approach it expects to be followed when responders are using its funds.

25

4.1.1 CERCLA

CERCLA, better known as Superfund, was passed in 1980 to provide the federal government with a mechanism to respond to the growing number of uncontrolled hazardous waste sites that were being discovered. It also authorizes response to any release of hazardous substances to the environment. Response is governed by the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). In 1986, the Superfund Amendments and Reauthorization Act (SARA) amended CERCLA to require among other things a strengthening of community and state involvement, consideration of other federal laws as well as state and local requirements, and an amendment of the NCP to reflect these changes.

The NCP provides for two general response programs: removal and remedial actions. Removal actions are short-term in nature and are generally taken to abate or mitigate imminent threats. There are three types of removal actions based on the seriousness of the threat and the time required to mitigate it (U.S. EPA 1992). Emergency removal actions are those that require a response to occur as soon as possible. Examples are an overturned tanker truck or a fire at a chemical facility. Time-critical removal actions are those in which the lead agency has determined that a response is necessary, and while the situation might not present an imminent hazard, there is potential for exposure to or spread of hazardous substances. A time-critical removal must begin within 6 months of the decision that cleanup is necessary. Non-time-critical removals are those in which the lead agency decides that a removal is necessary, but a planning period of more than six months is available before on-site activities must begin.

Remedial actions are generally performed at sites having complex and widespread contamination. They involve an in-depth characterization of the site subsurface, contaminant distribution, and exposure pathways for both human and ecological receptors. The site characterization provides the lead agency or responsible party with the information necessary to evaluate various approaches and technologies to clean up the site. Once a cleanup approach is agreed upon, a record of decision is issued that formally lays out the problem, the approach chosen, and why it was chosen over other candidate approaches.

In carrying out a remedial action, EPA must consider all federal, state and local laws and requirements to determine if they are applicable or relevant and appropriate requirements (ARARs). Response actions are required to meet ARARs to the extent practicable. Applicable requirements are those that specifically address the action that the EPA is going to perform. For example, if EPA is going to dispose of hazardous substances, it must do so according to the rules set out in RCRA or the state equivalent. Relevant and appropriate requirements refer to actions that while not specifically addressed by other laws and regulations are sufficiently similar to the other laws and regulations that their use is well suited to the particular site.

The Small Business Liability Relief and Brownfields Revitalization Act of 2001 amended CERCLA to, among other things, promote brownfields cleanup and reuse and provide

26

financial assistance for revitalization. Included in the definition of brownfields properties that are eligible for federal grant funding (assessment and cleanup) are properties contaminated by a controlled substance (as defined in section 102 of the Controlled Substances Act, 21 U.S.C. 802).

While meth labs are rarely large or hazardous enough to warrant a federal CERCLA response action, the environmental protection agencies in some states maintain an emergency response capability specifically directed at meth and other clandestine drug laboratories. For example, the California Health and Safety code section 25354.5 requires the state Department of Toxic Substances Control (DTSC) to remove and dispose of hazardous substances discovered by law enforcement officials while investigating clandestine drug laboratories. Over a five-year period, the Drug Lab Removal Program (a part of the Department’s emergency response division) funded and coordinated removal and disposal actions at more than 12,000 illegal drug-related lab activities (CDTSC undated).

4.1.2 RCRA

RCRA, which was passed in 1976, controls the disposal practices for municipal solid waste landfills (Subtitle D) and the treatment, storage, and disposal of EPA-defined (40 CFR 261) hazardous wastes (Subtitle C). EPA defines wastes in terms of being characteristic or listed. Characteristic wastes are divided into four categories: ignitability, corrosivity, reactivity, and toxicity.

An ignitable waste has one of the following properties:

• It is a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume, and it has a flash point less than 60° C (140° F).

• It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard.

• It is an ignitable compressed gas.

• It is an oxidizer as defined in 49#CFR 173.151.

Chemicals that have been identified with some meth production methods that might fall under the characteristic of ignitability are red phosphorus, acetone, coleman fuel, ethanol, ethyl ether, and hexane.

A corrosive waste is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, or can corrode steel at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55° C. Chemicals associated with some meth production methods that might fall under the characteristic of corrosivity are hypophosphorus acid, hydroiodic acid, hydrochloric acid, nitric acid, sulfuric acid, formic acid, mercuric chloride (in liquid), sodium hydroxide (in liquid), sodium thiosulfate, and phosphoric acid.

27

A reactive waste has one or more of the following properties:

• It is normally unstable and readily undergoes violent change without detonating.

• It reacts violently with water.

• It forms potentially explosive mixtures with water.

• When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.

• It is a cyanide- or sulfide-bearing waste that when exposed to pH conditions between 2 and 12.5 can generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.

• It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.

• It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

• It is a forbidden explosive as defined in 49 CFR 173.51, a Class A explosive as defined in 49 CFR 173.53, or a Class B explosive as defined in 49 CFR 173.88.

Sodium metal and lithium aluminum chloride are chemicals that have been identified with some meth production methods and might fall under the characteristic of reactivity.

The toxicity characteristic is established with the Toxicity Characteristic Leaching Procedure (Test Method 1311 in SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods) when the leachate contains a chemical(s) that is listed in 40 CFR 261.24, Table 1, with concentrations equal to or above those contained in the table. Chloroform and mercury, which are chemicals associated with some meth production methods, might fall under the characteristic of toxicity.

The listed EPA hazardous wastes fall into four broad categories. The first are process related but are not linked to a specific industrial source. These wastes carry an “F” code and include such processes as spent solvents from degreasing, electroplating baths involving cyanides, and wastewater from creosote wood treating. The potential for the generation of an F003 or F005 waste exists at meth labs. F003 is for spent non-halogenated solvents that include the meth lab-associated chemicals ethyl ether, acetone, and methanol. The listing is for ignitability, and if the waste does not exhibit this characteristic, then it would not qualify as an F003 waste. F005 contains non-halogenated spent solvents that are considered both ignitable and toxic. Meth-associated chemicals contained in F005 include isopropanol, benzene, and toluene.

The “K” series of listed wastes are for specific industrial process waste streams. There are some 170 plus waste streams listed, but none address meth production and none apply to meth lab waste management.

28

The “P” (40 CFR 261.33(e)) and “U” (40 CFR 261.33(f)) series lists are commercial products. The products listed in the “P” series are regarded as acutely hazardous, and the U products are toxic. The chemicals on both these lists become subject to RCRA regulation when they are discarded. In other words, a gallon bottle of unused benzene found at a meth lab may be subject to fire-code storage requirements, but it is not subject to RCRA until a decision is made to send it to a disposal facility. This is important because while there are holding times associated with accumulating hazardous wastes before having to obtain a RCRA storage permit, there are no holding times associated with storing a commercial product.

The “P” and “U” commercial products are also considered to have been discarded if they are spilled or poured on the ground. At that point, the soil becomes a hazardous waste for purposes of off-site treatment or disposal. Note that many of the chemicals associated with meth production are on one or the other of these lists. Requirements for the disposal of contaminated soil are found in 40 CFR 268.49. In general, land disposal restriction requirements for contaminated soil are linked to the underlying hazardous constituents requirements. An underlying hazardous constituent is any constituent listed in 40 CFR 268.48 Table UTS (Universal Treatment Standard) that can reasonably be expected to be present at the point of generation of the hazardous waste at a concentration above the constituent-specific treatment standards. Contaminated soil requires treatment before it can be disposed of in a Subtitle C landfill if it contains chemicals with concentrations that are ten times those listed in the UTS table.

RCRA recognizes three types of hazardous waste generators:

• Large-quantity generators produce over 1,000 kg per month.

• Small-quantity generators (SQG) produce between 100 and 1,000 kg per month.

• Conditionally exempt small quantity generators (CESQG) produce under 100 kg of hazardous waste or 1 kg of acutely hazardous waste (U.S. EPA 2001).

Large-quantity generators are required to have an EPA generator identification number, use a hazardous waste manifest if the waste is transported off site to a permitted treatment, storage, or disposal facility (TSD), and cannot accumulate wastes on site for a period exceeding 90 days. Small-quantity generators are required to have an EPA generator identification number, use a hazardous waste manifest if the waste is transported off site to a permitted TSD, and cannot accumulate wastes on site for a period exceeding 180 days (270 days if the transport distance is greater than 200 miles). CESQGs are not required to have an EPA identification number, do not have to manifest their hazardous waste shipments, cannot accumulate wastes longer than 180 days, and can dispose of those wastes in a Subtitle C facility or any Subtitle D facility willing to accept them. Note that state requirements may be different. Some states do not recognize CESQGs and require all small-quantity generators to adhere to SQG requirements, including forbidding the disposal of wastes in a Subtitle D facility. Residential property owners who are responsible for final cleanup of a meth laboratory

29

are likely to qualify as CESQGs, and in states that recognize CESQG will have the option of disposing of meth-related wastes at a municipal landfill, provided it will accept them. Note that unless the cleanup contractors are directly affiliated with a TSD, it is unlikely they will have an EPA identification number of their own, and they will not be willing to act as the generator of record.

In many cases, bulk chemicals associated with a meth lab and considered hazardous wastes are handled by a government contractor as part of the initial law enforcement action. For example, the Colorado Department of Public Health and Environment states:

The chemical wastes produced by the process of manufacturing meth are often hazardous wastes. These chemicals are generally removed by law enforcement at the time of the meth lab seizure. . . Based on best professional judgment and knowledge of meth labs, the Department has determined that material and debris that are contaminated with residual concentrations of meth lab chemicals and wastes can be managed as [non-hazardous] solid waste (CDPHE 2005b).

Bulk chemicals that are corrosive can often be neutralized and disposed of at the site, e.g., by carefully adding baking soda to acids or vinegar to bases.

4.1.3 DEA

The DEA is responsible for enforcing the criminal aspects of meth manufacturing, which is beyond the scope of this document; however, as part of its enforcement activities it is also responsible for meth lab removal actions and has developed protocols for its cleanup contractors to follow. One policy decision the DEA has made for chemicals and equipment found at meth labs is to treat them all as hazardous wastes (Joint Federal Task Force 1990 and DEA 2005b). As of September 30, 2006 a federal rule was put in place by DEA governing the sale of products containing precurser chemicals (DEA 2006c).

4.1.4 Emerging Developments

Legislative initiatives are being considered to deal with meth labs at all levels of government. ONDCP, DOJ, and HHS (2006) jointly sponsor a Web page containing up-to-date information on legislation and policy developments at all levels of government. http://methresources.gov/InformationTypeResource.aspx?InfoId=7.

4.2 States

Meth lab cleanup and response actions are generally performed at the state and local levels. The state and local regulations and standards that cover meth labs vary widely from one jurisdiction to another. This section provides a brief summary of the types of regulations and standards being used by selected states. It is based primarily on information from the Web sites of 21 states and four local jurisdictions. Because websites often contain incomplete information or may not be up to date, this information

30

should be considered a broad description of the range of regulatory strategies and practices that are in place rather than an inventory of all regulations and procedures in all states. Some of the most current information is based on materials collected by the National Alliance for Model State Drug Laws, which was originally created as a presidential commission charged to create a model code of laws to help states effectively address alcohol and other drug abuse. The Alliance regularly tracks state laws and selected related statutes.

Most of the meth-related regulations tend to revolve around four basic issues: precursor chemicals, cleanup and removal processes and standards, victim protection, and compliance and enforcement.

4.2.1 Precursor Chemicals

To prevent the production of meth, 38 states have passed measures establishing or enhancing restrictions on over-the-counter sales of pseudoephedrine products (National Alliance 2006b). There are four general categories of restrictions including:

•Restrictions on the display of products, e.g., locked display cabinets, video surveillance, anti-theft mechanisms, placement of products within view of staffed counters.

• Restrictions on who can sell or buy specific products and on the sales process, e.g., only pharmacies or other certified establishments may sell specified chemicals, purchasers are required to provide ID, sellers are required to maintain a log of sales.

• Restrictions on the quantity that can be sold or purchased within a specified time period, e.g., a maximum amount in single transaction, maximum grams per month.

• Restrictions on the packaging of the product, e.g., blister packaging, maximum amount in single pack.

In addition, 11 states have classified ephedrine and/or pseudoephedrine as a Schedule V controlled substance, and three more have bills pending to do so. The State of Oregon, by classifying pseudoephedrine as a Schedule III controlled substance, requires a prescription to dispense the drug.

Although most of the chemicals used in conjunction with pseudoephedrine are already regulated by the government, some states (e.g., Illinois and Indiana) have passed legislation making the possession, procurement, transport, storage, or delivery of anhydrous ammonia with the intent of using it for the manufacture of meth a felony. In New Hampshire, a person in the possession of any chemical reagent or precursors with the intent of manufacturing meth is guilty of attempted manufacturing of meth (National Alliance 2006e).

31

4.2.2 Cleanup and Removal Processes and Standards

The authority to require cleanup of a meth lab is generally linked to local health and/or building codes. More than 15 states and an unknown number of local jurisdictions have some form of guidelines, minimal or extensive, recommended or required, for the removal and cleanup of a seized meth lab. The discussion of the processes and standards below is an indication of the diversity of these guidelines.

FirstResponderActivities. When a meth lab is identified, local law enforcement, sometimes in conjunction with members of other public agencies (e.g., health department, environmental control agency), is traditionally the first responder. The first responder usually removes gross contamination from the seized meth site. Because of the potential hazards faced by these responders, some jurisdictions (e.g., Illinois) require officers performing clandestine laboratory enforcement duties to be certified, to undergo annual medical screenings, and to be equipped with protective wear and safety equipment (Illinois State Police 2004). In North Carolina, the State Bureau of Investigation conducts awareness training for local law enforcement officers, firefighters, and emergency medical personnel on the detection of clandestine laboratories. The State Bureau also helps ensure that, in some of the hard-hit counties, law enforcement personnel become certified in Hazardous Waste Operations and Emergency Response, or HAZWOPER (Hetzel 2005). At the same time, many states do not address the need for training and/or certification of their responders; however, the federal OSHA requirements do require training when hazardous materials response is part of the person’s job (OSHA 2006).

CleanupPractices. The diversity of practices among jurisdictions is repeated throughout the various stages of the cleanup process. In Iowa, the remediation process is left up to the property owner. In North Dakota, the owner can certify to the local health agency that the property has been cleaned up (North Dakota 2005). In contrast, the County of Sacramento, California, requires pre- and post-remediation assessments to be conducted and work plans developed by either a Certified Industrial Hygienist or a Registered Professional Engineer with demonstrated relevant experience. The County also requires remediation tasks to be conducted by a licensed hazardous materials contractor (SCEMD 2003). Minnesota defines responsibilities for all parties involved in the process, including the local authority that approves the cleanup contract and work plan; the agencies that maintain records, provide guidance for stakeholders, and oversee sampling facilities; the contractors; and the property owners (MDH 2006).

