Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

REVISED EDITION

AUGUST 2021

Voluntary Guidelines for Methamphetamine

and Fentanyl Laboratory Cleanup

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Contents

Acronyms ...........................................................................................................................................................................3

1.0 Introduction ...............................................................................................................................................................4

1.1 Background .......................................................................................................................................................................4

1.2 Purpose and Scope ...........................................................................................................................................................5

1.3 Methodology .....................................................................................................................................................................7

1.4 Potential for Future Research .........................................................................................................................................7

1.5 How to Use this Document .............................................................................................................................................8

2.0 Remediation Standards ...........................................................................................................................................9

3.0 Remediation Sequence and Techniques ............................................................................................................11

3.1 Overview of Remediation Sequence ............................................................................................................................ 11

3.2 Hiring a Contractor ........................................................................................................................................................12

3.3 Ventilation .......................................................................................................................................................................12

3.4 Worker Safety and Health ............................................................................................................................................. 12

3.5 Preliminary Assessment ................................................................................................................................................13

3.6 Pre-Remediation Sampling ...........................................................................................................................................14

3.7 Cleanup Plan ...................................................................................................................................................................15

3.8 Removal of Contaminated Materials ........................................................................................................................... 15

3.9 Waste Characterization and Disposal Procedures ..................................................................................................... 16

3.10 HighEciencyParticulateAir(HEPA)Vacuuming .................................................................................................16

3.11 Initial Wash ...................................................................................................................................................................... 17

3.12 Heating,VentilationandAirConditioning(HVAC) .................................................................................................17

3.13 Detergent-Water Solution Washing .............................................................................................................................18

3.14 Post-Remediation Sampling .........................................................................................................................................19

3.15 Encapsulation .................................................................................................................................................................. 19

3.16 Plumbing ..........................................................................................................................................................................20

3.17 Sewer/Septic ....................................................................................................................................................................20

3.18 Outdoor Remediation ....................................................................................................................................................21

3.19 Final Report .....................................................................................................................................................................21

4.0 Item-andMaterial-SpecicBestPractices .........................................................................................................22

4.1 Walls .................................................................................................................................................................................22

4.2 Ceilings ............................................................................................................................................................................22

4.3 Floors ................................................................................................................................................................................22

4.4 Kitchen Countertops ......................................................................................................................................................23

4.5 Concrete, Cement and Brick .........................................................................................................................................23

4.6 Appliances .......................................................................................................................................................................23

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

4.7 Wood ................................................................................................................................................................................23

4.8 Windows ..........................................................................................................................................................................24

4.9 Electrical Fixtures, Outlets and Switch Plate Covers ................................................................................................24

4.10 Dishes, Flatware and Other Hard Non-Porous Household Goods ........................................................................24

4.11 Toys and Other Children’s Items .................................................................................................................................24

4.12 Carpets .............................................................................................................................................................................24

4.13 Clothing and Other Fabrics ........................................................................................................................................... 24

4.14 Leather or Fabric Upholstered Furniture .................................................................................................................... 25

4.15 Maresses ........................................................................................................................................................................25

4.16 Paper Items/Books ..........................................................................................................................................................25

4.17 Mobile Residences ..........................................................................................................................................................25

5.0 PotentialSamplingConstituents,TheoryandMethods.................................................................................26

5.1 Sampling Constituents ...................................................................................................................................................26

5.2 Sampling Theory ............................................................................................................................................................27

5.3 Wipe Sampling Methods ...............................................................................................................................................28

5.4 Microvacuum Sampling Methods ................................................................................................................................29

5.5 QualityAssurance/QualityControl(QA/QC) ............................................................................................................ 29

6.0 ClandestineFentanylLaboratoryCleanup ........................................................................................................30

6.1 Background .....................................................................................................................................................................30

6.2 Prevalence ........................................................................................................................................................................ 30

6.3 Protection/Precautions/Planning ..................................................................................................................................31

6.4 Remediation Standards .................................................................................................................................................32

6.5 Remediation Techniques ...............................................................................................................................................33

6.6 Item-andMaterial-SpecicBestPractices ..................................................................................................................34

6.7 Potential Sampling Constituents, Theory and Methods ........................................................................................... 34

Endnotes ..........................................................................................................................................................................35

KeyContributors ............................................................................................................................................................37

AppendixA:PrimaryMethodsofMethProductionandAssociatedHazards .................................................38

