Clandestine drug labs â€” or clan labs â€” are popping up across the country, posing a threat to human health and the environment. Clan labs are makeshift operations that produce illicit drugs, such as methamphetamine (meth), phencyclidine (PCP), 3,4-methylenedioxyphenylisopropylamine (MDMA or ecstasy), and lysergic acid diethylamide (LSD), to name a few. Methamphetamine accounts for 80 to 90 percent of the clandestine drug labs discovered, according to reports from the U.S. Drug Enforcement Administration (DEA).
Clan labs have been discovered in rural areas, in residences, hotels, public storage facilities, even in the rear of pet stores. And they are becoming more prevalent. The DEA reports that 234.5 kilograms (kg) of methamphetamine were seized in 1986, while 1,817 kg were seized through September of 2005.
Faced with the task of identifying and cleaning up these hazardous sites, law enforcement officers and property owners need the help of EHS experts.
Operators generally â€œcookâ€ their products in haphazard, dangerous environments. Statistics indicate that three to six people working in clandestine drug labs die from fires, explosions or toxic exposures annually. Itâ€™s estimated that for every pound of manufactured methamphetamine, five to six pounds of hazardous waste is generated â€” most of which is disposed of illegally.
All of the above illicit drugs are cooked with common household materials and items that are â€œprocuredâ€ for the intended purpose. Methamphetamine has at least 11 different production methods. With no standard production method, itâ€™s hard to determine the exact type of chemical hazards present at any given lab.
Depending on the quantity of the chemicals present and the condition of the lab, you can expect physical hazards associated with fires and explosions. Skin, eye and inhalation hazards are also associated with the chemicals.
Known vs. the unknownGenerally projects can be segregated into two categories: known production laboratories and unknown labs. Known labs are those clandestine labs that were discovered and investigated by law enforcement. These properties undergo gross cleanup in tandem with the criminal investigation. These are tightly controlled sites until law enforcement completes their investigation. Responsibility for final cleaning and returning the property to a habitable situation will remain with the property owner.
Law enforcement is a valuable resource in these situations. Officers can supply information as to the cook method, areas of contamination, what was removed, and by what contractor or HAZMAT Team. All this information can be utilized to develop a detailed sampling protocol and a site-specific health and safety plan, designed to protect the sampling team. Risks to the sampling team and costs associated with the project are substantially reduced.
Unknown labs are those where the property owner or operator has information that a clandestine drug lab may have been operating at the site. The property owner or ownerâ€™s representative may have been at the property and discovered visible stains but no other evidence that a lab existed. These types of projects tend to carry more risk and be more costly due to the extensive list of materials to rule out.
- Initial investigation protocols are dependent on a number of variables. These include client requirements, site information, and state guidelines or regulations. Preliminary assessment and associated sampling are required to develop information as to the extent of any potential contamination.
- Visual property assessments are required to identify and document evidence of burn areas, trash pits, debris piles, stained areas, and distressed vegetation exterior to the building.
- Internal assessments will include inspection of the rooms, crawl spaces, and hidden areas. Wipe sampling in areas suspected of production and storage can be obtained for methamphetamine, amphetamine, ephedrine, and pseudophedrine. Additional wipes can be obtained for lead and phosphorous. pH samples should be obtained using pH test strips with a visual indication for a pH between 6 and 8. A pH of less than 6 and greater than 8 would indicate that residual corrosive contamination remains on the surface and should be cleaned.
- An inspection of the plumbing system is required to identify and document potential disposal into the sanitary sewer or an individual septic system. All plumbing inlets to the septic or sewer system must be visually assessed for any staining or other visible residual contamination. All plumbing traps should be assessed for VOC concentrations using a PID or FID and for mercury vapors, using a mercury vapor analyzer.
- The inspection should determine if the heating, ventilation and air conditioning (HVAC) system serves more than one unit, such as in motels or apartments. Unlined ducted ventilation systems will require composite samples to be collected from inside the duct system and analyzed for methamphetamine, amphetamine, ephedrine, and pseudophedrine. Analysis will be performed by gas chromatograph/mass spectrometer (GC/MS). When possible, obtain a bulk sample from the HVAC system filter to determine if the intake of the system has been contaminated. For lined duct systems, a bulk sample of the liner may be obtained. Contact the laboratory for advice on sampling.
- The inspection team should determine if lead or asbestos building materials have been, or have the potential to be, disturbed during remediation. Question the owner to determine if sampling and compliance with state regulations are required.
- It is imperative that the inspection team notifies the lead law enforcement agency if lab remnants or other evidence of methamphetamine manufacturing is discovered that may have been overlooked during bulk decontamination.
Remediation planningAll of this information will be used to develop a remediation work plan. The plan will cover removal, cleaning requirements, disposal of generated materials, post-remediation sampling and the required clean criteria.
Septic systems, burn piles and dump sites all require special consideration. Depending on what is discovered, and the state or local regulations, remediation requirements will vary. This is where the EHS professional turns the project over to the environmental professional. Some states will require that a licensed or professional geologist develop sampling plans for subsurface water or soil investigations. This is especially true when septic systems have been impacted by illegal disposal operations. Here is where the location of the clan lab and the degree of contamination can cause these projects to escalate in costs.
Clandestine drug lab investigations and cleanup provide numerous challenges for those involved and offer many opportunities for EHS pros to lend their expertise:
- Law enforcement bears the greatest risk of physical and chemical hazards. Officers rely on their safety staff for professional guidance and training.
- Hazardous waste contractors require health and safety plans, additional training and air monitoring.
- Property owners, operators and mortgage holders require initial investigations, remediation protocols, post-remediation verification, support for disposal and help in navigating the regulatory maze.
- Regulators are finding themselves in uncharted territory and will seek help in determining effective sampling methods, remediation protocols and clean criteria.