State guidelines range from comprehensive descriptions of the stages of cleanup and sampling protocols and analysis (e.g., Alaska, Colorado, Minnesota, Oregon, and Washington) to more general descriptions of the cleanup process (e.g., Arkansas, Iowa, Kansas, and Missouri). In its interim guidance for meth labs, the State of Tennessee presents a four-tiered program describing the minimum typical cleanup requirements for four types of sites: abandoned or ‘spooked-cook,’ motel/hotel ‘transient-cook,’ rental property ‘entrenched cook,’ and the ‘mass production cook/drugs-for-profit’ super lab.

32

Several states (e.g., Alaska, Colorado, Minnesota, Tennessee, and Washington) have adopted quantitative decontamination standards for meth, VOC, mercury, and lead at meth labs. Others (e.g., Arkansas, Michigan, and South Dakota) have suggested levels for meth only, while most states do not appear to have standards.

DocumentationandRecordkeeping. Most states with guidelines include fairly comprehensive documentation and recordkeeping procedures, beginning with the required posting of a notice of quarantine or warning at the site. In some states (e.g. Tennessee, Oregon, and Arizona) notice also is recorded at the county register and/or other public departments, or placed on an ‘unfit for use’ listing. Some jurisdictions also require or advise that written notice be given to home and business owners in the area.

Signed and dated records are generally required by the authorities. Examples include pre-assessment reports that diagram and detail conditions at the site once initial removal is conducted, work plans for remediation, post-remediation assessment reports, and sampling and analysis plans. Most work plans, when required, must be submitted for review and approval. In at least one jurisdiction (Salt Lake Valley, Utah), documentation is scrutinized at every stage. Pre- and post-cleanup photographs are normally included in the documentation packages, along with receipts and other relevant documents, such as chain of custody records and sampling result tables. A final report with a summary of the documentation may be required before a jurisdiction releases a site for reoccupancy. In the state of Michigan, a statement of compliance by the owner is required, while in Oregon, a Certificate of Fitness is issued by the state.

Some states require property owners to retain cleanup records for a specified number of years or until the property is sold or transferred. In the states of Alaska, Arizona, and Oregon, a property owner is required to provide written disclosure of the meth history of the site to a buyer or renter. In Oregon, the disclosure is attached to the sale or transfer document. Illinois requires records of medical screening for first responders to be retained for 30 years after the termination of employment (Illinois State Police 2004).

4.2.3 Victim Protection

According to a 2002 DOJ information bulletin, the number of children found at seized meth labs more than doubled from 1999 to 2001 (NDIC 2002). The Drug Enforcement Administration’s El Paso Intelligence Center (EPIC) notes that the number of children found in those locations jumped from 1,224 in 2000 to 3,474 in 2003 (Peed 2004). The risk of exposure to meth and other hazardous compounds on meth lab surfaces is likely to be much greater for children because they tend to place hands and objects in their mouths and to sit and play on floors, which places them at an increased risk. Recognizing the increasing danger to children in and around meth labs, state and local jurisdictions have or are in the process of enacting legislation and creating programs to coordinate the social, medical, and legal aspects of child protection.

33

Some states have either enacted or amended legislation making it unlawful to manufacture meth where children are present (e.g., Alabama and Iowa). Other states address the delivery, storage, possession, and/or disposal of meth where children are present in their laws (e.g., Idaho and Wisconsin). In the State of Indiana, a law enforcement agency that discovers a child less than 14 years of age at a meth lab must notify the Department of Child Services. Michigan is working on related legislation, including requirements for the Department of Human Services to assist and cooperate with law enforcement when a child has been exposed to meth. The legislation would allow for a medical examination of a child to be made without a court order if the child displays symptoms of exposure related to meth. It also requires the Family Independent Agency to refer cases to prosecutors if a central registry case involves a child’s exposure to or contact with meth production facilities. Some of the legislation specifies penalties, including imprisonment and/or fines. The State of Wisconsin recently approved a bill to increase penalties in cases where the endangered child is 14 years of age or younger. The bill includes a provision to terminate parental rights when a child is present at a meth manufacturing site (National Alliance 2006f).

In 1993, Butte County, California, initiated the Drug Endangered Children (DEC) program. The program brings together law enforcement officers, social workers, public health nurses, and district attorneys in a cooperative effort to remove children from homes where meth is produced. The program relies on a response team that is on call 24 hours a day. The team receives specialized training in meth production, its relationship to children, and evidence collection in child endangerment cases. Approximately 15 other California counties and at least nine states (Arizona, Idaho, Illinois, Missouri, Nevada, Oklahoma, Oregon, Utah, and Washington) have begun to replicate the DEC response teams in their jurisdictions (NDIC 2002).

4.2.4 Compliance and Enforcement

The most frequently identified compliance and enforcement issues involve liability, tagging and listing of sites, property use restrictions, and penalties.

Liability. Most jurisdictions stipulate clearly that the property owner or occupier is responsible for the cleanup costs of a meth site. In Colorado, property owner adherence to the cleanup regulations provides immunity from potential civil lawsuits (CDPHE 2005a). Under Minnesota law, if the property owner cannot be found or does not respond to notices, the county is authorized to proceed with cleanup or removal, including demolition and disposal of the structure as needed. The property owner is still held responsible for all costs incurred by the county and may be subject to a special assessment (MDH 2006).

TaggingandListing. In most jurisdictions, a seized property is tagged with a restricted entry sign that includes information on the location seized, date of and reason for seizure, and the local enforcement or other agency that seized or made arrests at the site. In the State of Arizona, the sign must also include a statement that it is a felony to violate this rule and a misdemeanor to disturb the notice of removal. The sign must

34

also state that if the property owner fails to remediate the property, he/she is subject to civil penalty. In addition to the warning signs, many localities are required to enter information of seized sites in a county/city register or on an ‘unfit for use’ list. Although the information may be amended once the property is cleaned up, the information is not necessarily deleted from the record.

PropertyUseRestrictions. In at least three states (Alaska, Arizona, and Oregon), a property owner must notify a buyer or renter in writing that the property was used for the manufacture of meth. Non-compliance is grounds for voiding the purchase or rental agreement and subjects the owner to civil penalties.

Penalties. Penalties for non-compliance with state and local laws governing meth labs range from misdemeanors to felonies and are punishable with fines and/or incarceration. As noted above, there are diverse penalties for violating many of the aforementioned laws and regulations (e.g., child endangerment laws; restrictions on possession, procurement, transport, delivery, or storage of restricted chemicals; and the various notification procedures). In at least one state, Oklahoma, persons charged with meth offenses are denied bond (Drug Reform 2005). In Oregon, contractors who fail to adhere to cleanup requirements are subject to license revocation, suspension, and civil or other penalties (OARs 2000).

5.0RemovalRemoval has a somewhat different meaning in clandestine lab work than it has in conventional environmental work. For the purposes of this paper, removal refers to activities associated with a law enforcement action. Typically in a meth lab investigation, law enforcement officials combined with first responders and/or a hazardous materials contractor collect evidence for the criminal investigation and then remove and properly dispose of gross contamination. Gross contamination is usually defined as materials that are immediately hazardous to health and safety and generally include lab equipment and chemicals (Figure 9), or in some jurisdictions, chemicals that are not in their original containers since many of the chemicals used are common household items. A cleanup (remedial action), which is discussed in the next section, occurs after law enforcement agents have left the premises. The cleanup addresses items such as contaminated rugs, clothing, furniture, walls, air ducts, sinks, appliances, and potential environmental damage from waste disposed of on site.

Different approaches may be taken to a cleanup response depending on whether the lab is active or inactive and for materials that are discarded in locales away from the lab.

Figure9.Motel Lab (Source: Niswonger 2003)

Figure9.Motel Lab (Source: Niswonger 2003)

35

5.1 Active Lab

The active lab presents the most complex of the situations encountered because it involves the presence of the cookers and associates, the potential for cooking to be in progress, heightened risk of exposure to toxic fumes, and the potential for explosion and fire.

The command structure for an environmental response to an active meth lab is different than that for conventional emergency responses for chemical releases in that the lead agency is law enforcement. There are several texts on meth lab removal activities (Alberta Municipal Affairs 2004, CPH undated, IAFF 1996, EPA undated, Joint Federal Task Force 1990 and DEA 2005). These texts are directed at different audiences but give a basic idea of what is needed for a meth lab takedown and removal.

As in conventional emergency response operations, the on-site supervisor (equivalent to an on-scene coordinator) has ultimate authority in how the response is carried out and ensures that standard operating procedures are followed. There may be a case agent (law enforcement officer responsible for supporting enforcement attorneys). If this individual is laboratory-safety certified, she will assume direction of the investigation (processing phase) and is responsible for ensuring:

• Standard operating procedures are followed.

• Evidence is properly collected, handled, and stored.

• Appropriate local health officials and the property owner, if different from the arrestee, are notified.

• A waste handling company is available.

The response effort should also have a designated site health and safety officer (SHSO). The SHSO has the following duties:

• Establishing work zones.

• Ensuring health and safety protocols are followed.

• Selecting appropriate personal protective equipment (PPE) for each stage of the investigation.

• Ensuring that emergency first aid equipment is available and ready for immediate use (e.g., first aid kit, eye wash, shower).

• Ensuring all contaminated disposal equipment is bagged and removed by the waste handling company.

• Ensuring that all contaminated non-disposable equipment is decontaminated.

• Ensuring chemical spill material is available.

36

The descriptions of site personnel and their duties are adapted from CPH (undated), which comes from draft State of California documents.

OSHA requires anyone entering a site where hazardous chemicals may be encountered to receive at least 40 hours of training. A work plan containing health and safety information and standard operating procedures for all routine tasks should be available for consultation, and all personnel should be familiar with it.

Following standard procedures for emergency response to a hazardous materials incident, the site should be divided into at least an exclusion zone, contamination reduction zone, and support zone (U.S. EPA 2000a). The exclusion zone is the lab and any area that may be contaminated and hence may require some form of PPE. The hazard reduction zone should be clean and is the area where a decontamination station is set up. The support zone is where equipment and the command center are located. Some jurisdictions also recommend that a shower tent be available in the event that children on site require decontamination. The site work plan should have a standard operating procedure for processing children.

There are generally four specific steps for addressing an active meth lab: raid, assessment, processing, and removal.

The raid is carried out by law enforcement officials. Its sole purpose is to apprehend everyone associated with the lab. Before entering a lab structure, it may be possible to sample the interior air with a small tube pump and real-time analytical devices to determine if it is safe to enter. While it is advisable that members of the raid party wear some form of positive-pressure, self-contained breathing apparatus (SCBA), or at a minimum an air-purifying respirator (APR), these items often are not used because they can reduce mobility and vision that may be needed to deal with armed residents of the lab. Police officers who raid meth labs report the most exposure injuries of all responders (CDC 2005). To reduce their exposure, police officers sometimes place suspects in a Tyvek® suit with booties and hood to avoid having to decontaminate the inside of the vehicle transporting them to the police station.

In the second phase of action, an assessment team enters the structure. The assessment team should be in level A or B personal protection gear. Level A is a totally contained system with positive-pressure supplied air (either SCBA, or in some cases, an air line). Level A suits are very expensive but provide maximum protection against respiratory and vapor/splash hazards. Level B is similar to level A but has a Saranex®

suit with hood. The hood design does not provide as much skin protection around the head and neck as the totally encapsulated level A design. Saranex® is preferred over Tyvek® because it is impervious, while Tyvek® breathes and will allow penetration of some chemicals. Because of OSHA regulations, at least two personnel (buddy system) must be in the structure at any given time. In addition, two dressed-out personnel must be on the outside of the structure in the event a rescue of the staff inside is required (CPH undated).

37

The purpose of the assessment is to determine the quality of the air, identify any fire or explosion potential, and look for booby traps. By observing the cooking area, the forensic chemist should be able to identify the meth production method. If a cook is still in process, the assessment team will try to terminate it. In some guidance, the termination step is left for the processing team (e.g., IAF 1995). Real-time gas meters are used to determine air quality. The meters should measure at the very least the lower explosive level and oxygen content of the air. Ammonia and phosphine meters are also recommended, as are colorimetric tubes that can measure acid vapors, such as hydrogen chloride and hydrogen iodide.

The assessment data provide the information necessary for the SHSO to determine the level of PPE required by the processing team. The quality of the data gathered (including completeness) and the choice of PPE can mean the difference between a safe or injured team. For example, in one reported case, a forensic chemist working in a well-ventilated lab without respiratory protection was unknowingly exposed to phosphine gas (which is odorless) for 20-30 minutes and became very ill (Burgess 2001). The processing team is the group that gathers evidence by taking photographs, videotapes, chemical samples, and fingerprints. CHP (undated) recommends that lab glassware, equipment, or containers of chemicals be inventoried for disposal rather than collected or stored.

The removal phase of the action may be carried out under the direction of the designated local official (law enforcement or public health) and a licensed waste disposal company. For example, in California the local official calls the state DTSC emergency response office and provides the duty officer with an address and inventory of materials to dispose of. The duty officer in turn contacts a DTSC hazardous waste contractor and arranges for pickup of the materials. The complexity of disposal for a removal action ranges from a few pounds of waste and a couple of gallons of solvents from a mom-and-pop lab that is just starting up to hundreds of pounds of waste and many gallons of solvent from a super lab that has been operating for some time.

Not all states have a structure as centralized as that of California, and in some areas the cost of the raids and removal falls entirely on the local jurisdiction’s law enforcement and first responders (firefighters). As discussed in the regulatory setting section, many of the chemicals and waste products found at meth labs have the potential to be RCRA hazardous wastes that are subject to generation, transportation, storage, and disposal regulations.

Missouri provides an example of a system to address this problem. The Clandestine Drug Lab Collection Program provides collection stations to selected fire and police departments across the state. These collection stations are designed to allow the safe sorting and storage of meth lab wastes and chemicals. They have features such as an alarmed fire suppression system, secondary containment, spill-control shelving, and electrical grounding. The stations are permitted as 90-day storage facilities and hence can have a scheduled pickup by a licensed hazardous waste hauler. By consolidating meth raid wastes and scheduling pickups, the state greatly reduces the number of trips a licensed waste hauler needs to make to properly dispose of hazardous wastes.

38

The Missouri system also provides a response trailer to the 25 law enforcement drug task forces located throughout the state. These 16-foot trailers are divided into two sections. The front section is designed to safely secure and transport meth lab equipment and chemicals to the temporary collection facilities. The rear section contains response equipment, such as PPE. The transport capability allows for expedient removal of lab wastes and eliminates the need for scheduling a waste hauler with on-site packaging and manifest requirements. To adhere to state RCRA laws, Missouri exempted the transport by law enforcement officials of hazardous wastes from a meth lab to a collection station from the point of generation requirements and altered the 90-day generator requirements to allow the storage at collection areas away from the point of generation (MDNR 2006 and Harris 2001).