AppendixB:CostsAssociatedwithMethLabCleanup .......................................................................................39

AppendixC:PropertiesofChemicalsAssociatedwithMeth ..............................................................................40

Appendix D: Meth Resources ......................................................................................................................................49

AppendixE:MethLabRemediationDiagrams .......................................................................................................53

AppendixF:FentanylResources .................................................................................................................................55

AppendixG:CommonFentanylAnalogs .................................................................................................................57

AppendixH:FentanylLabRemediationDiagrams ................................................................................................58

AppendixI:PhotoCredits ............................................................................................................................................60

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

AACT American Academy of Clinical Toxicology

ACMT American College of Medical Toxicology

APR Air Purifying Respirator

ASTM American Society for Testing and Materials

ASTSWMO Association of State and Territorial Solid Waste Management Ofcials

ATSDR Agency for Toxic Substances and Disease Registry

CDC Centers for Disease Control and Prevention

CFR Code of Federal Regulations

CIH Certied Industrial Hygienist

CNS Central Nervous System

DEA U.S. Drug Enforcement Administration

DEC Drug Endangered Children

DOJ U.S. Department of Justice

DQOs Data Quality Objectives

DTSC California Department of Toxic Substances Control

EPA U.S. Environmental Protection Agency

HAZWOPER Hazardous Waste Operations and Emergency Response

HEPA High Efciency Particulate Air

HHW Household Hazardous Waste

HVAC Heating, Ventilation and Air Conditioning

IH Industrial Hygienist

IHE Illicit Hazardous Environments

LGR U.S. EPA Local Governments Reimbursement Program

NACO National Association of Counties

NAMSDL National Alliance of Model State Drug Laws

NIOSH National Institute for Occupational Safety and Health

NIST National Institute of Standards and Technology

OJP U.S. Department of Justice Ofce of Justice Programs

ONDCP White House Ofce of National Drug Control Policy

OSHA Occupational Safety and Health Administration

P2P Phenyl-2-Propanone

PID Photoionization Detector

PPE Personal Protective Equipment

QA/QC Quality Assurance/Quality Control

RCRA Resource Conversation and Recovery Act

SCBA Self-Contained Breathing Apparatus

TCOs Transnational Criminal Organizations

TSP Trisodium Phosphate

TSP-PF Phosphate-Free Trisodium Phosphate

USCG U.S. Coast Guard

VOCs Volatile Organic Compounds

Acronyms

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

1.0 Introduction

1.1 Background

Theproductionanduseofmethamphetamine(meth)

across the United States continues to pose considerable

challenges to our nation. Meth is easy to make, is highly

addictive and its production and use can have serious

impacts on both human health and the environment.

Despite a decline in domestic meth production in recent

years, vigilance is warranted not only because of the

destructive nature of meth itself, but also due to the

signicantenvironmentalhazardsmethlaboratories

(labs)generate.SeeAppendix A: Primary Methods of Meth

Production and Associated Hazards and Appendix B: Costs

Associated with Meth Lab Cleanup for more information.

Ournationrstdemonstrateditscommitmentto

beerunderstandthehazardsassociatedwithmeth

labs in March 1990, when the Joint Federal Task Force

(TaskForce)publishedtheGuidelines for the Cleanup of

Clandestine Drug Laboratories(commonlyreferredtoas

the Red Book).TheTaskForcewascreatedasaresult

of Section 2405 of the Anti-Drug Abuse Act of 1988

(PublicLaw100-690)andincludedrepresentativesfrom

theU.S.DrugEnforcementAdministration(DEA),the

U.S.EnvironmentalProtectionAgency(EPA)andthe

U.S.CoastGuard(USCG).TheTaskForce’scharge

wastoissueguidelinestoassiststateandlocalocials

conducting clandestine laboratory cleanups. The Red

Book wasrstupdatedin2005andagainin2019.

DEA’s Guidelines for Law Enforcement—Cleanup of Illicit

Hazardous Environments (2019), addresses the various

typesofillicithazardousenvironments(IHEs)found

at illicit drug operations to include clandestine meth

laboratories and clandestine fentanyl laboratories.

Whereas DEA’s document focuses on law enforcement’s

response to IHEs and their responsibility for the removal

ofhazardouschemicalsandchemicalwaste(gross

contamination),thisdocumentaddressesremediation(the

cleanup of residual contamination after gross removal

hasoccurred),whichisnecessarytoallowunrestricted

future use of former clandestine drug laboratories.

