The National Methamphetamine Drug Conference

The National Methamphetamine
Drug Conference

Workgroup 4
Clandestine Labs: Protecting The Environment And Community

PRESENTATION SUMMARIES:
"Enforcement Program Development"
George J. Doane, Chief
California Bureau of Narcotic Enforcement, Sacramento,California
Chief Doane presented a brief history of the California Bureau of Narcotics Enforcement's (CBNE) experience with methamphetamine abuse. It was not until the 1980s that California began to fully understand the devastating impact of clandestine methamphetamine laboratories as they began to flourish throughout the state. Prior to this time, California law enforcement agencies seized a relatively small number of methamphetamine labs per year. As the number of methamphetamine labs increased, the sophistication level grew, as did the explosions and fatalities.
Consequently, California was inundated with an enormous number of methamphetamine labs. In 1989, CBNE seized as many as 356 methamphetamine labs. Last year, CBNE's methamphetamine lab seizures reached an all-time high of 835 labs, compared to the U.S. Drug Enforcement Administration (DEA) statistics of 850 methamphetamine labs seized for the entire nation. California clearly is the source state for methamphetamine, much as Colombia is for cocaine.
As law enforcement officers continued to struggle with the growing epidemic, they also continued operating under fiscal constraints with limited resources while the labs continued to multiply. In 1995, approximately one of six methamphetamine labs resulted in an explosion. The most widely publicized case was in Riverside County, where a child burned to death in a house trailer as a result of a methamphetamine lab exploding in the kitchen where her mother had been cooking methamphetamine on top of the kitchen stove. The parents would not allow the neighbors to help rescue the child for fear that the neighbors would discover the lab.
Over the years, CBNE made great strides in dealing with clandestine methamphetamine labs. In the early years, agents were not provided with the protective safety equipment that is available to them today. The only protection made available to them were plastic bags and painter masks. Through years of exposure and experience, CBNE began to recognize the health dangers continuously confronted by agents. Through trial and error and with the assistance of the California Environmental Protection Agency and the Department of Toxic Substance Control, CBNE developed safety standards and safety equipment to minimize the risks of hazardous contamination.
CBNE also recognized the need to protect children found at lab sites from toxic exposure to dangerous chemicals. Assistant Chief Mitch Brown of CBNE completed his Masters Degree research on child endangerment at methamphetamine labs. During his research, Assistant Chief Brown found that CBNE encountered 1600–2400 kids per year in drug labs, and typically the children were under the age of 13, with some as young as age 4. Several of the children removed from methamphetamine labs were found to have bruises, abrasions and sporadic bald spots on their heads. When tested by the local child-protection services unit, 35 percent of the children tested positive for heavy metals.
When asked what can be done in other states, Chief Doane stressed, first and foremost, that we need to raise the level of awareness by educating the public about the hazards of methamphetamine labs. CBNE discovered the public is unaware and uniformed about methamphetamine labs, and there is a need to educate all agencies, such as child-protective services, social services, emergency rooms and hospitals, and criminal justice.
California was instrumental in the formation of a special ad hoc committee from the Governor's Office of Criminal Justice and Planning. Chief Doane stressed that there is a further need to developed treatment protocols for emergency room staff and nurses who are not familiar with treating this type of exposure. Chief Doane further contended it is imperative that law enforcement enact special policies to deal with children found at methamphetamine labs. Steps need to be in place to have each child taken to protective services for an evaluation to determine the amount of toxic exposure; officials must recommend immediate blood testing to detect toxicity in the blood of children.
What kind of interaction do you have with local lab teams? Do you work in an integrated system? In other words, can you go in and work with a lab team from Riverside?

Yes, that is normal routine. CBNE has set protocols with the local labs. Each officer must complete training before he can investigate that crime. This is standard in California.