5.2 Inactive Lab

As crime scenes, inactive lab sites will still need a law enforcement lead. The assessment, processing, and removal steps outlined above for an active lab are still valid as there is the danger of booby traps and the potential for chemicals left behind to be sufficiently reactive to cause a health and safety problem. Once the assessment team has swept the area in level B gear, a decision is made as to the appropriate level of PPE to use for the processing step. As the example for phosphine given above shows, a minimum of level C is probably a conservative choice to ensure responder safety. Following the gathering of evidence, any gross contamination should be removed by appropriate personnel.

5.3 Discarded Materials

Disposal of meth wastes in parks, vacant land, and along roads has become a common practice in some areas of the country. Because the wastes can be corrosive, flammable, toxic, and explosive they must be approached carefully. In many instances, they are bagged in plastic and their exact state is unknown. In addition, some chemicals used at different times during a cook may not be compatible with each other, and rough handling of the bag and its contents can result in undesirable outcomes. These meth wastes, whether they can be connected directly with an operating lab or not, are the result of illegal activity and as such constitute a crime scene. Trained law enforcement personnel and contractors experienced in hazardous materials cleanup are the only people who should attempt to handle these wastes (Figure 10).

Figure10.Neutralizing Soil (Source:Clay County IA)Figure10.Neutralizing Soil (Source:Clay County IA)

39

Especially dangerous wastes are containers used for generating hydrogen chloride (HCl) to salt out the meth base and for containing other compressed gases (propane, ammonia, and hydrogen) that they may or may not have been designed to hold. Kummerlowe (1998) lists the following HCl generators encountered in the field:

• propane tanks • Ziploc or plastic bags• plastic gasoline containers • glass vacuum flasks• 2-liter pop bottle • fire extinguisher bottles• soda-syrup cylinder • acetylene cylinders• medical oxygen cylinder • dive bottles• Freon and helium cylinders • baby bottles• ketchup dispensers

The purpose of the generator is to produce HCl gas at sufficient pressure to bubble through the meth-containing solvent to produce meth chloride. Since most cookers do not calculate stoichiometric ratios, HCl containers may or may not be pressurized. In addition, HCl is corrosive to metals and will compromise the structural integrity of both the container and the valve. Figure 11 shows a tank used for HCl generation with a corroded brass valve. While the pressure in the containers rarely rises above 60 psi (Kummerlowe 1998), they should be handled and transported with the expectation that the contents could be released at any time.

6.0CleanupCleanup activities are those necessary to make a structure or vehicle safe for reuse, or in the case of outdoor areas, environmentally safe. The conduct of a cleanup action is generally governed by the state and/or local health department, though occasionally meth cleanup activities are governed by the state environmental protection agency. In some cases, cleanup activities must be governed by a state’s environmental protection agency, depending on where the environmental damage occurs and the media impacted. Approaches and standards of cleanup vary widely among the responsible government authorities. Typical cleanup costs for a 1,500 square foot rambler range from $5,000 to $15,000 (Committee on Science 2005) but can be much higher. The actual cost to an owner of a structure will depend upon how long the lab operated (and hence how dirty it is), the extent of damage to plumbing and appliances, and whether a cleanup standard must be met. For example, if one cook is done in a bedroom with no carpet, the cost to clean up is basically wiping the hard surfaces down and laundering the bedding, plus confirmation testing costs, if testing is required. Costs will escalate depending on the type of work required. For example:

Figure11.HCI Generator (Source: Kummerlowe 1998)Figure11.HCI Generator (Source: Kummerlowe 1998)

40

• All the walls in the house and ductwork require cleaning.

• Some or all of the sinks, bathtubs, and toilets need replacing.

• Some or all of the kitchen appliances, cabinets, countertops, and drywall need replacing.

• Regulations require all furniture and textiles (carpeting, draperies, bedding, clothing) to be discarded or proved by testing to be non-contaminated.

• A statistically designed sampling and analysis program is required to show cleanup standards have been met.

In some jurisdictions, most if not all of the work can be done by the property owner, whereas in others, hazardous materials contractors are required. An example of the extreme end of costs is a property in California where meth was produced utilizing a mercuric chloride method. The mercury permeated the entire structure, and despite vigorous cleanup efforts, the entire building had to be razed and disposed of at a cost of $100,000 (Dicum 2006).

6.1 Cleanup Levels

Currently, no scientific data on the effects of chronic exposure to low levels of meth are available, and hence the cleanup concentration for meth is not generally health based.

There are several approaches to meth lab remediation standards for structures and personal property. One sets a cleanup level for meth alone, with the assumption that if it is met then any other contaminants associated with the lab will also be adequately addressed. Another approach sets a cleanup level for meth and includes other chemicals or classes of chemicals, such as VOCs. A third assumes the cleanup method as outlined will work and sets no cleanup level. This last approach may or may not require confirmation sampling. None of the approaches requires full-suite analyses of all potential contaminants used in meth production. Table 3 provides a sampling of the approaches taken by various states.

41

Table3. Cleanup of Methamphetamine Labs.

State MethamphetamineLevel

VOClevel

Mercury Lead PrelimSamplingRequired

Confirm SamplingRequired

ProfessionalContractorRequired

Source

AK 0.5 µg/ft2 1 ppm 50 ng/m3

2 µg /100 cm2 No Yes No

Alaska 2004

AR1 0.5 µg/ft2 None None None No No No ADH 2005

CA2 0.1 µg/100 cm2 None 50 µg/m340 µg/ft2 Yes3 Yes Yes

SCEMD 2003

CO4 0.5 µg/100 cm2 None 1.0 µg/m340 µg/ft2 Yes3 Yes Yes

CDPHE 2005a

IA None None None None No No NoIowa Undated

IL None None None None No No NoIllinois Undated

KS None None None None No No NoKansas Undated

MI5 0.5 µg/100 cm2 None None None No No NoMichigan Undated

MN6 <10 µg/ft2 <1 ppm

<0.3 µg/m3

40 µg/ft2 Yes3 Yes7 Yes MDH 2006

MO None None None None No No NoMissouri Undated

MT 0.1 µg/100 cm2 None 50 µg/m3

40 µg/ft2 Yes3 Yes Yes

Montana 2006

NC None None None None No No NoN. Carolina 2005

ND None None None None No No NoNDDH 2005

SD 0.1 µg/100 cm2 None None None No No NoS. Dakota Undated

TN 0.1 µg/100 cm21 ppm (total) 50 ng/m3

40 µg/ft2 No Yes YesTDEC 2005

WA ≤0.1µg/100 cm21 ppm (total) 50 ng/m3

20 µg/ft2 Yes Yes Yes

WSDH 2005b

WI None None None None No No NoWDPH 2003

WY None None None None No No NoWyoming Undated

1 State cannot compel cleanup of interiors of privately owned properties (Arkansas Department of Health 2005).

2 Criteria of Sacramento County.3 Not required if owner presumes area is contaminated.4 Colorado also has a cleanup level for iodine of 22 µg/100 cm2 5 Suggested, not required.6 Many Minnesota locales have their own ordinances concerning meth cleanup.7 Under a prescribed cleanup regime, post-sampling is not required.

42

6.2 Cleanup Guidance and Requirements for StructuresThere are no national guidelines or requirements for the cleanup of meth labs, and as suggested above, the state and local requirements, when present, range from a list of suggestions with no reporting mechanism or cleanup concentration values to a list of requirements with government pre- and post-approval reporting points, confirmation sampling, and analysis to show specific cleanup values have been met. Without endorsing either cleanup program, the approaches followed in the state of Missouri and in Sacramento County, California are presented below as representative examples of non-prescriptive and prescriptive programs, respectively.

The Missouri guidance on meth lab cleanup (MDHSS 2000) suggests the property owner take the following steps to prepare the structure for reoccupancy.

1. Airing out property. Doors and windows should be opened and exhaust fans placed in them for several days. It may be appropriate to close the doors and windows for a time and heat the building to approximately 90o F to facilitate volatilization of VOCs.

2. Contamination removal and disposal. Items that are visibly contaminated/stained should be removed from the property and may be disposed of in a local landfill. Absorbent materials, such as carpeting, drapes, clothing, should also be disposed of properly, especially if an odor or stain is present. These are suggestions, not requirements.

3. Surfaces. Surfaces such as walls, counters, floors, ceilings, are porous and require cleaning using normal household cleaning methods and products. Wearing gloves, long sleeves and eye protection is recommended. If a surface has visible contamination or staining (Figure 12), complete removal and replacement of that surface section is recommended. If this is not possible, intensive cleaning followed by the application of a physical barrier, such as an oil paint or epoxy, is recommended.

4. Ventilation system. If a ventilation system is present, replace all of the air filters, remove and clean vents, clean the surfaces near system inlets and outlets, and clean the system’s ductwork.

5. Plumbing. Much of the waste produced by a lab is poured into drains or toilets. If the drain system is giving off an odor that doesn’t go away with flushing, the property owner should hire a plumbing contractor. If the house has a septic tank or the owner suspects outside dumping, contact with the local health department is suggested.

6. Repainting. Painting of cleaned surfaces is suggested as a good contact barrier if cleaning did not completely remove the contamination. Note that water based paint does not generally form a barrier.

Figure12.Iodine Stained Wall (Source: Niswonger 2003)

Figure12.Iodine Stained Wall (Source: Niswonger 2003)

43

Sacramento County, California, provides an example of a highly prescribed procedure (SCEMD 2003). In Sacramento County, a meth lab property suspected to be contaminated is found “unfit for occupancy,” and its cleanup must be formally approved by the county before the label is lifted. The preparation of reports and cleanup must be done by a certified industrial hygienist or a registered professional engineer with demonstrated experience in environmental remediation. The county may grant an exemption that allows the owner to perform the remediation activities as specified in the county guidance if meth was the only drug manufactured at the site, the method was red phosphorus, there was no manufacturing-related fire, and there is no visual or apparent evidence of manufacturing.

In a multi-unit building, such as a hotel or apartment complex, the unit involved may be the sole unit blocked from occupancy, or nearby units may be included in the ban, depending upon the professional judgment of the county.

The owner’s consultant shall gather site information and conduct a site walk-through. The purpose of this walk-through and information gathering is to provide the basis for preparing a preliminary site assessment (PSA) work plan. Before work can begin, the county must approve the work plan. The work plan includes:

• Summary of information from law enforcement and other government entities that includes duration of lab operation, methods and chemicals used, location of cooking and storage areas, and potential disposal methods.

• A description of areas to be sampled and the basis for the selection or the rationale for not sampling.

• Sampling and analysis protocols, including labs to be used and their qualifications. Wipe sampling is the preferred method for taking the samples, and up to four samples may be composited.

• A description of areas and items that will be remediated in lieu of sampling (e.g., removed and properly disposed of).

• Estimated time of PSA results and report to agency.

The PSA report forms the basis for the cleanup. In it, the consultant must specifically describe how each item will be decontaminated (e.g., double-wash the wall outside the kitchen with a detergent from floor to ceiling, or remove and dispose of refrigerator in basement). From the PSA recommendations, a remediation work plan is drawn up. The remediation work plan contains a timeline; site map; PSA summary; plan for post-remediation assessment, including sampling and analysis protocols; remediation procedures; and a waste disposal plan. The remediation work plan must be approved by the county before work can begin.

44

The guidance briefly addresses a number of cleanup methods and their applicability.

• Venting. Airing-out may be a valid way to reduce exposure to the remediation crew, but it is not a valid part of the remediation process. Long-term volatile organic vapor concentrations will only decline when their sources are removed.

• Air monitoring. Except for potential occupational exposures for the remediation crew, air monitoring, especially by total instruments such as photo ionization detectors (PIDs) and flame ionization detectors (FIDs), is too gross to provide risk information for a home environment. The instrumentation and collection techniques to provide speciation of the air contaminants are very expensive; with source removal, the volatile organic concentrations should go to background relatively quickly.

• Removal. The county requires etched or stained sinks, bathtubs, toilets, and similar fixtures to be removed and properly disposed of. While not requiring the disposal of porous materials, such as carpeting, suspended ceiling panels, wallpaper, clothing, and furniture, proof is required that the items are not contaminated. Often the cleaning and testing process will cost more than the replacement cost of the item. Appliances that were in the room where cooking was conducted must be disposed of. Floors, countertops, tiles, walls, and ceilings that show visible staining should be replaced.

• Surface washing. Washing takes many forms, such as pressure washing, detergent washing, solvent (alcohol) washing, and steam cleaning. Whichever method is chosen must get the surface clean to a wipe test, and the wash solutions and rinsate must be properly disposed of.

• Encapsulation. In cases where porous or semi-porous surfaces (e.g., walls, wood flooring, panels, ceiling, concrete) have had levels of contamination that permitted in situ cleaning, such surfaces will be encapsulated with an oil-based paint, varnish, or similar sealant. After drying, wipe sampling is required to prove lack of contamination. Water-based paints are porous and should not be used.

• Ventilation system. The ventilation system, when present, should have all filters replaced, registers removed and cleaned, and surfaces near inlets and outlets cleaned. The county recommends that consideration be given to cleaning system ductwork, but says the efficacy of duct cleaning is subject to debate.

Landfills in California, as elsewhere, are licensed to receive different types of wastes. Meth lab debris and appliances are not generally considered hazardous wastes, but the landfill must agree to take the materials. An assumption that the landfill will accept the wastes is not warranted. The disposal plan must list the landfill in which the material is proposed for disposal. The county expects an inventory of the materials disposed of and a receipt from the landfill verifying that everything on the inventory was accepted. Wastewater generated during the cleanup may be accepted by the local publicly owned treatment works (POTW); however, permission to dispose of it must be obtained first, and documentation of the permission is required. If POTW disposal is not an option, then landfill disposal will need to be arranged.

45

A final remediation report is required by the county. If the only remediation that took place was replacing potentially contaminated items (wallboard, cabinets, countertops, and appliances) then the consultant should provide written, detailed documentation that the remediation was carried out according to the approved work plan. If cleaning operations were carried out, the final report must provide, in addition to a description of any cleanup actions, an explanation of the sampling and analysis process and the results to show that final contaminant levels meet the reoccupancy concentration criteria. The county must approve the final report before the building can be reoccupied.

6.3 Cleanup of Septic Systems

For each pound of meth produced, approximately five to six pounds of waste is generated (U.S. DOJ 1993). The most convenient and least conspicuous method for a cooker to dispose of this waste is to pour it down the drain or flush it down the toilet. Depending upon the method used to make the meth, this waste may be corrosive (base or acid), may contain solvents and/or reactive metals, and may have the potential to generate phosphine gas. The presence of pitting on metal drain parts and ceramics, as well as staining (iodine), are good indications that hazardous wastes were disposed of. If the structure is on a city sewer system, then cleanup will consist of ensuring that nothing hazardous remains in the piping. This is usually accomplished by thorough flushing; however, in instances where the drains emit persistent odors, it might be necessary to have the cleanup contractor address the issue.