In 2006, the White House Office of National Drug

ControlPolicy(ONDCP)publishedtheSynthetic

Drug Control Strategy: A Focus on Methamphetamine

and Prescription Drug Abuse (Synthetics Strategy) as a

companion to the National Drug Control Strategy. The

Synthetics Strategy acknowledges 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.”

Thus, the Synthetics Strategy tasked EPA with

identifying best practices related to the remediation of

former meth labs.

Congress passed the Methamphetamine Remediation

Act(PublicLaw110-143)inDecember2007

directing EPA to establish voluntary guidelines for

EPA’s Local Governments

Reimbursement Program

In the event of a release (or threatened release) of hazardous

substances, EPA may reimburse local governments for

expenses related to the release and associated emergency

response measures. The Local Governments Reimbursement

(LGR) Program provides a “safety net” of up to $25,000 per

incident to local governments that do not have funds available

to pay for response actions.

Under the LGR Program, costs associated with the gross

removal of meth labs and their related wastes may be

eligible for reimbursement. These costs may include overtime

wages related to hours spent securing the site or performing

decontamination, costs for equipment purchased specically

for the response and contractor cleanup costs incurred by

the local government for gross removal. However, costs

related to long-term remediation actions as described

in these voluntary guidelines (e.g., hiring a remediation

contractor, conducting pre- and/or post-remediation

sampling, developing a remediation cleanup plan and outdoor

remediation) are generally not eligible for reimbursement

under the LGR Program.

For more information, please visit the LGR website:

https://www.epa.gov/emergency-response/local-governments-

reimbursement-program

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

the remediation of former meth labs based on the

best currently available scientific knowledge. This

document, in addition to new research, serves to meet

both the Synthetic Strategy’s and the Methamphetamine

Remediation Research Act’s goals of improving “our

national understanding of identifying the point at

which former methamphetamine laboratories become

clean enough to inhabit again.”²

1.2 Purpose and Scope

EPA prepared this document to provide voluntary

cleanup guidelines to homeowners, cleanup contractors,

industrial hygienists, policy makers and others involved

in meth lab remediation. It does not set requirements,

but rather suggests a way of approaching meth lab

remediation. Those using this document should also

consult their appropriate state and local requirements

or guidelines. This document is not meant to supersede

stateandlocalrequirementsorguidelines(however,this

document may be useful to state and local authorities

as they develop and/or review and revise their own

requirementsorguidelines).EPAdidnotdesignthis

document for real estate transaction purposes. For

disclosure laws, those using this document should

consult their state and local authorities. Recognizing

theemergingthreatoffentanylandthesignicant

hazards fentanyl poses to the public, EPA updated this

document in 2021 to include a new chapter on fentanyl

remediation. This chapter can be found in Section 6.0.

The purpose and scope described above related to

meth lab remediation may be applied to fentanyl lab

remediation as well.

Tracking Former Drug Labs

DEA maintains the National Clandestine Laboratory Register,

which lists some former clandestine drug labs or dump sites.

[Note: The entries are reported by law enforcement and are not

veried by DEA.] In addition, not all former clandestine drug labs

or dump sites appear on the Register. The Register is available

at: https://www.dea.gov/clan-lab.

Some states maintain their own clandestine laboratory registries.

Please refer to your specic state for additional information.

Meth Labs

Thesevoluntaryguidelinesspecicallyaddressthe

remediation of former meth labs and the unique dangers

and hazards associated with them and may be applied

to all meth labs regardless of the manufacturing method

utilized. For the reasons listed below, no two meth labs

are alike:

• Meth labs range from crude, makeshift operations to

highly sophisticated and technologically advanced

facilities.

• Meth labs can be set up almost anywhere and

are often found in private residences, motel and

hotel rooms, apartments, trailers, automobiles,

campgrounds and commercial establishments. Labs

are also found in rural outbuildings, barns and other

structures that may appear uninhabitable.

• There are many ways to make meth, and the

precursor chemicals, by-products and hazards

associatedwitheachproductionmethoddier.

Partial Meth Labs

The manufacture of meth is a multi-stage process. In

some cases, the various steps are performed in more

thanonelaborstructure.Forexample,unreneddrug

precursors may be chemically altered in one location

andusedinthenalstepsofthemethmanufacture

processlateratadierentlocation.Labsinwhichonly

a partial step of the meth manufacturing process was

performed are called “partial labs.” The remediation

process described in this document accounts for the

possibility that precursor chemicals, in addition to meth,

may be present in the structure. While each lab should

be evaluated on a case-by-case basis, the remediation

techniques contained in this document are applicable to

partial labs.