"Pharmacology and Toxicology,"
Scott Lukas, Ph.D., Associate Professor of Pharmacology, Harvard Medical School
Precursors are substances that, in nature, might very well be inactive. However, when combined with another chemical, a catalyst, the result is a new product. There are many reasons to combine products, but usually it is to increase the activity of that product, as with precursors like ephedrine, pseudoephedrine, and phenylpropanolamine.
One can increase potency, the amount of the drug required to produce an effect. One can increase the duration of action, decrease the metabolism to prevent it from being broken down by the body, or change the profile of effects. Methamphetamine starts with an inactive or marginally-inactive compound, and other chemicals are added to produce the drug. The problem is that many of these chemicals are producing a toxicology and pharmacology that are extremely hazardous.
Natural products are anything found in the environment. Ephedrine and pseudoephedrine come from the plant ephedra, which may well become a new precursor for methamphetamine. The problem with ephedra is that it requires more labor to extract the chemical from the natural plant. It is much easier to work with synthetics.
A synthetic product is something made entirely in the laboratory with compounds not found naturally in the environment. Semi-synthetic products are modifications made to natural products, and that is what methamphetamine is. If one starts with ephedrine, or pseudoephedrine, those compounds which are found naturally, the clandestine lab operator modifies these natural products to produce a different effect.
Methamphetamine synthesis by P2P was placed on Schedule II in 1980, and its use decreased. Conversely, methamphetamine production by the ephedrine-reduction method increased. As ephedrine and pseudoephedrine became scarce, methamphetamine producers began to use another compound called phenylpropanolamine. What is important to remember is that phenylpropanolamine does not produce methamphetamine but amphetamine, which is less potent and not as effective as methamphetamine. Still, it is often sold as methamphetamine.
After 1989, a huge jump in the ephedrine-production model was observed while the P2P method declined. The ephedrine-reduction method was first observed in 1981 in southern California. Lab operators now prefer it to the P2P method for three major reasons: (1) The process is simpler to conduct, (2) the model is not as strictly controlled under the Controlled Substances Act, and (3) it produces a more potent product due to production of the D-isomer.
Understanding why some of these changes in production methods have evolved is important. Changes started because of availability but also produced more active products. The P2P method makes 50% of the L-isomer, and that isomer is important. The D-isomer and the L-isomer are like the receptors in the brain; the L-isomer only fits on one receptor, but the D-isomer fits all three receptors. Thus, if one starts with ephedrine or pseudoephedrine, more of the D-isomer is produced, and more of the drug fits into the receptor. This means the drug exerts more impact on the brain.
Ephedrine occurs naturally in many plants; it is used as a nasal decongestant and is 10 times longer acting than epinephrine. By itself, ephedrine has low central nervous system (CNS) stimulation except after extremely high doses. Pseudoephedrine has the same profile as ephedrine but even less effect on the brain. PPA was called the "look-alike" drug in the 1970s and 1980s because it was very similar in profile to ephedrine. By themselves, these drugs do not produce the kind of stimulation the amphetamines do. These "look-alike" drugs cause problems because people increase their dosage so much that they developed other organ toxicity, even heart attacks.
Clandestine labs also produce their own toxic dangers. Metals, sulfite agents and solvents are very potent compounds that can enter the CNS and cause neural damage. The P2P method is actually a dirtier method than the ephedrine-reduction method that has fewer by products (the only redeeming quality is that this is less of a chemical disaster). Cyanide is also a very potent byproduct in this process. Corrosives and irritants are usually in liquid form, but a gas form also exists. These are very dangerous compounds.
Additionally, solvents, metals and salts are highly reactive. When one mixes these compounds, explosions can occur because many of these processes involve heating. The lab operator may start with two seemingly innocuous compounds, but, after mixing, he creates a highly-explosive compound.
The three main body areas impacted by methamphetamine are the heart, cardiovascular system and brain. Skin exposure to methamphetamine production can ultimately effect the liver and the kidneys. It can also burn the skin, the eyes and the nose, and the corrosive and irritants hurt the eyes and the nose. Cyanide, through inhalation, interrupts the body's ability to metabolize. Methamphetamine has a very specific, specialized, and desired pharmacologic profile.
Its precursors have a much wider spectrum of effects as do the other compounds normally associated with its production. One is not dealing with just methamphetamine but with the pharmacology, as well. Many of these chemicals can remain in improperly-processed batches of methamphetamine, and some toxic effects of methamphetamine may be due to these contaminants and precursors.
Can you expand on cyanide as a byproduct?

These labs are not only methamphetamine labs. Some labs also dabble in other synthetic drugs, such as PCP, which produce an unintended and unknown result. For example, a cyanide byproduct may be produced from a PCP process. Often these labs cook a vat of PCP along with methamphetamine since they use many of the same chemicals. The result is a mixture of different chemical compound elements. It is difficult to state that only certain chemicals are used for methamphetamine and nothing else.