The presence of a septic system where there is evidence of disposal may, depending upon the state and locale, trigger an environmental investigation. Generally this involves sampling the septic tank contents and ensuring that the sample(s) are representative. Note that most solvents used in meth production are hydrophobic (form nonaqueous phase liquids) that either float on water or sink to the bottom of the tank. The Colorado Regulations Pertaining to the Cleanup of Methamphetamine Laboratories (CDPHE 2005a) provide a detailed description for septic system sampling. The regulations recommend first screening the tank for total VOCs and pH. If the screening indicates the potential for a problem or the lab has been operating for a long time, a sample taken at the outlet end of the tank should be taken with a drum thief, coliwasa tube, or similar sampling device. The sample should extend from the top of the liquid to the bottom of the tank. The regulations state that meth wastes in septic tanks typically are not considered RCRA-listed hazardous wastes (U, P, F) because the solvents have been used and there is too much uncertainty about the type, sources, and original concentrations of the solvents discovered in septic tanks.

The sample should be tested to determine if it is a characteristic hazardous waste. The tests required for this are:

• VOCs using Method 8260B in "Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods," EPA Publication SW-846.

• Ignitability/flash point by a Pensky-Martens Closed Cup Tester, using the test method specified in ASTM Standard D-93-79 or D-93-80 (or Method 1010 in EPA

46

SW-846), or Setaflash Closed Cup Tester, using the test method specified in ASTM standard D-3278-78 (or Method 1020A in EPA SW-846).

• Corrosivity as determined by the pH electrometeric measurement Method 9040 in EPA SW-846, or by corrosivity toward steel using Method 1110 in SW-846.

• Reactivity using Method 9014/9034 in EPA SW-846.

If the sample tests indicate the septic tank contents contain a characteristic toxic chemical or are otherwise a characteristic waste, the tank will need to be pumped and the contents disposed of as a hazardous waste. The presence of nonaqueous phase liquids may also require cleanup, whether they are on the RCRA toxicity characteristic list or not. Colorado regulations require septic waste that contains meth lab wastes to be pumped and disposed of in an appropriate solid waste landfill.

Because a septic tank is basically a liquid redistribution system, the presence of organic solvents or heavy metals (e.g., mercury, lead) in the effluent may require further environmental investigation to determine the nature and extent of the contamination in the subsurface. These chemicals, in dissolved form, are capable of migrating to groundwater and/or to surface water, if present.

6.4 On-Site Dumping and Open-Air Labs

On-site dumping and wastes left at open-air sites (Figure 13) are generally covered by a state’s environmental program and may fall under its voluntary cleanup program. Some states may require the outside cleanup to be performed by a licensed professional geologist or engineer.

A meth lab will generally produce two types of waste streams. The first is composed of the sludges and spent chemicals from making the meth. As discussed above, these are typically flushed because they represent a handling hazard; however, on occasion they are disposed of outside by either dumping on the ground or burning in a burn pit or 55-gallon barrel. The second waste stream consists primarily of containers—cartons for cold pills, glass and plastic bottles for chemicals, and sometimes old propane or other pressure tanks for anhydrous ammonia or hydrogen chloride generation. If the cooker had access to a burn pit, that is a likely disposal option for the plastic containers and paper cartons.

The open-air lab presents a cleanup problem similar to on-site dumping. The lab equipment and chemicals are, for the most part, taken during the law enforcement

Figure13. Open Dumping of Meth Wastes (Source: King County Washington)

47

and removal actions, leaving soils potentially contaminated by spills and cooking wastes. The approach to sampling to determine if a hazard exists is the same as that for any conventional hazardous substances release. While a systematic approach, such as gridding the property or suspect area and conducting random sampling, can be employed, it will probably be more cost effective and equally as successful to use a judgmental approach. In the judgmental approach, the site is searched for stained, bare soil or dead vegetation, and any area displaying these qualities is screened for pH and VOCs. A soil sample can be placed in a plastic bag, allowed to heat slightly, and the headspace measured using an FID. The sample can be taken with a hand auger or trowel. This method allows the surficial extent of the waste to be determined. Positive results in the first six inches should be followed up with deeper samples. The most contaminated soil should be bottled and sent to an off-site laboratory for analysis. U.S. EPA (2000) provides a standard operating procedure for taking soil samples at hazardous waste sites. At some point, it may become necessary to bring equipment, such as a direct push rig, on site to continue the sampling at depth. Depending upon the state and locale, the regulatory county may require a formal sampling and analysis plan and may want the groundwater (if shallow) to be sampled. Shallow, corrosive-only areas can be remediated in place using baking soda or vinegar; however, the regulatory agency may require that a sample of the soil in the contaminated area be tested for metals (e.g., lead, mercury).

6.5 Cleanup and Property Values

A large body of literature that goes beyond the scope of this paper is available on the effects that hazardous waste on or near a property has on its value and the various ways of calculating it (Meyer and Reaves 1998 and Kilpatrick and Mundy 2003). Stigma is usually represented as the difference in price (the perceived worth) of an impaired property versus that of an unimpaired property. Impaired in this case means there is a public perception that a cleanup is incomplete and hazardous levels of chemicals remain on the property, or that a property, while not contaminated itself, is close enough to a contaminated one to be affected by it.

A potential buyer of a home or rental property with former meth lab operations generally focuses on whether the cleanup procedure truly cleaned the property, especially in a jurisdiction where confirmation sampling is not required. If the property is not clean, the owner may incur costs to remediate beyond work previously performed to achieve a sale. The concept of clean is also problematic because of the lack of health-based standards for chronic exposure to meth residues. Perception is another issue. Should a potential buyer invest in a neighborhood that has had a meth lab? Is it a neighborhood that supports such activity, and will this cause a depreciation of value?

On a nationwide basis, this is a relatively complex issue because the impact on both the property containing the lab and its neighbors depends primarily on a given state’s laws and, to some extent, the socioeconomic class of the neighborhood. As is discussed in greater detail in the section on state regulations, cleanups may be voluntary or they may

48

be required and approved by the state. There is also the issue of listing and disclosure laws, which range from no listing or disclosure to a requirement that the owner must always disclose to potential buyers or renters that the property was formerly a meth lab. Buyer or renter views of the risks associated with meth production will also affect whether or not the former presence of a lab presents a stigma.

An issue may arise in areas where the authorities rule that a property is unfit for use until it is cleaned up, but cannot compel cleanup. This situation sometimes results in the abandonment of the property. Abandoned properties will deter potential buyers and depress the values of surrounding properties.

7.0ReferencesAdvisory Council on the Misuse of Drugs (ACMD). 2005. Methylamphetamine Review. 93 pp. http://www.drugs.gov.uk/publication-search/acmd/ACMD-meth-report-November-2005?view=Binary

Alaska. 2004. ‚Fit for Use‘ Standards for Sites Associated with Clandestine Drug Labs. Department of Environmental Conservation. http://www.dec.state.ak.us/spar/perp/docs/methlab_rpt.pdf

Alberta Municipal Affairs. 2004. Clandestine Drug Operations Awareness and Safety. http://www.municipalaffairs.gov.ab.ca/fco/pdf/AB-clan6-1.pdf

Allen, A. and T. Cantrell. 1989. Synthetic reductions in clandestine amphetamine and methamphetamine laboratories - a review. Forensic Science International 42:183-199. http://www.erowid.org/archive/rhodium/chemistry/amphetamine.reduction.html

Arkansas Department of Health (ADH). 2005. Clandestine Methamphetamine Laboratory Cleanup Guidelines. State of Arkansas, 13 pp. http://www.healthyarkansas.com/pdf/adh_methguidelines_2005.pdf

Association of State and Territorial Health Organizations (ASTHO). 2005. Cleaning-up Clandestine Methamphetamine Labs: the Role of State Public Health Agencies. http://www.astho.org/pubs/MethLabsClean-up2005.pdf

Bureau of Indian Affairs (BIA). 2005. Bureau of Indian Affairs Performance and Accountability Report, Fiscal Year 2005. Department of Interior, 181 pp. http://www.doi.gov/bureau-indian-affairs.html

Bureau of Justice Statistics. 2003. Tribal Law Enforcement, 2000, NCJ 197936. Office of Justice Programs, U.S. Department of Justice, 4 pp. http://www.ojp.gov/bjs/pub/pdf/tle00.pdf

49

Burgess, J. 1997. Methamphetamine labs: community risks and public health responses. Washington Public Health 15:Fall. http://www.health.state.mn.us/divs/eh/meth/lab/jburgess.pdf

Burgess, J. 1999. Hospital evacuations due to hazardous materials incidents. American Journal of Emergency Medicine 17(1):50-52. http://www.publichealth.arizona.edu/divisions/environ_com_hlth/popups/meth_lit_review.htm

Burgess, J. 2001. Phosphine exposure from a methamphetamine laboratory invesigation. Journal of Toxicology and Clinical Toxicology 39(2):165-168. http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&dopt=Citation&list_uids=11407503

Burgess, J., et al. 2002. Medical surveillance of clandestine drug lab investigators. Journal of Occupational and Environmental Medicine 44(2):184-189. http://www.joem.org

California Department of Toxic Substances Control (CDTSC). 2004. Summary of the 2002-2003 Clandestine Drug Laboratory Remediation Survey. 33 pp. http://www.dtsc.ca.gov/SiteCleanup/ERP/upload/SMBRP_DRUGLAB_SURVEYSUMMARY.pdf

California Department of Toxic Substances Control (CDTSC). Undated. Clandestine Drug Lab Removals website. State of California. http://www.dtsc.ca.gov/SiteCleanup/ERP/Drug_Lab_Removal.cfm

Centers for Disease Control and Prevention (CDC). 2000. Public Consequences Among First Responders to Emergency Events Associated with Illicit Methamphetamine Laboratories: Selected States, 1996-1999. U.S. Department of Health and Human Services, 7 pp. http://www.cdc.gov/mmwr/preview/mmwrhtml/mm4945a1.htm

Centers for Disease Control and Prevention (CDC). 2005. Acute Public Health Consequences of Methamphetamine Laboratories: 16 States, January 2000-June 2004. U.S. Department of Health and Human Services, 8 pp. http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5414a3.htm

Centers for Disease Control and Prevention (CDC). 2006. Centers for Disease Control and Prevention website. U.S. Department of Health and Human Services. http://www2a.cdc.gov/phlp/Methlab.asp

Cecil, J. 2006. Methamphetamine & Kids. Victims Assistance Conference, March 21-23 2006, Marriott’s Griffin Gate Resort, Lexington, Kentucky. http://ag.ky.gov/NR/rdonlyres/C3E29486-F999-4399-B792-29960E6364A4/0/VI_D__Meth_and_Kids__Cecil.ppt#2

50

Chesley, M. 1999. Methamphetamines: An Epidemic of Clandestine Labs and Health Risk. Howard University Hospital, Washington, DC, 22 pp. http://www.health.state.mn.us/divs/eh/meth/lab/mchesley.pdf

Colorado Department of Public Health and Environment (CDPHE). 2005a. 6 CCR 1014-3, State Board of Health Regulations, Pertaining to the Cleanup of Methamphetamine Laboratories. Department of Public Health and Environment, 36 pp. http://www.cdphe.state.co.us/op/regs/boardofhealth/101403methlabrules.pdf

Colorado Department of Public Health and Environment (CDPHE). 2005b. Questions and Answers Regarding the Meth Lab Cleanup Regulations. Department of Public Health and Environment, 6 pp. http://www.cdphe.state.co.us/hm/methlabregqanda.pdf

Committee on Science. 2005. Hearing: H.R. 798, Methamphetamine Remediation Research Act of 2005. U.S. House of Representatives, 107 pp. http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_house_hearings&docid=f:99573.pdf

CPH. Undated. Recommendations of Work Practices to Maintain Officer Safety. Mel and Enid Zuckerman College of Public Health, University of Arizona, 54 pp. http://www.publichealth.arizona.edu/divisions/environ_com_hlth/pdf/phase_iii_final-officer_safety.pdf

Dicum, G. 2006. Crystal mess: illegal drug labs contaminate living spaces with toxic waste. San Francisco Chronicle, 22 February. http://www.sfgate.com/cgi-bin/article.cgi?file=/gate/archive/2006/02/22/gree.DTL

Doyle, R. 2006. The crystal crisis. Scientific American, August, p 28.

Drug Reform Coordination Network. 2005. Following Oklahoma’s lead, states target cold remedies in fight against methamphetamine. Drug War Chronicle, 371:21 January. http://stopthedrugwar.org/chronicle/371/sudafed.shtml

Drug Enforcement Administration (DEA). 2005a. Drugs of Abuse, 2005 Edition. U.S. Department of Justice. http://www.dea.gov/pubs/abuse/index.htm

Drug Enforcement Administration (DEA). 2005b. Guidelines for Law Enforcement for the Cleanup of Clandestine Drug Laboratories. Department of Justice, 122 pp. http://www.dea.gov/resources/redbook.html

Drug Enforcement Administration (DEA). 2006a. General Information Regarding the Combat Methamphetamine Epidemic Act of 2005 [Title VII of Public Law 109-177]. http://www.deadiversion.usdoj.gov/meth/cma2005.htm

Drug Enforcement Administration (DEA). 2006b. Methodology Used in Developing Preliminary Estimates of Ephedrine and Pseudoephedrine 2005 Legitimate Use, 78 pp. http://www.deadiversion.usdoj.gov/fed_regs/notices/2006/DEA_IMS_study_062606.pdf

51

Drug Enforcement Administration (DEA). 2006c. NEWS RELEASE: DEA Issues Regulations to Implement the Combat Methamphetamine Epidemic Act of 2005. http://wwww.deadiversion.usdoj.gov/meth/pressrel.htm

Drug Enforcement Administration (DEA). Undated. Drug Trafficking in the United States: Methamphetamine. Briefs & Background. http://www.usdoj.gov/dea/concern/drug_trafficking.html

Edwards, G. 2006. Statement of Gary L. Edwards, Chief Executive Officer, National Native American Law Enforcement Association, Before the Senate Committee on Indian Affairs, Regarding the Problem of Methamphetamine in Indian Country (April 5, 2006). http://www.ncai.org/ncai/Edwards040506.pdf

Ferguson, T. 2000. Overview of Medical Toxicology and Potential for Exposures to Clandestine Drug Laboratories in California. University of California Davis, 4 pp. http://www.health.state.mn.us/divs/eh/meth/lab/tferguson.pdf

Fleming, S. 2005. The meth effects. American City & County, 120(1):42-45. http://www.americancityandcounty.com/mag/government_meth_effects/index.html

Forest Service (FS). Undated. Forest Service Drug Control Program. Department of Agriculture, Forest Service. http://www.fs.fed.us/lei/drug%20control_words.html

GMDC Educational Foundation (GMDC). 2005. The Methamphetamine Issue: Addressing Its Challenges. White paper, 5 pp. http://www.gmdc.org/Edu/GMDC_METHAMPHETAMINE_f.pdf

Goddard, T. 2006. 2006 Meth Fact Sheet. Arizona Office of the Attorney General. http://www.azag.gov/StopMeth/MethFactSheet-Leg.pdf

Guevara, R.E. 2003. Statement of Rogelio E. Guevara, Chief of Operations, Drug Enforcement Administration, Before the House Committee on Government Reform, Subcommittee on Criminal Justice, Drug Policy and Human Resources, ‘”Facing the Methamphetamine Problem in America,” (July 18, 2003). http://www.usdoj.gov/dea/pubs/cngrtest/ct071803.htm

Hargreaves, G. 2000. Clandestine drug labs: chemical time bombs. FBI Law Enforcement Bulletin 69(4):1-6. http://www.popcenter.org/problems/Supplemental_Material/drug_labs/Hargreaves_2000.pdf

Harris, B. 2001. Risky Business Managing Methamphetamine Cleanups. Missouri Department of Natural Resources, 5 pp. http://www.dnr.mo.gov/magazine/2001_spring/Risky_Business_Feature.htm

52

Hetzel, F.R. 2005. Law enforcement’s response to the spread of methamphetamine use. Popular Government. Fall:31-35.