Meth Conversion Labs

MexicanTransnationalCriminalOrganizations(TCOs)

are the primary suppliers of meth in the United States.

Manufactured on an industrial scale in Mexico, the

meth is smuggled across the Southwest Border of the

United States and is available in greater quantities and a

lower cost than product made in domestic laboratories.

Before it is smuggled into the country, the meth is often

dissolvedintoliquidsincludingvehicleuids,fuel,

water and alcoholic beverages to avoid detection. Once

across the border, the meth needs to be extracted from

the solution in which it was dissolved and recrystallized

so conversion labs are becoming more commonplace.

This process requires a variety of hazardous chemicals.

While each lab should be evaluated on a case-by-case

basis, the remediation techniques contained in this

document are generally applicable to conversion labs.

Cooking vs. Smoking Meth

Studies have shown that the smoking of meth alone

can produce levels of airborne meth that may result in

a general contamination of the structure in which it is

smoked(althoughcontaminationlevelswilldepend

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

upon how much meth was smoked and the smoker’s

technique).

While EPA originally developed these

voluntary guidelines to apply to structures in which

meth was manufactured or “cooked,” the voluntary

guidelines contained in this document may be useful

for cleaning up all sites contaminated by meth

including “smoking sites” and other “use sites.” This

may be especially relevant as the number of meth labs

in the United States where manufacture occurs has

signicantlydeclinedinrecentyears–fromahighof

23,703 in 2004 to the lowest reported in 19 years of 891

in 2019.

Despite the drop in the number of labs seized

in the United States, the abuse of meth in this country

remains high as does the likelihood of encountering

contaminated meth sites.

Fentanyl Labs

Properties may be contaminated by hazardous chemicals

used or produced in the manufacture or packaging of

fentanyl where those chemicals remain and where the

contamination has not been remediated. Procedures

for the assessment and remediation of properties or

materials contaminated with fentanyl may be most

applicable in situations where contamination of fentanyl

isknown(ordetermined)tohaveoccurred.Inthis

document, “clandestine fentanyl laboratory” means

any location involved in the illegal manufacturing or

storage of fentanyl. This may include manufacturing,

compounding, converting, producing, deriving,

processing or preparing, either directly or indirectly by

chemicalextraction,pillpressing,distribution,cuing,

diluting, synthesis or other activity that has the potential

to contaminate the property with fentanyl or any of its

precursors.

As with meth labs, law enforcement will conduct the

initial cleanup of the fentanyl-contaminated property

limited to the removal of bulk hazardous materials,

equipment and associated glassware that pose an

immediate threat to public health and the environment.

Wherefentanylproductionhasoccurred,signicant

levels of contamination may be found throughout

properties if the contamination is not remediated.

As of August 2021, there are currently no state or federal

standards in the United States for determining when

the site of a closed fentanyl drug laboratory has been

successfully remediated.

While many of the remediation considerations

and techniques for fentanyl are similar to those for

the remediation of meth, the particle size, toxicity

and production of fentanyl means a few different

procedures should be followed. These differences are

noted in Section 6.0.

Removal vs. Remediation

Making a former meth or fentanyl lab safe for

reoccupationrequirestwobasiceorts:1)theremoval

ofgrosscontamination(i.e.,containersofchemicals,

equipment and apparatus that could be used to make

illegaldrugs);and2)theremediationofinteriorstructures

and surrounding soil, surface waters and groundwater.

This document provides voluntary guidelines related

to remediation. As the Synthetics Strategy explains,

“remediation involves utilizing recognized procedures

and technology-based standards to restore former meth

labs to a state in which the property can be inhabited

again—or, instead, identifying properties that are not

yet ready for reoccupation and must undergo further

treatment.”

Remediation always occurs after gross

chemical removal, when the site is secured and is no

longer subject to criminal investigation.

Household Hazardous Waste

While the Resource Conservation and Recovery Act

(RCRA)allowsdisposalofhouseholdhazardouswaste

(HHW)inmunicipallandlls,methandfentanyllab

waste chemicals would neither be generated as waste

in normal residential households, nor generated in the

quantities that might be used in the normal activities and

maintenance of a residence. For these reasons, EPA does

not consider meth and fentanyl lab waste chemicals and

materials contaminated by those chemicals to be RCRA

exempt household hazardous wastes.