"CLANDESTINE DRUG LAB CLEANUPS: THE CALIFORNIA MODEL,"
KARL PALMER, CHIEF OF EMERGENCY RESPONSE, CALIFORNIA DEPARTMENT OF TOXIC SUBSTANCE CONTROL, SACRAMENTO, CALIFORNIA
Historically, California law enforcement managed cleanups of drug labs. In the 90s, as law enforcement resources became more constrained and lab cleanup spending increased, more cost-effective approaches had to be developed. California ultimately tasked CAL/EPA to do the cleanups and reduced the responsibility of law enforcement in this process. The state legislature sponsored a bill which gave the Department of Toxic Substances Control (DTSC) oversight of the environmental cleanup at clandestine labs. The rationale was that CAL/EPA had over 15 years experience doing environmental cleanups of all kinds, emergency cleanups, and working with state, federal and local HAZMAT agencies. It was skilled at health-based and environmentally-based cleanups. The bill passed in 1994, and CAL/EPA started the program in July of 1995.
There is an acute danger at these toxic sites. Signs posted by the Sacramento County Environmental Health Department identify the property as a clandestine lab and state, "Enter at your risk." These are not laboratories in the purest sense; they are "bucket" chemistry, literally. These sites are also dangerous because the labs are not controlled environments. Any number of solvents, precursors and hazardous agents are found in unmarked containers at these sites. The lab operators are not abiding by OSHA regulations to protect themselves or anyone else. The cookers, their families and children are living in the midst of this toxic environment.
Law enforcement and emergency-response officials are faced with extreme chemical threats: Strong acids, strong bases, sodium hydroxide (from lye and products like Draino), red phosphorus, hydriodic acid, hydrogen chloride gas, methamphetamine impurities and solvents (Freon, white gas) as well as the psychoactive drugs. Even in small quantities, exposure can have an impact on human receptors. The dangers are extreme. A lab in Carson, California, in a small motel had three fatalities. The hotel was poorly ventilated. They made a cook in the middle of the night. The people overheated chemicals, thereby creating phosphine gas, which immediately endangers life at 50 parts per million, and the incident crossed that threshold. Law enforcement may be exposed to this type of toxic threat routinely. The danger of fire and explosion risk always exists.
CAL/EPA uses its HAZMAT experience and views methamphetamine labs as hazardous waste sites requiring emergency response. It conducts an inventory of sites and abandonments, waste abandoned alongside the road or at the lab that may not have much enforcement value, yet which is toxic. EPA uses an duty officer who works closely with a CBNE agent or local law enforcement official on each lab seizure. They record what they find, and the contractor also does an inventory for law enforcement purposes. It is a very contract-management-intensive process, but it works well. Even with EPA assistance, a methamphetamine lab cleanup is still a burden on law enforcement because overseeing the scene is still necessary.
What does it cost? When CAL/EPA first started the program for the fiscal year July to June, 1995–1996, there were about $1.4 million in contractor costs. This rose to $2.5 million by year-end. This year, 1996–97, they allocated $5.1 million in contractor costs for cleanup labs. Based on this trend, CAL/EPA estimates an expenditure of $6 million in contractor costs for next fiscal year. The total program costs about $8 million dollars, including staff. It also includes $200,000 a year to train local health, fire and hazard officials about clandestine lab response, not only for safety, but to meet the needs of law enforcement. The participation of these officials, therefore, is a critical component at the local level.
How many labs are cleaned up? In calendar 1996, the agencies achieved a total of 1,313 cleanups combining State and local enforcement task forces. The DEA has cleaned up more than 100 labs, primarily in the San Diego area. About 40 labs were cleaned in July of 1995; the numbers have risen steadily each month. The largest month was February, in which there were 168 labs in a short month. In that month, CAL/EPA had a 24-hour period where 24 labs were cleaned. For May, it was 140 labs. During FY 96/97 (July-June), CAL/EPA's DTSC conducted 1,565 removal actions at clandestine labs.
Finally, a sound cleanup program requires a multi-discipline and multi-agency coordinated approach among law enforcement, task forces, HAZMAT and health officials. Since there are not enough resources to do oversight at every cleanup, CAL/EPA must rely on local health and fire officials to help with the process. Lab cleanups require more training for health, fire, HAZMAT and law enforcement personnel. State EPA must issue guidance to local agencies about procedures after a removal is completed and how they can participate in this process.
TERRY BRUBAKER, SECTION CHIEF, SUPERFUND PROGRAM,
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 9, SAN FRANCISCO
U.S. EPA conducts Superfund removal actions at large drug-lab sites where the cleanup cost exceeds available state and local resources. From this perspective, we have several concerns and observations.
First, methamphetamine labs may be associated with other illegal and hazardous activities, such as bomb making or exotic-chemical experimentation. This increases both the hazards to responders and to the complexity and cost of the cleanup. At one recent site, we expended over $150,000 to identify and dispose of thousands of small containers of such chemicals as hydrazide, picric acid and radioactive isotopes, as well as drug-lab waste.
Second, the issue of responder safety needs additional attention. Many methamphetamine labs have the characteristics of hazardous waste sites, making the invocation of OSHA standards for waste site workers at 29 C.F.R. 1910 an issue. In simplest terms, should law enforcement personnel who are first on-site be offered the opportunity or be required to analyze the risks at labs and undergo appropriate training and wear personal protective equipment? This obviously could compromise the effectiveness of the law enforcement effort if it is not intelligently interpreted. In the short term, we need to improve the awareness of the potential hazards among the law enforcement community and encourage more communication by law enforcement with fire service, HAZMAT and environmental response agencies.
Third, EPA and California are not currently funding the decontamination of structures used as methamphetamine labs. There are no standard protocols for measuring residuals of drugs and precursor chemicals, and there are no standards established for acceptable levels in living areas. From our experience in other parts of the Superfund program, interior assessment and decontamination can easily cost up to $50,000 per unit. Given that the average drug lab cleanup for chemical and gross contamination only is less than $5,000, the implications of a broader policy are obvious. At a minimum, we need to develop valid, standard ways of measuring living-area residuals and of assessing the risk from different residual levels.
What are the most serious environmental consequences of abandoned labs?