Hunt, D., S. Kuck, and L. Truitt. 2006. Methamphetamine Use: Lessons Learned. U.S. Department of Justice, National Criminal Justice Reference Service, Document No. 209730, 74 pp. http://www.ncjrs.gov/pdffiles1/nij/grants/209730.pdf

Indian Health Service (IHS). 2006. Indian Health Service Fact Sheet. http://www.ihs.gov/PublicInfo/PublicAffairs/Welcome_Info/ThisFacts.asp

Illinois. Undated. Environmental Health Fact Sheet: Guidelines for Cleaning Up Former Methamphetamine Labs. Department of Public Health. http://www.idph.state.il.us/envhealth/factsheets/meth-cleanup.htm

Illinois State Police. 2004. Investigation and Closure of Clandestine Laboratories. http://www.isp.state.il.us/crime/methcleanup.cfm

International Association of Fire Fighters (IAFF). 1996. Training for Hazardous Materials Response: Clandestine Drug Operations: Student Text. 86 pp. http://www.iaff.org/academy/pdfs/CDO%20ST.pdf

Iowa. Undated. Guidelines for Cleaning up Former Methamphetamine Labs. Department of Public Health. http://www.idph.state.ia.us/eh/common/pdf/hseess/meth_lab_cleanup.pdf

Joint Federal Task Force. 1990. Guidelines for the Cleanup of Clandestine Drug Laboratories, EPA 540-P-90-005. U.S. Drug Enforcement Agency, Environmental Protection Agency, and Coast Guard. 52 pp. http://nepis.epa.gov/pubtitleOSWER.htm

Kaley, K.B. and C. Salocks. 2003a. Ammonia. Clandestine Drug Labs/ Methamphetamine 1(1). State of California, Office of Environmental Health Hazard. http://www.oehha.ca.gov/public_info/clanlabs.html

Kaley, K.B. and C. Salocks. 2003b. Phosphine. Clandestine Drug Labs/ Methamphetamine 1(5). State of California, Office of Environmental Health Hazard. http://www.oehha.ca.gov/public_info/clanlabs.html

Kansas. Undated. Cleaning Up Former Methamphetamine Labs. Kansas Department of Health and Environment. http://www.kdheks.gov/methlabs/ml_cleanup.html

53

KCI. 2006. State and Legislative Laws about Selling Houses and Homes used for Cooking Methamphetamine. KCI: The Anti-Meth Site. 2006. http://www.kci.org/meth_info/meth_labs/state_laws.htm

Kilpatrick, J. and B. Mundy. 2003. Appraisal of contaminated property in the United States. Journal of the Japan Real Estate Institute 306:25-32. http://www.mundyassoc.com/publications/appconprop.pdf

Manning, T. 1999. Drug labs and endangered children. FBI Law Enforcement Bulletin 68(7):10-14. http://www.fbi.gov/publications/leb/1999/jul99leb.pdf

Martyny, J. et al. 2004a. Chemical Exposures Associated with Clandestine Methamphetamine Laboratories. National Jewish Medical and Research Center, 44 pp. http://www.njc.org/pdf/Chemical_Exposures.pdf

Martyny, J. et al. 2004b. Chemical Exposures Associated with Clandestine Methamphetamine Laboratories Using the Anhydrous Ammonia Method of Production. National Jewish Medical and Research Center, 27 pp. http://www.njc.org/pdf/Ammonia%20Meth.pdf

Martyny, J. et al. 2004c. Methamphetamine Contamination on Environmental Surfaces Caused by Simulated Smoking of Methamphetamine. National Jewish Medical and Research Center, 16 pp. http://www.njc.org/pdf/Meth%20smoking%20experiment.pdf

Martyny, J. et al. 2005a. A 24-Hour Study to Investigate Chemical Exposures Associated with Clandestine Methamphetamine Laboratories. National Jewish Medical and Research Center, 16 pp. http://www.njc.org/pdf/Meth-24hour-study.pdf

Martyny, J. et al. 2005b. Chemical Exposures Associated with Clandestine Methamphetamine Laboratories Using the Hypophosphorous and Phosphorous Flake Method of Production. National Jewish Medical and Research Center, 20 pp. http://www.njc.org/pdf/meth-hypo-cook.pdf

McSwain, R. 2006. Statement of Robert McSwain, Deputy Director, Indian Health Service, Before the Senate Committee on Indian Affairs Oversight: Hearing on the Problem of Methamphetamine in Indian Country, April 5, 2006. Department Of Health and Human Services, Indian Health Services, 9 pp. http://www.ncai.org/ncai/McSwain040506.pdf

Meyer, P. and C. Reaves. 1998. Accounting for Stigma on Contaminated Lands. University of Louisville, Center for Environmental Policy and Management, 18 pp. http://cepm.louisville.edu/Pubs_WPapers/PDF_Docs/stigma.pdf

54

Michigan. Undated. Resources for Cleanup of Methamphetamine. Department of Environmental Quality. http://www.michigan.gov/documents/Resources_for_Cleanup_of_Methamphetamine_132443_7.pdf

Miller, M. 2002. Meth lab explosion becomes murder case after victim dies. The Daily Ardmoreite. July 18. http://www.mapinc.org/drugnews/v02/n1349/a04.html?201

Minnesota Department of Health (MDH). 2005. Methamphetamine and Meth Labs: On-Scene Safety for Emergency Responders. State of Minnesota. http://www.health.state.mn.us/divs/eh/meth/lab/frsafety.html

Minnesota Department of Health (MDH). 2006. Clandestine Drug Lab General Cleanup Guidance. State of Minnesota, 46 pp. http://www.health.state.mn.us/divs/eh/meth/lab/guidance0106.pdf

Missouri Department of Health and Senior Services (MDHSS). 2000. Guidelines for Cleaning up Former Methamphetamine Labs. 8 pp. http://www.dhss.mo.gov/TopicsA-Z/MethLabCleanupGuidelines.pdf

Missouri Department of Health and Senior Services (MDHSS). Undated. Guidelines for Cleaning Up Former Methamphetamine Labs. http://www.dhss.mo.gov/TopicsA-Z/MethLabCleanupGuidelines.pdf

Missouri Department of Natural Resources (MDNR). 2006. Methamphetamine/Special Projects. http://www.dnr.mo.gov/env/esp/meth-special-projects.htm

Mitchell, M. and M. Shaffrey. 2006. Emergency rooms feeling pain of meth, studies find: hospitals reporting increase in cases related to drug. Winston-Salem Journal. 19 January. http://www.mapinc.org/drugnews/v06/n091/a05.html

Montana. 2006. Methamphetamine Program, Draft Cleanup Rules. Authority 75-10-1304, Montana Code Annotated. http://deq.mt.gov/Meth/DraftMethFinal.pdf

Multijurisdictional Counterdrug Task Force Training Program (MCTFT). 2006. Mission Statement. Multijurisdictional Counterdrug Task Force Training Program. http://www.mctft.com/

National Alliance for Model State Drug Laws. 2006a. Scheduling and Regulation of Ephedrine and Pseudoephedrine: 2006 Legislative Chart. May 24. http://www.natlalliance.org/pdfs/Legislative%20Chart%20May%2024.pdf

National Alliance for Model State Drug Laws. 2006b. Restrictions on Over-the-Counter Sales/Purchases of Products Containing Pseudoephedrine. March 8, 2006. http://www.natlalliance.org/pdfs/pseudo042606.pdf

55

National Alliance for Model State Drug Laws. 2006c. Highlights. April 26, 2006. http://natlalliance.org/publications.asp

National Alliance for Model State Drug Laws. 2006d. Tracking Sales of Ephedrine and Pseudoephedrine Products Bill Status Update. April 2006. http://www.natlalliance.org/pdfs/April%202006%20BSR.pdf

National Alliance for Model State Drug Laws. 2006e. State Anhydrous Ammonia Bill Status Update. April 20, 2006. http://www.natlalliance.org/Anhydrous%20Ammonia%20Bill%20Status%20Update%204.20.pdf

National Alliance for Model State Drug Laws. 2006f. State Child Endangerment Bill Status Update. April 24, 2006. http://www.natlalliance.org/pdfs/DEC%20Bill%20Satus%20April24.06.pdf

National Alliance for Model State Drug Laws. 2006g. State Controlled Substance(s) Environmental Bill Status Update. April 26, 2006. http://www/natlalliance.org/Environmental%20Bill%20Status%20Update%20Apr06.pdf

National Association of Counties (NACo). 2005. The Meth Epidemic in America: Two Surveys of U.S. Counties. http://www.naco.org/Content/ContentGroups/Publications1/Press_Releases/Documents/NACo-MethSurvey.pdf

National Drug Intelligence Center (NDIC). 2002. Information Bulletin: Children at Risk. U.S. Department of Justice, Document 2002-L0424-001. http://www.usdoj.gov/ndic/pubs1/1466/index.htm

National Drug Intelligence Center (NDIC). 2004. National Drug Threat Assessment 2004. Department of Justice. http://www.usdoj.gov/ndic/pubs8/8731/meth.htm

National Drug Intelligence Center (NDIC). 2005. Marijuana and Methamphetamine Trafficking on Federal Lands Threat Assessment. U.S. Department of Justice, Document 2005-Q0317-007. http://www.usdoj.gov/ndic/pubs10/10402/index.htm

National Drug Intelligence Center (NDIC). 2006a. Mission Statement. http://www.usdoj.gov/ndic/

National Drug Intelligence Center (NDIC). 2006b. National Drug Threat Assessment 2006. Department of Justice, Document 2006-Q0317-001, 57 pp. http://www.usdoj.gov/ndic/pubs11/18862/index.htm

National Institute on Drug Abuse (NIDA). 2002. Research Report Series: Methamphetamine Abuse and Addition. Department of Health and Human Services, 8 pp. http://www.nida.nih.gov/ResearchReports/Methamph/Methamph.html

56

National Jewish Medical and Research Center. Methamphetamine research articles. http://nationaljewish.org/news/y2005/meth_research_results.aspx

National Tribal Justice Resource Center. Undated. Methamphetamine Tools and Resources. National American Indian Court Judges Association. http://www.ntjrc.org/legal/details.asp?83

Niswonger, K. 2003. Clandestine meth labs. Colorado Rocky Mountain Chapter Solid Waste Association of North America 2003 Annual Meeting, 54 slides. http://www.coloradoswana.org/presentations/2003_Annual_Meeting/Clandestine_Meth_Labs.ppt

North Carolina. 2005. Subchapter 41D – Methamphetamine Decontamination: Section .0100 – Decontamination of Methamphetamine Sites. http://www.epi.state.nc.us/epi/oii/pdf/SubchapterDRules72005.pdf

North Dakota Department of Health (NDDH). 2005. Best Management Practices for Cleanups at Methamphetamine Labs. State of North Dakota, 8 pp. http://www.health.state.nd.us/wm/pdf/05_2WEBDrugLabCleanup.pdf

Occupational Safety & Health Administration (OSHA). 2005. OSHA Best Practices for Hospital-Based First Receivers of Victims from Mass Casualty Incidents Involving the Release of Hazardous Substances. 158 pp. http://www.osha.gov/dts/osta/bestpractices/firstreceivers_hospital.pdf

Occupational Safety & Health Administration (OSHA). 2006. Hazardous Waste Operations and Emergency Response. 29 CFR 1910.120. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765

Office of National Drug Control Policy (ONDCP). 2006a. Office of National Drug Control Policy website. http://www.whitehousedrugpolicy.gov/index.html

Office of National Drug Control Policy (ONDCP). 2006b. Synthetic Drug Control Strategy: A Focus on Methamphetamine and Prescription Drug Abuse. 56 pp. http://www.whitehousedrugpolicy.gov/publications/synthetic_drg_control_strat/

Office of National Drug Control Policy (ONDCP), Department of Justice, and Department of Health and Human Services. 2006. Meth Resources webpage. http://methresources.gov/

Peed, Carl R. 2004. Children in meth labs: risky business. Community Links, November. http://www.nationaldec.org/research%20and%20articles/articles/Meth%20and%20ChildrenByCOPSDirector.pdf

Peterson, D. 2000. Hazardous Materials: Clandestine Drug Labs. http://www.health.state.mn.us/divs/eh/meth/lab/dpeterson.pdf

57

Pyle, G. 2006. Testimony Presented to the House Appropriations Subcommittee for Labor, Health and Human Services, Education and Related Agencies on the FY 2007 Budget for the Department of Health and Human Services (March 29, 2006). http://appropriations.house.gov/_files/GregoryPyleTestimony.pdf

Ragsdale, W. 2006. Testimony of William P. Ragsdale Director, Bureau of Indian Affairs, U.S. Department of The Interior, Before The Committee on Indian Affairs United States Senate Hearing on the Problem of Methamphetamine Use in Indian Country (April 5, 2006). Department of the Interior, Bureau of Indian Affairs, 5 pp. http://www.ncai.org/ncai/Ragsdale040506.pdf

Salocks, C. and K.B. Kaley. 2003. Technical Support Document: Toxicology —Clandestine Drug Labs: Methamphetamine. State of California, Office of Environmental Health Hazard 1(8). http://www.oehha.ca.gov/public_info/pdf/TSD%20Methamphetamine%20Meth%20Labs%2010’8’03.pdf

Salt Lake Valley Health Department (SLVHD). 2001. Regulation #32: Chemically Contaminated Properties, 79 pp. http://www.slvhealth.org/eh/pdf/reg32.pdf

Sanchez, D.R. and B. Harrison. 2004. The Methamphetamine Menace. Legisbrief 12(1). National Council of State Legislatures. http://www.ncsl.org/programs/cj/meth.pdf