Children’s Health

Protecting children’s health from environmental risks is

fundamental to EPA’s mission. Children may be more

vulnerable to environmental exposures than adults

becausetheirbodilysystemsarestilldeveloping;they

eat more, drink more and breathe more in proportion

totheirbodysize;andtheirbehaviorcanexposethem

more to chemicals and organisms.

According to the

DepartmentofJustice(DOJ)OceofJusticePrograms

(OJP),childrenwholiveinorvisitmethlabsorare

present during drug production face acute health

and safety risks. The age-related behaviors of young

children(suchasfrequenthand-to-mouthcontact

andphysicalcontactwiththeirenvironment)increase

the likelihood that they will inhale, absorb or ingest

toxic chemicals, drugs or contaminated food. Their

physiologicalcharacteristics(suchashighermetabolic

and respiratory rates and a developing central nervous

system)leavethemparticularlyvulnerabletothe

eectsoftoxicchemicalexposures.Exposuretodrugs

and alcohol before birth places infants at increased

risk for neurological abnormalities and respiratory

problems, which may be compounded by ongoing

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

environmental exposures. Children may also have a

special vulnerability to certain harmful materials that

may be present during meth lab remediation activities,

including lead, asbestos and mercury. For these reasons,

special care should be taken when cleaning up a former

meth lab if a child lives or will live in the residence. The

same considerations related to children’s health for meth

lab remediation should be employed for the remediation

of fentanyl.

Drug Endangered Children

Many states have enacted Drug Endangered Children (DEC)

laws to protect children from the consequences of drug

production, trafcking and abuse. For more information, please

see the National Alliance for Drug Endangered Children

website: www.nationaldec.org.

Environmental Justice

EPA does not regulate the cleanup of meth or fentanyl

labs;theprioritiesforsuchcleanupsaresetbystateand

local laws. As such, concerns related to environmental

justice(anEPApriority)shouldbelefttothediscretion

of the state and local jurisdiction.

1.3 Methodology

A research team reviewed federal and state requirements

and guidelines and other relevant studies, noting

potential best practices as well as discrepancies in

recommended practices.

After this research was completed, a group convened

at EPA headquarters in Washington, D.C. in December

2007toreviewthendings,providefeedbackand

share individual opinions. The group of 13 individuals

(internalandexternaltoEPA)includedenvironmental,

public health, industrial hygiene and toxicology

professionals.Duringthemeeting,thesesubjectmaer

expertsconrmedexistingbestpractices,discussedthe

discrepancies in recommended practices and shared

other best practices based on their own experiences.

EPAusedboththendingsfromtheresearcheortand

the opinions expressed in the meeting to develop these

voluntary guidelines.

Following the meeting, this document was distributed

for wider review. EPA received comments from

the Association of State and Territorial Solid Waste

ManagementOcials(ASTSWMO),theAgencyfor

ToxicSubstancesandDiseaseRegistry(ATSDR),the

NationalAssociationofCounties(NACO),theNational

InstituteofStandardsandTechnology(NIST),ONDCP

and several other stakeholders. Updates were made

based on these comments, as appropriate.

Then, in August 2008, the National Alliance of Model

StateDrugLaws(NAMSDL)convenedaforumofits

Cleanup and Remediation Working Group in Santa

Fe, New Mexico to discuss the issues surrounding the

cleanup and remediation of properties contaminated

by meth labs. As part of the forum, working group

members provided feedback on these voluntary

guidelines and addressed outstanding questions. The

voluntary guidelines were updated as a result of this

input and other feedback from experts around the

country.

In November 2012, EPA began a process to update these

voluntary guidelines. As such, EPA solicited feedback

fromtheoriginalgroupofsubjectmaerexpertsand

other partners. The experts and partners assessed

whether the information in this document was still

accurateandrelevant,identiedotherinformationthat

might be added and discussed how these voluntary

guidelines are being used. Based on the input from the

experts, the document was revised again and distributed

for wider review during early 2013. Comments were

received from several states and other stakeholders and

additionalupdatesweremadetonalizethesevoluntary

guidelines in March 2013.