The immediate fire, explosion and direct-contact hazards presented by unstable and reactive compounds such as red phosphorus and hydrochloric acid are of first importance; these inorganics do not present a long-term threat since they break down in the environment. Chlorinated solvents are a long-term problem since they can persist in soil and groundwater for years. These are primarily localized concerns, and the quantities of waste are relatively small, but it is very important to locate and excavate burial pits early, since the longer they remain unaddressed, the more the contamination can spread. Cleanup costs are increased because solvent-contaminated soil usually needs to be incinerated.

What about contamination of residences or hotel rooms?

This is a gray area right now; officially, our position is that it is the property owner's responsibility to insure the habitability of a structure that has been used as a lab. The problem is that, once the chemicals and glassware are removed, there are no requirements or standard procedures to identify chemical residuals that may remain. Local law enforcement might not inform the health agencies of the potential problem. The first step is better and earlier communication among all the agencies. In experienced California localities, cross-notification and response is the norm.

Discussion—Questions and Comments

What are your recommendations for improvement?

What should other states know about lab cleanups?

How do we protect children found at these sites?

We need to determine training requirements for law enforcement and health officials.

The federal government needs to provide grants and discretionary funds through ONDCP.

Targeted dollars for methamphetamine-lab cleanups must be available through cooperative efforts at the multi-jurisdictional level.

We need to coordinate beyond state boundaries; federal law enforcement must help.

We need those protocols. What do we take from toxic sites, and what do we not, and what do we do with what we do not take?

Funding could include the asset forfeiture fund or another percent tax on chemicals or lab equipment.

Maybe third parties, such as hotel owners, need to generate insurance-type settlements.

There is a definite need for coordinated training and intelligence.

A national model for training is in order; officers are pleading for training.

Two kinds of training are needed; specialized expertise that an entry team needs and basic awareness training for community police.

Law enforcement and OSHA need to develop a joint-training program.

We need shared intelligence, on a regional basis and in CD-ROM format.

DEA is setting up a clan-lab database, and the National Drug Intelligence Center has a clandestine operator's handbook.

We need a clearinghouse for model programs.

The National Alliance of State Drug Enforcement Agencies (NASDEA) is a good conduit for information sharing.

Law enforcement and health personnel need to be cross-trained.

The cost of cleanups can be so prohibitive that small departments cannot afford to undertake the investigation.

Preventing labs from opening should be our priority. How can we make this happen?

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