Sacramento County Environmental Management Department (SCEMD). 2003. Criteria for the Assessment and Remediation of Clandestine Methamphetamine Laboratories. http://www.emd.co.sacramento.ca.us/Documents/Info/SAC%20-%20Criteria%20for%20Clan%20Lab%20Remediation.pdf

Skinner, H. 1990. Methamphetamine synthesis via hydriodic acid/red phosphorous reduction of ephedrine. Forensic Science International, 48(2):128-134. http://designer-drugs.com/pte/12.162.180.114/dcd/chemistry/meth.hi-rp.html

Snell, M.B. 2001. Welcome to meth country. Sierra Magazine, 86(1):Jan/Feb. http://www.sierraclub.org/sierra/200101/Meth.asp

South Dakota. Undated. Guidelines for Contamination Reduction: Proven Practices for the Cleanup of Clandestine Methamphetamine Laboratories. State of South Dakota, 30 pp. http://www.state.sd.us/denr/DES/WasteMgn/HWaste/MethLabCleanup.pdf

Substance Abuse and Mental Health Services Administration (SAMHSA). 2005. Methamphetamine Use, Abuse, and Dependence: 2002, 2003, and 2004. Office of Applied Studies. http://oas.samhsa.gov/2k5/meth/meth.htm

58

Substance Abuse and Mental Health Services Administration (SAMHSA). 2006. Methamphetamine Use, Abuse, and Dependence: 2002, 2003, 2004, and 2005. Office of Applied Studies. http://www.drugabusestatistics.samhsa.gov/NSDUH/2k5NSDUH/2k5results.htm

Swetlow, K. 2003. Children at Clandestine Methamphetamine Labs: Helping Meth’s Youngest Victims. Department of Justice Office for Victims of Crime, 12 pp. http://www.ojp.usdoj.gov/ovc/publications/bulletins/children/197590.pdf

Tennessee Department of Environment and Conservation (TDEC). 2005. Reasonable, Appropriate, Protective (RAP) Cleanup Response and Documentation Guidance for Properties Quarantined Due to Clandestine Methamphetamine Laboratory (CML) Activities Pursuant to TCA 68-212 Part 5. State of Tennessee, 14 pp. http://tennessee.gov/environment/dor/pdf/Meth_RAP_Guidance.pdf

U.S. Congress. 2001. Small Business Liability Relief and Brownfields Revitalization Act of 2001. http://www.epa.gov/brownfields/pdf/hr2869.pdf

U.S. Department of Justice (U.S. DOJ). 1993. Developing a Strategy for a Multiagency Response to Clandestine Drug Laboratories. Bureau of Justice Assistance, NCJ 142643, 152 pp. http://www.ncjrs.gov/pdffiles/clan.pdf

U.S. Department of Justice (U.S. DOJ). 2006. The Office of Community Oriented Policing Services Methamphetamine Initiative. Office of the Inspector General, Audit Report 06-16, 105 pp. http://www.usdoj.gov/oig/reports/COPS/a0616/final.pdf

U.S. Environmental Protection Agency (U.S. EPA). 1992. CERCLA/Superfund Orientation Manual. Office of Solid Waste and Emergency Response, EPA 542-R-92-005, 177 pp. http://www.epa.gov/superfund/resources/remedy/pdf/542r-92005.pdf

U.S. Environmental Protection Agency (U.S. EPA). 2000a. Establishing Work Zones: Uncontrolled Hazardous Waste Sites & RCRA Corrective Actions. Office of Solid Waste and Emergency Response, EPA 540-F-00-026, 9 pp.

U.S. Environmental Protection Agency (U.S. EPA). 2000b. Standard Operating Procedure: Soil Sampling. Environmental Response Team, 13 pp. http://www.dem.ri.gov/pubs/sops/wmsr2012.pdf

U.S. Environmental Protection Agency (U.S. EPA). 2001. Managing Your Hazardous Waste: A Guide for Small Businesses. Office of Solid Waste and Emergency Response, EPA 530-K-01-005, 31 pp. http://www.epa.gov/epaoswer/hazwaste/sqg/handbook/k01005.pdf

59

U.S. Environmental Protection Agency (U.S. EPA). 2006. Environmental Response Team website. http://www.ert.org/mainContent.asp?section=About&subsection=Overview

U.S. Environmental Protection Agency (U.S. EPA). Undated. Clandestine Drug Labs - The Problem, the Dangers, the Future. Environmental Response Team, 25 minute CD/DVD. http://www.ertvideo.org/Pages/Video.html

U.S. White House Office of National Drug Control Policy. 2006. Drug endangered children. http://www.whitehousedrugpolicy.gov/enforce/dr_endangered_child.html

Utah Department of Environmental Quality (UDEQ). 2005. Decontamination Specialist Certification Program Decontamination Specialist Training Manual. State of Utah, 217 pp. http://www.superfund.utah.gov/docs/methCertManual.pdf

Utah Department of Public Safety (UDPS). 2004. Methamphetamine Identification: Meth Causes for Concern. State of Utah, 4 pp. http://sbi.utah.gov/narcotics/meth_concern.html

Vona, M. 2003. Initial Evaluation of Emission from Methamphetamine Manufacturing via the Ephedrine/Red Phosphorus/Hydriodic Acid Method. California Department of Toxic Substances Control. 8 pp. http://www.dtsc.ca.gov/SiteCleanup/ERP/upload/SMBRB_MEMO_Initial-Eval.pdf

Washington State Department of Health (WSDH). 2002. First Responder Injuries from Non-Petroleum Hazardous Substances Emergency Events in Washington State, 1995-2000. Washington State, Office of Environmental Health and Safety, 10 pp. http://www.doh.wa.gov/ehp/oehas/HSEES/First-Responder-injuries-95-2000.pdf

Washington State Department of Health (WSDH). 2003. Work Plan Template for the Decontamination of Illegal Drug Manufacturing Sites. 11 pp. http://www.doh.wa.gov/ehp/ts/CDL/workplantemplate.doc

Washington State Department of Health (WSDH). 2005a. Guidelines for Environmental Sampling at Illegal Drug Manufacturing Sites. http://www.doh.wa.gov/ehp/ts/CDL/cdl-envir-sampling.pdf

Washington State Department of Health (WSDH). 2005b. Rationale for the Establishment of the Washington State Department of Health’s Clandestine Drug Lab Program Decontamination Standards. 9 pp. http://www.doh.wa.gov/ehp/ts/CDL/estab-cdl-standards.pdf

60

Wisconsin Division of Public Health (WDPH). 2003. Cleaning Up Hazardous Chemicals at Methamphetamine Laboratories. State of Wisconsin, 4 pp. http://www.dhfs.state.wi.us/eh/ChemFS/pdf/MethFS.pdf

White, M. 2004. FSS Report on Methylamphetamine, Chemistry, Seizure Statistics, Analysis, Synthetic Routes, and History of Illicit Manufacture in the UK and the USA. Appendix One. The Forensic Science Service, 31 pp. http://www.drugs.gov.uk/publication-search/acmd/ACMD-meth-annex-November-2005?view=Binary

Willers-Russo, L. 1999. Three fatalities involving phosphine gas, produced as a result of methamphetamine manufacturing. Journal of Forensic Science 44:647-652.

Wyoming. Undated. Cleaning Up Hazardous Chemicals at Methamphetamine Laboratories. State of Wyoming, Department of Health, 5 pp. http://wdh.state.wy.us/epiid/methcleanup.asp

Other Resources

National Alliance for Model State Drug Laws. http://www.natlalliance.org/

University of Arizona, Mel and Enid Zuckerman College of Public Health. http://www.google.com/search?q=methamphetamine&sitesearch=publichealth.arizona.edu

Other State Websites

Alaska Department of Environmental Conservation. 2004. Guidance and Standards for Cleanup of Illegal Drug Manufacturing Sites. November 22, 2004. http://www.dec.state.ak.us/docs/druglab_guidance.pdf

Alaska Department of Environmental Conservation. Methamphetamine Cleanup Health Standards. http://www.dec.state.ak.us/spar/perp/methlab/methlab_healthstd.htm

Arizona Drug Endangered Children Program. 2005. Environmental Cleanup. February 3, 2005. http://www.azag.gov/DEC/cleanup.html

Arkansas Department of Health. 2004. Clandestine Methamphetamine Laboratory Cleanup Guidelines. March 28, 2004. http://www.healthyarkansas.com/pdf/adh_methguidelines_2004.pdf

Colorado Department of Public Health and Environment. 2003. Cleanup of Clandestine Methamphetamine Labs Guidance Document. http://www.cdphe.state.co.us/hm/methlab.pdf

61

Colorado Department of Public Health and Environment. 2005. Support for Selection of a Cleanup Level for Methamphetamine at Clandestine Drug Laboratories. http://www.cdphe.state.co.us/hm/methlabcleanuplevelsupport.pdf

Colorado Department of Public Health and Environment. 2005. Questions and Answers Regarding the Meth Lab Cleanup Regulations. http://www.cdphe.state.co.us/hm/methlabregqanda.pdf

Georgia Council on Substance Abuse. Georgia Meth Watch Program. http://www.gameth.com/

Illinois Department of Public Health. Undated. Guidelines for Cleaning Up Former Methamphetamine Labs. http://www.idph.state.il.us/envhealth/factsheets/meth-cleanup.htm

Iowa Department of Public Health. 2003. Guideline for Cleaning Up Former Methamphetamine Labs. http://www.idph.state.ia.us/eh/common/pdf/hseess/meth_lab_cleanup.pdf

Iowa Legislative Services Agency. 2004. Methamphetamine Laboratories: Issues Review. Fiscal Services. October 5, 2004. http://www.legis.state.ia.us/lsadocs/IssReview/2005/IRJDA000.pdf

Kansas Department of Health and Environment. Undated. Cleaning Up Former Methamphetamine Labs. http://www.kdheks.gov/methlabs/ml_cleanup.html

North Carolina Department of Health and Human Services. 2005. Illegal Methamphetamine Laboratory Decontamination and Re-occupancy Guidelines. http://www.epi.state.nc.us/epi/oii/pdf/methguidelines.pdf

North Dakota Department of Health. 2005. Best Management Practices for Cleanups at Methamphetamine Labs. http://www.health.state.nd.us/wm/pdf/05_2WEBDrugLabCleanup.pdf

Oregon Department of Environmental Control. 2006. Chemical Residual Removal for Children Associated With Clandestine Methamphetamine Laboratories. April 2006. http://www.regondec.org/decon/pdf

Oregon Department of Human Services. 2006. Decontamination of Illegal Drug Manufacturing Sites. Oregon Administrative Rules (OARs), Public Health. April 14, 2006. http://arcweb.sos.state.or/us/rules/OARs_300/OAR_333/333_040.html

Tennessee Department of Environment and Conservation. Cleanup of Methamphetamine Contaminated Properties. http://state.tn.us/environment/dor/meth/

62

Washington State Department of Health. 2005. Guidelines for Environmental Sampling at Illegal Drug Manufacturing Sites. November 30, 2005. http://www.doh.wa.gov/ehp/ts/CDL/cdl-envir-sampling.pdf

Washington State Department of Health. Methamphetamine webpage. http://www.doh.wa.gov/phepr/handbook/meth.htm

Wisconsin Department of Health and Family Services. 2003. Cleaning Up Hazardous Chemicals at Methamphetamine Laboratories. November 2003. http://www.dhfs.state.wi.us/eh/ChemFS/fs/MethClnUp.htm

Wyoming Department of Health. Undated. Cleaning Up Hazardous Chemicals at Methamphetamine Laboratories. http://wdh.state.wy.us/epiid/methcleanup.asp

Local Jurisdictions

Dakota County, MN. 2004. Cleanup of Clandestine Drug Lab Site Ordinance. Dakota County Ordinance No. 129, August 2004. http://www.co.dakota.mn.us/public_health/Meth_labs/Meth_PDFs/2004%20-%20Meth%20Ordinance%20Final%2020129%20AMENDMENT.pdf

A-1

8.0AppendixA:PropertiesofChemicalsAssociatedwithMethamphetamineAppendix A is a table that presents chemicals that may be found at meth labs and identifies their physical form (solid, liquid, gas), hazards (combustible, corrosive, flammable, poison, reactive), acute and chronic health effects, and environmental fate and transport, when available.

ChemicalandCASNumber

Form Hazard HealthEffect FateandTransport

Acetic Acid (64-19-7)

[manufacture of phenyl-2-propanone(P-2-P)]

Ref: 11, 44, 51

Colorless liquid Corrosive Vapors cause eye irritation. Exposure to high concentrations cause inflammation of airway and ulcers of eyes. IDLH of 50 ppm.

Miscible in water. While reacting with soil components, likely to be neutralized or diluted in soil. Readily biodegrades by aerobic or anaerobic mechanisms.

Acetic Anhydride (108-24-7)

(manufacture of P-2-P)

Ref: 11, 44, 51

Colorless liquid Corrosive Vapors cause eye irritation. Exposure to high concentrations may lead to ulcerations of the nasal mucosa and can severely damage the eye. IDLH of 200 ppm.

Dissolves slowly in water. Specific gravity is greater than 1 so there is potential that it will sink in ground/surface water. Will degrade over time to acetic acid.

Acetone (67-64-1)

(solvent)

[syn: dimethyl ketone, 2-propanone]

Ref: 8, 10, 12, 51

Colorless liquid with fragrant odor

Flammable Vapors may cause skin irritation. Prolonged exposure to high concentration may lead to blurred vision, fatigue, convulsions and death. IDLH of 2,500 ppm.

Miscible in water. Not persistent. Readily biodegrades in soil or water.

Ammonia (7664-41-7)

(Birch/Nazi method)

Ref: 11, 44, 45, 51

Colorless gas with pungent odor, anhydrous form is liquid under pressure

Corrosive Liquid anhydrous ammonia causes severe skin burns on contact. Lung irritant at low concentrations. IDLH of 300 ppm.

Lighter than air gas, likely to dissipate into atmosphere.

Ammonium Hydroxide (1336-21-6)

Ref: 13

Clear colorless solution with ammonia odor

Corrosive and Poison

Ammonium solution (10-35% ammonia) can cause upper respiratory irritation. Exposure to greater than 5,000 ppm can be fatal. Can cause irritation and burns to skin. Ingestion of as little as 2-3 ml can also be fatal

Toxic to aquatic life. 28% solution has high vapor pressure and is likely to evaporate if spilled.

A-2



Benzaldehyde (100-52-7)

(Precursor for amphetamine or P-2-P)

Ref: 14, 51

Colorless liquid, bitter almond odor

Combustible Mild irritant to lungs. Central nervous system depressant.

If released in sufficiently large quantities, can migrate to shallow water table. Slightly soluble in water with specific gravity of 1.05. Moderately biodegradable.