In January 2020, EPA began the process of updating

theguidelinesagaintobeerreectthecurrentstate

and to include a new section about fentanyl. Internal

and external stakeholders reviewed the document and

provided feedback and targeted comments. Based on the

input from these partners, the document was revised and

distributed for wider review. Additional updates were

madetonalizethesevoluntaryguidelinesinAugust

2021. The name of the document was also changed to

reecttheadditionofthenewfentanylchapter.

A list of key contributors to this document can be found

on page 37.

1.4 Potential for Future

Research

Because state and local approaches to cleaning up

methlabsvary,therearesometimesdierencesin

recommended practices or techniques. This variance in

opinion indicates a need for further research. In many

cases, the remediation techniques and approaches

includedinthisdocumenthavenotbeenveedthrough

rigorousscienticreview.Instead,therecommendations

are based on the lessons learned and practical experience

ofexpertsintheeld.Thesevoluntaryguidelinesmay

be augmented by EPA’s research and development, with

support from DEA, NIST and other agencies, as it is

made available.

The above also applies to fentanyl remediation. As of

August 2021, there are no state or federal standards for

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

determining when a closed fentanyl drug laboratory

has been successfully remediated in the United States.

Due to this and as on the ground situations change,

new fentanyl analogs are encountered or remediation

techniquesareimproved;thesevoluntaryguidelines

may need to be augmented by other sources and

information.

1.5 How to Use this Document

This document begins with background information on

quantitative meth remediation standards from across

the United States. Next, this document presents users

with a possible sequence of remediation activities, from

securingthesitetodeliveringthenalreport.Oncethe

processforremediationisunderstood,userswillndbest

practicesonhowtocleanspecicitemsand/ormaterials

foundwithinaformermethlab(e.g.,walls,oors,

appliances,electronics,fabrics,toys).Thisdocument

alsooersdetailedinformationonsamplingtechniques

and methods. A new chapter about fentanyl cleanup is

included as well due to increasing clandestine fentanyl lab

encounters in the United States. Special considerations are

warranted because of the toxicity of fentanyl, its physical

properties and the ability to alter the fentanyl structure

resulting in hazardous/toxic fentanyl analogs. Finally, the

appendices provide additional information and resources.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

2.0 Remediation

Standards

Due to the variety of chemicals that could potentially

be used to manufacture meth, it can be time consuming

and prohibitively expensive to sample for all of

them. In addition, many of the chemicals used in the

manufacturing process are already present in most

homes. See Appendix C: Properties of Chemicals Associated

with Meth for more information. [Note: In cases where the

manufacturing method is known to employ chemicals that

present unique hazards (such as a Phenyl-2-Propanone (P2P)

lab), testing for individual components of the manufacturing

process may be warranted.]

With this in mind, meth is often used as an indicator for

theeectivenessofcleanupactivities.Thisisbasedonthe

following assumptions:

• Bulk chemicals will be removed during the gross

removal;

• Furniture, appliances or building materials with

obviousstains(i.e.,contamination)willbediscarded;

• Many of the other potential contaminants are volatile

organiccompounds(VOCs)andtendtovolatilize

beforeand/orduringcleanup;and

• The activities needed to clean up a structure to meet

the applicable state standard for meth should be

sucienttoreduceconcentrationsofotherpotentially

hazardous chemicals as well.

EPA does not intend this document to set, establish or

promote quantitative cleanup standards. Many state

and local authorities have established quantitative

cleanup standards for meth and chemicals associated

with its production. As of August 2021, 21 states

require or recommend that meth labs be cleaned to

meet certain quantitative meth remediation standards.

Current state standards range from 0.05 µg/100 cm

to 1.5 µg/100 cm

. The most common standard is 0.1

µg/100 cm

. Additionally, 11 states have process-based

cleanup guidance materials, but no associated numerical

remediation levels. See Appendix D: Meth Resources for

more information. Those using this document should bear

in mind that state and local requirements and guidelines

change frequently.

Most state remediation standards are based on analytical

detection limits and feasibility—they are not health-

based standards. It is important to note, however, that

thesestandardsarebelievedtobesetatsuciently

conservative levels to still be health-protective.

In other

words, remediation standards are believed to account

forthescienticuncertaintyinvolvedinmethlab

remediation in the interest of protecting human health

and the environment.

