Emerging Voluntary Guidelines for Meth Lab Cleanup

1
Emerging Voluntary Guidelines for Meth Lab
Cleanup
August 2008
Lisa A. Boynton Office of Emergency Management
(OEM) U.S. Environmental Protection Agency
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Voluntary Guidelines for Meth Lab Cleanup

• Overview
• History and background
• Purpose and scope
• Approach and considerations
• Status of guidelines process
• Timeline

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Overview

• EPA is in the process of developing Voluntary
  Guidelines for the Cleanup of Meth Labs
• Drivers include the 2006 White House Synthetic
  Drug Strategy and the 2007 Methamphetamine
  Remediation Act
• Guidelines will be established by the end of 2008

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History and Background 2006 Synthetic Drug
Control Strategy

• Document had its origins in the 2006 Synthetic
  Drug Control Strategy, which
• Aimed to improve our national understanding of
  identifying the point at which former
  methamphetamine laboratories become clean enough
  to inhabit again
• Acknowledged that, compared to first responder
  issues, a more complicated and less understood
  area of science is the optimal set and sequencing
  of response actions at former meth lab sites that
  may possess residual chemical contamination
• Tasked EPA to develop the Best Practices for Meth
  Lab Cleanup document

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History and BackgroundMethamphetamine
Remediation Research Act of 2007

• Requires EPA to establish voluntary guidelines
  based on best currently available scientific
  knowledge for the remediation of former
  methamphetamine laboratories including guidelines
  regarding preliminary site assessment and the
  remediation of residual contaminants in
  consultation with the National Institute of
  Standards and Technology (NIST)
• Considerations
• relevant standards, guidelines, and requirements
  found in Federal, State, and local laws and
  regulations
• the varying types and locations of former
  methamphetamine laboratories
• the expected cost of carrying out any proposed
  guidelines

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History and Background

• In response to ONDCPs Synthetic Drug Strategy,
  EPA began developing a document of best practices
  for meth lab cleanup
• On December 18-19, 2007 EPA convened a workgroup
  of experts from across the country to discuss the
  best practices
• As the Meth Remediation Act of 2007 was passed on
  December 21, 2007 the Best Practices document
  morphed into the Voluntary Guidelines for Meth
  Lab Cleanup document (thereby meeting both the
  charge of the White House and Congress)

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Purpose and Scope of the Document

• Provide homeowners, cleanup contractors,
  industrial hygienists, policy makers, and others
  involved in meth lab remediation with voluntary
  cleanup guidelines
• This guidance is not meant to supersede
  municipal, county, or state guidance documents or
  regulations (however this document may be useful
  to municipalities, counties, and states as they
  develop and/or review and revise their own
  guidelines)

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Approach and Considerations

• The voluntary guidelines contained in the
  document are just that voluntary they are not
  prescriptive nor are they required by law
• The document clearly refers the reader to his/her
  local and state guidelines when conducting meth
  lab cleanup
• The guidelines contained in this document are
  considered Best Practices
• The document intentionally is not a compilation
  of what every state is doing instead it focuses
  on what is generally agreed to be the best way to
  cleanup a meth lab (based on research and expert
  opinion)
• Most recommendations in the report are based on
  lessons-learned and practical experience of
  experts in the field and have not been
  scientifically vetted in labs

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Status of Guidelines Process

• Research team drafted document with findings from
  research effort and meeting of experts
  (workgroup)
• Document was reviewed by workgroup and workgroup
  members provided feedback
• Research team developed a comprehensive comment
  matrix of workgroup feedback
• EPA held a conference call with workgroup members
  to discuss the comment matrix, gather additional
  information, and determine next steps

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Status of Guidelines Process

• Document was updated based on the first-round of
  comments and a revised version was distributed
  for wider review
• EPA received feedback from workgroup members, EPA
  removal managers, ONDCP, ATSDR, ASTSWMO, and
  other stakeholders
• Research team created second comment matrix, made
  appropriate changes to the document based on
  feedback received, and created a list of
  questions to help frame discussion at this
  meeting as well as a list of potential sections
  to add to the document

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Timeline for Completion

• August 7-8, 2008 Meeting in Santa Fe
• September 2008 Interim final report out for
  review/comments
• October 2008 Literature search update
• November 2008 EPA publication process
• December 21, 2008 Final Voluntary Guidelines
  for Meth Lab Cleanup established

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Voluntary Guidelines for Meth Lab Cleanup

• Methodology and approach
• Current content
• Document status
• Outstanding issues and questions

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Methodology and Approach

• Reviewed all known state guidelines (and other
  relevant research)
• Organized information into a matrix according to
  topic (e.g., pre-remediation sampling, VOC
  sampling, wall-washing)
• Noted significant differences and potential best
  practices
• Differences identified and potential best
  practices formed the basis for discussion
  questions during the workgroup meeting

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Methodology and Approach

• In December 2007, a group of 13 external and EPA
  environmental, public health, industrial hygiene,
  and toxicology experts convened at EPA
  headquarters to
• Confirm best practices and discuss the
  discrepancies in recommended practices identified
  during the research process
• Share additional best practices based on their
  own first-hand experiences