Benzyl Chloride (71-43-2)

Ref: 7, 15, 51

Colorless to pale yellow liquid with pungent aromatic odor

Combustible Eye, skin, and respiratory irritant. IDLH 10 ppm.

Not persistent. Hydrolysis in moist conditions. Readily biodegradable.

Benzene (71-43-2)

(Solvent in meth process)

Ref: 8, 10, 44, 51

Colorless liquid with aromatic odor

Flammable Vapor in high concentrations may cause dizziness, headache, coughing. Chronic exposure may cause anemia or leukemia. IDLH of 500 ppm.

Mobile in soils. Lighter than water and slightly soluble. Will biodegrade over time. MCL of 5 µg/L

Chloroform (67-66-3)

Ref: 16

Colorless liquid with a pleasant odor

Irritation eyes, skin; dizziness, mental dullness, nausea, confusion; headache, lassitude (weakness, exhaustion); anesthesia; enlarged liver, suspect carcinogen. IDLH of 500 ppm.

Chloroform has a high vapor pressure and is likely to evaporate if spilled. In the event of a large spill, it may migrate to shallow groundwater. It is not toxic to aquatic life.

Coleman Fuel (68410-97-9)

(Birch/Nazi and red phosphorus)

Ref: 46, 51

Clear colorless liquid with odor of rubber cement. Mixture of light petroleum distillates containing up to 25% n-hexane and 15% cyclohexane.

Flammable Skin irritant. Central nervous system suppressant (dizziness, nausea, blurred vision, drowsiness, loss of coordination). Chronic exposure can cause damage to sensory and motor nerve cells, kidneys, and liver.

Vapors are heavier than air and may accumulate in low spots. Small spills are likely to evaporate. Large spills can penetrate soil and may reach groundwater. Will biodegrade over time.

Ephedrine (299-42-3)

(Precusor for meth)

Ref: 1, 51

Odorless white crystal

None Skin and respiratory irritant.

Not available.

Ethanol (64-17-5)

Ref: 8, 44, 51

Clear colorless liquid

Flammable Respiratory irritant. Central nervous system suppressant. IDLH of 3,300 ppm.

Miscible with water. Large spills may reach water table. Very biodegradable.

A-3



Diethyl Ether (60-29-7)

[syn: ether, ethyl ether, ethyl oxide]

Ref: 9, 11, 44, 51

Clear colorless liquid with sweet pungent odor

Highly Flammable Inhalation may cause headache, drunkenness, and vomiting. IDLH of 1,900 ppm.

Spilling of small amounts to ground or soil will likely result in volatilization. Expected to be mobile in soil and resistant to biodegradation.

Formic Acid (64-18-6)

Ref: 11, 18, 44, 51

Colorless fuming liquid with a pungent odor

Corrosive and moderate fire hazard

Highly toxic with inhalation for short duration. Produces blisters and burns on contact with skin. Prolonged exposure to low concentrations may cause liver and kidney damage. IDLH 30 ppm

Miscible in and heavier than water. When released in quantity to soil is expected to leach to shallow groundwater with moderate biodegradation. Because of its fire hazard and tendency to react explosively with oxidizing agents should not be flushed into sanitary sewer.

Normal Hexane (110-54-3)

Ref: 11, 29, 44

Clear colorless liquid with slight odor

Highly Flammable May cause skin irritation. Inhalation irritates respiratory system, and overexposure may cause light headedness, nausea, headache, and blurred vision. Chronic inhalation may cause peripheral nerve disorders and central nervous system damage. Potential teratogen. IDLH is 1,100 ppm.

When spilled on the ground expected to evaporate. If it penetrates the ground, not likely to leach (Log Kow of > 3.0) to groundwater. Not very soluble and lighter than water. Moderate biodegradation expected.

Cyclohexane (110-82-7)

Ref: 11, 17

Clear colorless liquid with faint ether-like odor

Highly Flammable Causes irritation to respiratory tract. High concentrations have a narcotic effect. Chronic exposure may cause skin effects.

When spilled on the ground expected to evaporate. If it penetrates the ground, may leach to groundwater. Not very soluble, lighter than water. Moderate biodegradation expected.

A-4



Hydrochloric Acid (7647-01-0)

[syn: muriatic acid]

Ref: 19, 51

Clear colorless liquid with pungent odor


Skin exposure will cause burns. Long-term exposure to concentrated vapors may cause erosion of teeth. Inhalation can lead to permanent lung and respiratory tract damage. IDLH 50 ppm as HCl gas.

Small spills may evaporate (water and HCl gas). Miscible with water and slightly heavier. What does not react with soil may reach shallow groundwater through leaching process.

Hydriodic Acid (10034-85-2)

Red phosphorus method

Ref: 20, 51

Clear colorless liquid with pungent odor (hydrogen iodide dissolved in water)


Vapors cause severe irritation and burns to respiratory tract. Liquid may cause burns to skin.

Small spills may evaporate (water and HI gas). Miscible with water and slightly heavier. What does not react with soil may reach shallow groundwater through leaching process.

Hydrogen Sulfide (7783-06-4)

Ref: 41

Clear colorless gas with rotten egg odor. Heavier than air.

Flammable and Poison

If in gas cylinder, escaping gas can cause frostbite. Short term inhalation exposure depending upon concentration can cause irritation, cough, eye sensitivity to light, changes in blood pressure, nausea, vomiting, breathing difficulty, headache, drowsiness, dizziness, disorientation, tremors, hallucinations, coma, death. Long-term exposure can cause loss of appetite, weight loss, irregular heart beat, headache, nerve damage, lung congestion, paralysis, brain damage. IDLH is 100 ppm.

Hydrogen sulfide is heavier than air and may accumulate in low-lying areas.

Hypophosphorus Acid (6303-21-5) Used in place of red phosphorus

Ref: 21, 51

Clear colorless and odorless liquid

Corrosive and Reactive. Strong reducing agent, heat may cause fire or explosive decomposition liberating phosphine gas (poison).

Destructive to mucus and upper respiratory tract tissue. Symptoms may include coughing, wheezing, laryngitis, shortness of breath, headache, nausea, and vomiting. May cause redness and burning of skin tissue.

Not available.

A-5



Iodine (7553-56-2)

Reagent in making hydriodic acid

Ref: 22, 51

Solid purple crystals or flakes with sharp odor

Corrosive, Reactive, and Poison

Inhalation may result in severe irritation and burns to respiratory tract. Inhalation of concentrated vapors may be fatal. Highly toxic to eye tissue. Chronic exposure may cause insomnia, tremors, conjunctivitis, bronchitis, diarrhea, and weight loss. IDLH is 2 ppm.

Slightly soluble in water (300 mg/L) with very low vapor pressure.

Iodine, Tincture, No CAS number. Reagent in synthesis of Hydriodic Acid

Ref: 23, 51

Dark Red Solution (Mixture of ethanol, iodine crystals and sodium iodide)

Flammable (ethanol)

See description for ethanol and iodine

Not available.

Lead Acetate (301-04-2)

Reagent in P-2-P synthesis

Ref: 24, 51

Solid white crystals or grey, brown in commercial grades with slight acetic acid odor

Poison Unless a large amount is ingested, lead acetate is a chronic poison that accumulates lead through ingestion and inhalation of dust. Chronic exposure symptoms are like those of ingestion poisoning: restlessness, irritability, visual disturbances, and hypertension. Can have a negative affect on the mental development of children (lower IQ). IDLH is 100 mg/m3 as lead.

As a solid, unlikely to move into ground but could be spread by wind. If left exposed to weathering is very soluble (60gm per 100gm water) and will likely move with precipitation into the subsurface. Subsurface mineral content will determine whether it stays in solution. Lead bioaccumulates.

Lithium (metal) (7439-93-2)

Used in Birch/Nazi method

Ref: 6, 47

Soft silvery-white metal

Flammable, Water-Reactive to give off hydrogen gas and form LiOH, a strong highly corrosive base and corrosive lithium oxide fumes.

The moisture-reactive property of lithium makes it corrosive to any tissue it contacts. Inhalation of fumes generated from a water reaction will irritate or damage upper respiratory tract tissues.

Only small quantities of lithium are likely to be used in a meth laboratory and should not present an environmental problem. In a release scenario, the metal will likely be transformed to LiOH and Li2O.

A-6



Lithium Aluminum Hydride (1302-30-3)

Hydrogenation in multiple processes

Ref: 25, 51

Solid white to grey odorless powder

Flammable, Reactive (water to form hydrogen gas and corrosive LiOH), and Corrosive

When inhaled is destructive to mucus membranes and tissues of respiratory tract. Corrosive to skin, may cause redness or burns.

Can ignite with friction. LiOH may be mobile in soil.

Mercuric Chloride (7487-94-7) Reagent in meth synthesis using P-2-P method

Ref: 26, 51

Solid white crystals Poison and Corrosive

Vapor inhalation can burn the mucus membranes of nose and throat as well as allow mercury sorption in blood stream. Causes irritation and burns to the skin. Chronic exposure can result in mercury poisoning: muscle tremors, personality and behavior changes, memory loss, metallic taste, loosening of the teeth, digestive disorders, skin rashes, brain and kidney damage. IDLH is 10 mg/m3 as mercury

As a solid, unlikely to move into ground but could be spread by wind. If left exposed to weathering is very soluble (7.6gm per 100gm water) and will likely move with precipitation into the subsurface. Subsurface mineral content will determine whether it stays in solution. Mercury bioaccumulates; if mercuric chloride is disposed into surface water it will have negative affects on the biota.

Methyl Alcohol (67-56-1) (HEET Gas Line Antifreeze is 99% methanol)

[syn: methanol, wood alcohol, carbinol]

Ref: 8, 11, 27, 44, 51

Clear colorless liquid


Inhalation acts on nervous system. Overexposure symptoms may include headache, drowsiness, nausea, vomiting, blindness, coma, and death. Usual fatal ingestion dose is 100-125 mL. Chronic exposure may cause marked impairment of vision. IDLH is 6,000 ppm.

Methanol is miscible in and lighter than water. When released to the ground in sufficient quantities to get into the subsurface it will leach into percolating water and may reach the groundwater. Methanol is biodegradable.

Methylamine (74-89-5)

Precursor for meth

[syn: aminomethane]

Ref: 8, 11, 44, 51

Clear colorless gas with rotten fish/ammonia odor. (Usually encountered in dissolved state in water)

Flammable and Corrosive

Exposure to vapors may cause irritation to eye and mucus membranes. Skin contact may result in irritation or burns. Symptoms may include coughing, shortness of breath, and headaches. IDLH is 100 ppm.

A spill of methylamine (dissolved in water) to the ground will tend to evaporate. If it enters the soil it is likely to leach rapidly through the soil to groundwater (log Kow of −0.57). Methylamine is biodegradable.

A-7



Methyl Ethyl Ketone (78-98-3)

[syn: 2-butanone, methyl acetone]

Ref: 8,10, 28, 44

Clear, colorless liquid with a sharp mint-like odor

Extremely flammable

Inhalation causes irritation to nose and throat at high concentrations. May cause headache, dizziness, nausea, shortness of breath, and nervous system depression. Contact with skin and eyes may cause irritation—skin absorption with possible systemic affects. Chronic exposure may cause dermatitis or central nervous system effects. IDLH of 3,000 ppm.

Methyl Ethyl Ketone is fairly soluble in water (239,000 mg/L) and has a log Kow of 0.29. If released to the ground it will partially evaporate, and if the release has a sufficient quantity to enter the subsurface will leach to shallow groundwater. It does not biodegrade readily.

Nitric Acid (7697-37-2)

Ref: 30

Clear colorless to yellowish liquid with suffocating acrid odor

Corrosive Oxidizer

Inhalation causes extreme irritation of upper respiratory tract. Skin contact can result in deep ulcers and staining of skin. IDLH of 25 ppm

Incompatible with most materials.

Nitroethane (79-24-3)

Precursor in P-2-P synthesis

Ref: 4, 11, 44, 51

Colorless oily liquid with a mild fruity odor

Flammable Skin contact may cause dermatitis. Eye contact may cause corneal damage. Inhalation causes respiratory irritation and may cause dizziness and suffocation. IDLH of 1000 ppm

With small spills on an impervious or wet ground, evaporation may be significant. After entering the subsurface, likely to move through the soil to shallow groundwater (log Kow of 0.18) or pond on low permeability soils. Slightly denser than water; water solubility of 4.5% by weight. Biodegradable under aerobic conditions.

Nitromethane (75-52-5)

Ref: 31, 44

Clear oily liquid Flammable Vapors may cause irritation to respiratory tract. A weak narcotic, higher concentrations may cause nausea, vomiting, diarrhea, and headaches. Skin contact can cause irritation, pain, redness. Absorbed through skin. Prolonged exposure can cause dermatitis and liver damage.

A-8



Perchloric Acid (7601-90-3)

Ref: 32

Clear to yellowish odorless liquid

Corrosive Oxidizer. Unstable at normal pressure and temperature and may decompose explosively.

Inhalation may cause irritation to upper respiratory tract. Skin contact may result in burns and discoloration.

May form sensitive explosive mixtures with organic materials.

Petroleum Distillates (Naphtha) (8002-05-9) Note that there are many Naphthas and they contain different ratios of petroleum hydrocarbons and have somewhat different properties in terms of toxicity. CAS 8002-05-9 is the one characterized by OSHA. Rosonol, a lighter fluid, is made up of Naphthas.

Ref: 44, 51

Clear colorless liquid with a hydrocarbon odor

Flammable Inhalation may cause dizziness, drowsiness, headache, and nausea. Skin contact will cause defatting and cracking. Vapors are an irritant to eyes nose and throat. IDLH 1,100 ppm

Naphthas are hydrophobic and lighter than water. In sufficient volume, they will move through the subsurface until they encounter a low permeability soil or the groundwater. Naphthas are biodegradable, but the process is lengthy.

Phenylacetic Acid (103-82-2) Precursor for P-2-P synthesis

[syn: benzeneacetic acid, alpha-toluic acid]

Ref: 51

Solid white crystal with a floral odor

None Contact is irritating to skin and eyes. Inhalation may cause upper respiratory tract irritation. Potential teratogen.

Not available.

Phenyl-2-Propanone (103-79-7)

Precursor for meth

Ref: 51

Clear, moderately viscous liquid

None Irritating to eyes and skin. Inhalation may lead to headache, nausea, and dizziness.

Not available.

A-9



Phosphine (7803-51-2)

Ref: 44, 48, 50, 51

Colorless gas with a fish- or garlic-like odor. Note: commercially made product has odor, phosphine itself is odorless.


Inhalation may cause dizziness, drowsiness, nausea, chest pressure, tremors, convulsions, and central nervous system damage. Exposure symptoms can be delayed for up to 48 hours. IDLH is 50 ppm.

Heavier than air. May accumulate in low spots. High reactivity will minimize environmental effects.