In December 2007, California’s Department of Toxic

SubstancesControl(DTSC)announcedthatithad

calculated a health-based remediation standard for meth

of 1.5 µg/100 cm

InFebruary2009,DTSCnalizedthe

scienticdocumentsthatformthebasisforthishealth-

based cleanup standard. In October 2009, the new health-

based standard of 1.5 µg/100 cm

was signed into state law

as a safe level of methamphetamine on an indoor surface.

Washington adopted the 1.5 µg/100 cm

remediation

standard. Additionally, Kansas, Montana, Virginia and

Wisconsin guidance use the value of 1.5 µg/100 cm

In addition to including remediation standards for meth,

some states include quantitative standards for VOCs,

corrosives, lead, mercury and iodine. Cleanup standards

for meth and VOCs apply to all meth manufacturing

sites,regardlessofthecookingmethod(s)used.Cleanup

standards for lead and mercury are especially relevant in

instances where the P2P method of manufacturing meth

was employed.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

As of August 2021, nine states require or recommend VOC

levels of less than 1 ppm. Six states set corrosive standards

or recommend targets for surface pH of 6 to 8. [Note:

The challenges associated with pH sampling are described in

Section 5.1.] Ten states include lead standards or targets in

theirremediationguidelines;standardsandtargetsrange

from 40 µg/ft

(oritsequivalentof4.3µg/100cm

)toa

more protective standard of 10 µg/ft

(oritsequivalentof

1 µg/100 cm

).Elevenstatesincludemercurystandards

ortargetsintheirremediationguidelines;standards

and targets range from a more conservative 0.05µg/m

(equivalentto50ng/m

)to3.0µg/m

(equivalentto3,000

ng/m

)ofmercuryinair.Twostatessetaniodinestandard

or target of 22 µg/100 cm

for iodine-stained surfaces that

are cleaned rather than removed. See Appendix D: Meth

Resources for more information. These standards and

associated sampling techniques are addressed in greater

detail in Section 5.0.

Chemicals Used in Meth Production

Chemical

Commonly Sold/

Found As Usage Health Hazards

Poison

Flammable

Toxic

Vapors

Explosive

Corrosive

Skin

Absorption

Acetone Paint Thinner, Nail

Polish Remover

Solvent Reproductive disorders; skin and tissue irritation

Ammonium

Nitrate

Instant Ice Packs,

Fertilizer

Eye and lung irritant; skin irritant, permeator; ingestion of

large amounts cause stomach irritation

Anhydrous

Ammonia

Farm Nurse Tanks Reagent Freezes and burns skin; destroys mucous membranes;

causes asphyxia

Camping Fuel Coleman Fuel Solvent Skin irritation

Ether Starter Fluid Solvent Respiratory failure

Hydriodic Acid Sold commercially

as lab grade

Reagent Burns; thyroid damage; lung damage

Hydrogen

Chloride Gas

Sold commercially

as lab grade

Reagent Respiratory failure; liver damage

Hydrogen

Peroxide

First Aid Antiseptic

(3%)

Reagent Skin and eye irritant and corrosive; lung sensitizer

Iodine 7% Iodine Tincture Reagent Extremely hazardous in case of skin or eye contact

Isopropyl Alcohol Rubbing Alcohol Solvent Eye, lung and stomach irritant; somewhat hazardous in

case of skin contact (irritant, sensitizer, permeator)

Lithium Metal Lithium Batteries Reagent Burns; lung damage

Methanol HEET Solvent Blindness

Mineral Spirits Paint Thinner Solvent Eye and lung irritation

Muriatic Acid Pool Cleaner/

Concrete Etcher

Reagent Burns; toxic vapors

Pseudoephedrine Decongestant (e.g.,

Sudafed)

Precursor Unknown

Red Phosphorous Striker Plates on

Matches and Road

Flares

Reagent Irritant; produces phosphine gas

Sodium Hydroxide Drain Cleaner (e.g.,

Drano)

Reagent Burns

Sodium Metal Sold commercially

as lab grade

Reagent Eye and tissue burns; temporary hair loss

Sulfuric Acid Drain Cleaner (e.g.,

Liquid Fire)

Reagent Very hazardous in case of skin or eye contact; may

produce severe irritation of respiratory tract

Toluene Paint Thinner Solvent Hazardous in case of skin or eye contact

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

3.0 Remediation

Sequence and

Techniques

Section 3.0 suggests a remediation sequence and techniques.

3.1 Overview of Remediation

Sequence

Below is an overview of the possible sequence in which

remediation activities may occur. See Appendix E:

Meth Lab Remediation Diagrams for more information.