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Content of Current Document

• Introduction
• Remediation Standards
• Remediation Sequence and Techniques
• Item- and Material-specific Best Practices
• Appendices
• Sampling Constituents, Theory, and Methods
• Primary Methods of Production and Associated
  Hazards
• List of Potential Research Topics
• State Resources and Other References
• Meeting Participants
• Acronyms

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Document Status

• Draft document was created based on research and
  discussions during workgroup meeting
• Document update was based on feedback from the
  workgroup and other interested parties
• Document was distributed to a wider audience for
  comment
• After the second review, several questions were
  raised that require attention and new sections
  for the document were proposed

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Issues to Be Addressed
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Costs Associated with Cleanup

• Add Content?
• Meth Remediation Research Act (in addition to
  feedback received) asks us to take into
  consideration the costs associated with
  implementing these guidelines.
• How can we best estimate the costs associated
  with implementing these guidelines? Is there
  existing data? What is the best way to come up
  with a figure?

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HEPA Vacuuming

• The document currently recommends HEPA-vacuuming
  the floors and structure after removing carpeting
  and flooring and vacuuming the walls and other
  hard surfaces prior to washing to remove dirt and
  cobwebs.
• Feedback received asked whether this practice can
  be recommended without conducting further
  research given
• Performance efficacy of HEPA vacuuming
• Cost and
• The potential for HEPA units to cross-contaminate
  non-related structures (especially if the unit is
  rented).

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Adjacent/Surrounding Structures

• Should adjacent units be vacated?
• Note that document currently addresses adjacent
  units in the Preliminary Assessment section
  compile a description of the site that
  includesa description of adjacent properties and
  structures.
• What additional detail is needed regarding
  adjacent structures/units?
• Should what is situated downwind of a lab be
  considered during ventilation?

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Worker Safety Health

• Feedback received questioned whether a certified
  industrial hygienist (CIH) should only be
  recommended if a state does not have a contractor
  certification process that addresses assessment,
  remediation, and sampling and that we should note
  that CIHs may be useful as independent third
  party samplers. Do you agree?
• Note Document currently states that it may be
  appropriate to involve a (CIH) in cleanup
  operations and even notes that it may not be
  cost/time effective to involve a CIH at every
  site.

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Septic System

• Further address the disposal method of wash water
  because people may dump the water into culverts
  that empty into rivers. Do you agree?
• Document advises against disposing of waste water
  in a septic system (as it may kill flora).
• Samples should be representative of the entire
  column of the septic tank because metals or
  heavier solvents may reside at the lower layers.
• Document currently states that wastewater
  sampling from septic tanks may be appropriate
  and contains detailed information on how to
  sample from the septic tank.

• Add Content?
• Include a discussion of independent gray water
  systems and the need to verify plumbing outfalls.
  Suggest that descriptions of various types of
  gray water systems should also be included, for
  example, direct to ground, 55-gallon drums,
  gravel lined pits, French drains, etc.

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Bleach

• Received several comments related to bleach
• Bleach should be forbidden if meth is used as an
  indicator for cleanliness as bleach breaks down
  meth and may make it difficult to detect even if
  other contaminants are still present.
• Explain why bleach should not be used especially
  if the Red P method of production was used? If
  this concern is based in the transformation of
  the amines, it is our understanding that amines
  are also produced in the Birch Reduction method.
• Do other peroxides/oxidizers hold the same
  potential hazards as bleach?
• Recommend using oxidizers on untreated wood, yet
  against using bleach, which is an oxidizer.

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Washing Clothing

• Received several comments advising against the
  washing of clothes
• How can it be verified that it meets cleanup
  standards?
• Does clothing pose a special risk because it is
  coming into direct contact with ones skin
  (dermal exposure)?
• Clothing tends to absorb contaminants.
• I have read several reports that contradict the
  machine washing of clothes theory. In fact, whole
  families have gotten sick from commingling
  clothes in loads.
• Note Current text reads Discard clothing or
  fabrics with visible staining or contamination.
  It is believed that machine-washable clothing may
  be safely cleaned in a washing machine. If a
  washing machine is used to wash potentially
  contaminated fabric, wash items twice, and run an
  empty load with detergent before using the
  washing machine again.

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Field Screening

• Elaborate on recommending field screening
  techniques for plumbing/septic systems.

• Add Content?
• Add guidance on field screening techniques that
  can be used to validate visual observations, such
  as pH field screen, sheen test, PID field
  screening, etc.

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Miscellaneous

• There is significant uncertainty that the
  decontamination process necessary to reduce the
  levels of meth to a protective level on surfaces
  will be sufficient to reduce the concentrations
  of other meth-manufacturing chemicals to
  acceptable levels as well.
• Much guidance is provided on the decontamination
  of countertop surfaces it would seem appropriate
  to post sample after cleaning these surfaces
  before taking more drastic measures. Years of
  experience has shown that these surfaces (wood,
  tile, granite, etc) have all shown themselves to
  be cleanable.
• Note Document currently says this is an area of
  debate and more research is needed. Document then
  lists some suggestions for specific types of
  countertops.

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Miscellaneous

• Add Content?
• Include a discussion of record review using
  available off-site resources. Potential
  information may include directions, aerial
  photos, property owner information, on-site
  structures, etc. Start new section (3.5.2, titled
  Preliminary Assessment).
• Create new section to address final
  inspection/final report documentation. Describe
  what it should contain and who should get copies.