Phosphoric Acid (7664-38-2)

Precursor for meth

Ref: 33, 44, 51

Thick, odorless crystalline solid often used in an aqueous solution

Corrosive Not an inhalation hazard unless misted or heated to high temperatures. Skin contact may cause burns. IDLH of 1,000 ppm.

When released in sufficient quantities may reach shallow groundwater. Neutralization leaves phosphate.

Phosphorus Pentachloride (10026-13-8)

Used in Emde method

Ref: 5, 44

White to pale yellow crystalline powder with pungent unpleasant odor

Corrosive Causes severe irritation of respiratory tract and at high concentrations can be fatal. Skin contact results in burns. Chronic exposure can cause liver and kidney damage. IDLH of 70 mg/m3.

Hydrolyzes in water (even in humid air) to form hydrochloric acid and phosphoric acid

Pseudoephedrine (321-97-1)

Meth precursor

Ref: 2, 51

Nearly odorous, white crystalline powder

None Contact with skin or eyes may result in irritation. Inhalation may result in respiratory irritation.

Completely soluble in water with a log Kow of 1.74. As crystal may be transported by wind. Dissolved in water or subjected to water (rain) will leach through soil. Moderately biodegradable.

Pyridine (110-86-1)

Reagent in the synthesis of P-2-P from phenylacetic acid in the presence of acetic anhydride

Ref: 8, 11, 42, 44, 51

Colorless to yellow liquid with a nauseating fish-like odor

Flammable Skin and eye irritant. Short-term inhalation may cause irritation, headache, drowsiness, dizziness, loss of coordination. Long-term inhalation may cause nausea, vomiting, diarrhea, stomach pain, loss of appetite, dizziness, sleep and emotional disturbances, loss of coordination, nerve, heart, kidney, and liver damage. IDLH of 1,000 ppm

Pyridine is miscible in water and has a log Kow of 0.65. As such, when released in sufficient quantity it should move freely through the subsurface, and lesser amounts will leach with rainfall. Very biodegradable.

A-10



Red Phosphorus (7723-14-0)

Red phosphorus method for meth production

Ref: 49, 51

Odorless red to violet solid

Flammable and explosive when mixed with oxidizing materials. In the presence of water vapor and oxygen decomposes to form phosphoric acids and phosphine gas.

May cause eye and skin irritation. Inhalation may cause respiratory tract irritation. Chronic ingestion or inhalation may induce systemic phosphorous poisoning. Liver damage, kidney damage, jaw/tooth abnormalities, blood disorders, cardiovascular effects can result.

Harmful to aquatic organisms. Insoluble in water. Will remain on ground surface if released.

Sodium (7440-23-6)

Ref: 36, 51

Silvery white solid Flammable and Corrosive. Severe fire risk in contact with water in any form. Reaction forms hydrogen gas and sodium hydroxide. Ignites spontaneously in dry air when heated.

Reacts with moisture on skin, mucus membranes, and eyes to cause chemical and heat burns.

High reactivity with air and moisture will quickly eliminate the metallic form. In a lab, it should be found as solids under a hydrocarbon solution.

Sodium Hydroxide (1310-73-2) Drano® contains 30-60% by weight of sodium hydroxide, Red Devil Drain Cleaner also has lye in it.

Ref: 35, 44, 51

Colorless to white solid (flakes, beads, pellets)


Contact with skin will cause irritation to severe burns. Inhalation depending upon concentration can cause mild irritation to severe damage to upper respiratory tract. IDLH of 10 mg/m3.

Dissolves in water with release of heat, creating a high pH solution.

Sulfuric Acid (7664-93-9)

Battery acid is sulfuric. Used battery acid may contain high concentrations of lead. Liquid Fire Drain Cleaner contains sulfuric acid.

Ref: 37, 44, 51

Colorless to yellow viscous liquid

Corrosive Contact with skin or eyes can cause severe deep burns. Inhalation of fumes can result in severe damage to upper respiratory tract. IDHL is 15 mg/m3.

Miscible with water with evolution of heat. In sufficient quantity may leach to shallow groundwater. Release to a surface water may be toxic to aquatic organisms if sufficient energy is not available for quick dilution.

A-11



Thionyl Chloride (7719-09-7)

Ref: 38, 44, 51

Pale yellow to red liquid with a pungent characteristic odor


Extremely destructive to tissues of the mucous membranes and upper respiratory tract when inhaled; can be fatal. Skin and eye contact may cause irritation and blistering burns. Prolonged or repeated exposure may cause conjunctivitis, dermatitis, rhinitis, and pneumonitis.

Reacts violently with water to form HCl and SO2. Not likely to remain in the environment as thionyl chloride.

Thorium Oxide (1314-20-1)

Catalyst for P-2-P synthesis

Ref: 3, 51

White heavy crystalline powder

None Irritant to skin and eyes. May cause mild irritation to respiratory system when inhaled. Thorium is a confirmed human carcinogen producing anglosarcoma, liver and kidney tumors, lymphoma, and other tumors of the

blood system. Chances of developing cancer increase with increased exposure.

Thorium oxide may spread through the environment by runoff or wind. It is insoluble in water and will likely remain where it is spilled.

Toluene (108-88-3)

[syn: methyl benzene, phenylmethane]

Ref: 8, 10, 39, 44, 51

Clear colorless liquid with an aromatic odor


Toluene is a central nervous system depressant and an irritant of the eyes, mucous membranes, and skin in humans. In contact with the eyes, toluene causes reversible corneal injury; prolonged skin contact causes defatting and dermatitis. Exposure while pregnant may affect fetal development. IDLH is 500 ppm.

Toluene has a solubility in water of about 534 mg/L. When released to the soil near-surface toluene will evaporate, with deeper releases leaching to shallow groundwater. Toluene will slowly biodegrade in both the soil and groundwater. It is lighter than water, so it will stop migrating down at the water table. (Howard Vol II)

A-12



1,1,2-Trichloroethane (79-00-5)

Gun-cleaning solvent

Ref: 43, 44

Colorless liquid with sweet odor

None Inhalation may cause irritation, irregular heartbeat, headache, symptoms of drunkenness, and kidney and liver damage. IDLH is 100 ppm.

Slightly soluble in water (4,420 mg/L). Has a log Kow of 2.07; unlikely to sorb to soil. If released in sufficient quantities may migrate to shallow ground water. Heavier than water and will sink through the water table. Not likely to biodegrade. Small spills likely to evaporate.

1,1,2-Trichloro-1,2,2-Trifluoroethane

Ref: 8, 11, 40, 44, 51

Clear colorless liquid with a slight ethereal odor

None Eye and skin contact may cause redness and pain. Causes irritation to upper respiratory tract. Air concentrations above 2,500 ppm may cause feeling of excitement and incoordination. Fatal arrhythmias are possible at high concentrations. IDLH is 2,000 ppm

1,1,2-Trichloro-1,2,2-Trifluoroethane has a very high vapor pressure and releases to soil or water will evaporate quickly. In the subsurface, it is hydrophobic (solubility in water of 1,100 ppm) and denser than water (1.56 specific gravity), it should move through the subsurface and, with sufficient head, through the water table. 1,1,2-Trichloro-1,2,2-Trifluoroethane does not readily biodegrade.

A-13

References:

1. BASF. 2002. Material Safety Data Sheet: Ephedrine HCL Crystal, 5 pp. http://worldaccount.basf.com/

2. BASF. 2002. Material Safety Data Sheet: Pseudoephedrine HCL Crystal, 5 pp. http://worldaccount.basf.com/

3. Electronic Space Products International. 1998. Material Safety Data Sheet: Thorium Oxide, 3 pp. http://www.espimetals.com/msds’s/thoriumoxide.pdf

4. Fischer Scientific. 2005. Material Safety Data Sheet: Nitroethane, 8 pp. https://fscimage.fishersci.com/msds/65832.htm

5. Fischer Scientific. 2005. Material Safety Data Sheet: Phosphorus Pentachloride, 4 pp. http://www.catalogue.fisher.co.uk/scripts/search.dll?ViewMSDS&SheetNumber=88710

6. FMC. 2005. Material Safety Data Sheet: Lithium, 5 pp. http://www.fmclithium.com/products/msds/MSDS037.pdf

7. Howard, P. 1990. Handbook of Environmental Fate and Exposure Data for Organic Chemicals, Vol. I Large Production and Priority Polutants. Lewis Publishers, 574 pp.

8. Howard, P. 1991. Handbook of Environmental Fate and Exposure Data for Organic Chemicals, Vol. II Solvents. Lewis Publishers, 546 pp.

9. Howard, P. 1993. Handbook of Environmental Fate and Exposure Data for Organic Chemicals, Vol. IV Solvents 2. Lewis Publishers, 578 pp.

10. Montgomery, J. and L. Welkom. 1991. Groundwater Chemicals Desk Reference. Lewis Publishers, 640 pp.

11. Montgomery, J. 1991. Groundwater Chemicals Desk Reference Volume 2. Lewis Publishers, 944 pp.

12. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Acetone, 11 pp. http://www.jtbaker.com/msds/englishhtml/a0446.htm

13. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Ammonium Hydroxide, 11 pp. http://www.jtbaker.com/msds/englishhtml/a0446.htm

14. Mallinckrodt Baker, Inc. 1999. Material Safety Data Sheet: Benzaldehyde, 10 pp. http://www.jtbaker.com/msds/englishhtml/b0696.htm

15. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Benzyl Chloride, 11 pp. http://www.jtbaker.com/msds/englishhtml/B1957.htm

16. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Chloroform, 11 pp. http://www.jtbaker.com/msds/englishhtml/C2915.htm

17. Mallinckrodt Baker, Inc. 2003. Material Safety Data Sheet: Cyclohexane, 9 pp. http://www.jtbaker.com/msds/englishhtml/c6886.htm

A-14

18. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Formic Acid, 9 pp. http://www.jtbaker.com/msds/englishhtml/f5956.htm

19. Mallinckrodt Baker, Inc. 2006. Material Safety Data Sheet: Hydrochloric Acid (10%-33%), 9 pp. http://www.jtbaker.com/msds/englishhtml/h3886.htm

20. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Hydriodic Acid, 8 pp. http://www.jtbaker.com/msds/englishhtml/h3728.htm

21. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Hypophosphorus Acid, 8 pp. http://www.jtbaker.com/msds/englishhtml/h8468.htm

22. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Iodine, 8 pp. http://www.jtbaker.com/msds/englishhtml/i2680.htm

23. Mallinckrodt Baker, Inc. 1999. Material Safety Data Sheet: Iodine Tincture, 8 pp. http://www.jtbaker.com/msds/englishhtml/i2682.htm

24. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Lead Acetate, 9 pp. http://www.jtbaker.com/msds/englishhtml/l2434.htm

25. Mallinckrodt Baker, Inc. 2001. Material Safety Data Sheet: Lithium Aluminum Hydride, 9 pp. http://www.jtbaker.com/msds/englishhtml/l6523.htm

26. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Mercuric Chloride, 11 pp. http://www.jtbaker.com/msds/englishhtml/M1469.htm

27. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Methyl Alcohol, 9 pp. http://www.jtbaker.com/msds/englishhtml/M2015.htm

28. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Methyl Ethyl Ketone, 11 pp. http://www.jtbaker.com/msds/englishhtml/m4628.htm

29. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: N-Hexane, 10 pp. http://www.jtbaker.com/msds/englishhtml/h2381.htm

30. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Nitric Acid, pp. http://www.jtbaker.com/msds/englishhtml/N3660.htm

31. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Nitromethane,11 pp. http://www.jtbaker.com/msds/englishhtml/N5740.htm

32. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Perchloric Acid, pp. http://www.jtbaker.com/msds/englishhtml/P1564.htm

33. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Phosphoric Acid, 9 pp. http://www.jtbaker.com/msds/englishhtml/p3973.htm

34. Mallinckrodt Baker, Inc. 2006. Material Safety Data Sheet: Phosphorus Amorphous, 9 pp. http://www.jtbaker.com/msds/englishhtml/p4017.htm

35. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Sodium Hydroxide, 11 pp. http://www.jtbaker.com/msds/englishhtml/s4034.htm

36. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Sodium Metal, 10 pp. http://www.jtbaker.com/msds/englishhtml/s2594.htm

37. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Sulfuric Acid, 52-100%, 10 pp. http://www.jtbaker.com/msds/englishhtml/s8234.htm

38. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: Thionyl Chloride, 8 pp. http://www.jtbaker.com/msds/englishhtml/t2938.htm

39. Mallinckrodt Baker, Inc. 2004. Material Safety Data Sheet: Toluene, 9 pp. http://www.jtbaker.com/msds/englishhtml/s8234.htm

40. Mallinckrodt Baker, Inc. 2005. Material Safety Data Sheet: 1,1,2-Trichloro-1,2,2-Trifluoroethane, 8 pp. http://www.jtbaker.com/msds/englishhtml/t5100.htm

41. Matheson Trigas. 2006. Material Safety Data Sheet: Hydrogen Sulfide, 8 pp. https://www.mathesontrigas.com/pdfs/msds/MAT11210.pdf

42. Matheson Trigas. 2004. Material Safety Data Sheet: Pyridine, 7 pp. http://www.matheson-trigas.com/msds/MAT19990.pdf

43. Matheson Trigas. 2004. Material Safety Data Sheet: 1,1,2-trichloroethane, 7 pp http://www.matheson-trigas.com/msds/MAT26380.pdf

44. National Institute for Occupational Health and Safety. 2005. Pocket Guide to Chemical Hazards, NIOSH Publication No. 2005-149. U.S. Department of Health and Human Services. http://www.cdc.gov/niosh/npg/

45. Office of Environmental Health Hazard. 2003. Ammonia. State of California, 2 pp. http://www.oehha.ca.gov/public_info/clanlabs.html

46. Office of Environmental Health Hazard. 2003. Coleman Fuel. State of California, 2 pp. http://www.oehha.ca.gov/public_info/clanlabs.html

47. Office of Environmental Health Hazard. 2003. Lithium. State of California, 2 pp. http://www.oehha.ca.gov/public_info/clanlabs.html

48. Office of Environmental Health Hazard. 2003. Phosphine. State of California, 2 pp. http://www.oehha.ca.gov/public_info/clanlabs.html

49. Office of Environmental Health Hazard. 2003. Red Phosphorus. State of California, 2 pp. http://www.oehha.ca.gov/public_info/clanlabs.html

50. Praxair. 2004. Material Safety Data Sheet: Phosphine, 7 pp. http://praxair.com/praxair.nsf/d63afe71c771b0d785256519006c5ea1/bd40c55346b4930f85256e5f007e8c2a/$FILE/Phosphine-Canada.pdf

51. Zuckerman College of Public Health. Undated. Hazardous Chemicals in Illicit Methamphetamine and Amphetamine Laboratories. University of Arizona, Tuscon, 9 pp. http://www.publichealth.arizona.edu/divisions/environ_com_hlth/popups/hazardous_chemicals.htm