Each of the processes below is described in greater

detail later in this section. The sequence in this list

begins after gross removal has occurred and any law

enforcement investigation has concluded. All procedures

should adhere to the Occupational Safety and Health

Administration(OSHA)HazardousWasteOperationsand

EmergencyResponse(HAZWOPER)Standard,29CFR

1910.120 and other applicable state and local requirements

and guidelines. Gross removal includes the removal and

disposal of bulk chemicals, equipment and apparatus

(hazardouswastes)thatcouldbeusedtomanufacture

meth and typically occurs immediately following the

seizure of a clandestine lab by law enforcement. [Note:

Chemical containers, equipment or apparatus from the lab

may be left behind during the gross removal step. If these items

are encountered, stop work and contact local law enforcement

personnel (or other appropriate agencies). If law enforcement

does not need these items and they can be handled safely,

dispose of them appropriately as outlined in the Red Book.]

1. Secure the property to prevent unauthorized entry.

The structure should not be reoccupied until after

remediation is complete.

2. Hire a contractor to conduct remediation, sampling

and air monitoring.

3. Ventilate or “air out” the structure with fresh, outdoor

air[e.g.,opendoorsandwindows;usefans,blowers

and/oranegativeairunitwithahigheciency

particulateair(HEPA)ltrationsystem]toensure

worker safety and health. Continue ventilation during

the remediation process, taking steps to protect nearby

or adjacent structures from contamination.

4. Perform a preliminary assessment:

a. Conductano-siteevaluationusingrelevant

documentation.

b. Conduct an on-site evaluation.

c. Assess the need for pre-remediation and post-

remediation sampling.

5. Conduct pre-remediation sampling, if applicable.

6. Develop a cleanup plan using information from

the preliminary assessment. This should include a

decontamination plan and a waste disposal plan.

7. Remove contaminated materials. Any materials or

objects that will be disposed of should be discarded

before cleanup begins.

8. Clean the rooms and areas in the structure from the

back to the front, sealing those areas to avoid potential

recontamination and continuing through the structure.

9. Vacuumwalls,oorsandotherhardsurfacesusinga

vacuumwithaHEPAlter.

10. Completeaninitialwashingofthewallsandoorsto

remove most of the contamination.

11. Clean and seal the heating, ventilation and air

conditioning(HVAC)systematallopenings.Do

not run this system again until all other cleanup is

complete to prevent potential recontamination.

12. Flush plumbing traps.

13. Use a detergent-water solution to wash ceilings, walls,

oors,non-porousfurnitureandotheritemsthatwill

be kept.

14. Conduct post-remediation sampling, if applicable.

(Ensurestructure/itemsarecompletelydrybefore

sampling.)

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

15. Consider encapsulating washed ceilings, walls and

oorsoncetheymeetremediationrequirementsor

guidelines.

16. If wastewater from detergent-water washing is

disposedofdowndrainswithinthestructure,ushthe

system again after remediation.

17. Ventilate the structure once more after indoor cleanup

is complete.

18. Perform outdoor remediation activities.

19. Secure the property once more to prevent

unauthorized entry.

20. Preparethenalreport.

3.2 Hiring a Contractor

Hire a contractor who has hazardous waste expertise

andiscertied(ifcerticationisrequiredbythestate)to

conduct cleanup operations at known or suspected meth

labs. Several states have developed meth lab remediation

certicationprogramsforcontractors,whichhelpto

ensure remediation processes are adequately conducted.

Contractorswhohavenotbeencertiedinasimilar

program should, at a minimum, complete the 40-hour

HAZWOPERtraining(OSHA29CFR1910.120).

Itmayalsobeappropriatetoinvolveacertiedindustrial

hygienist(CIH)incleanupoperations.Somestatesrequire

thataCIHorexperiencedindustrialhygienist(IH)

conduct the preliminary assessment and post-remediation

sampling. A CIH is trained in the assessment and control

ofchemicalhazardsandcanplayasignicantrolein

ensuring that working conditions are safe during the

remediation process. It is recognized that a CIH may not

be available to accompany contractors to every cleanup

site and that the use of a CIH can be expensive if they are

involved in the entire remediation process. Therefore,

contractors may consult a CIH to establish a general meth

lab cleanup strategy. Other potential resources that may

be consulted include state and local health agencies and

environmental health specialists.

3.3 Ventilation

For the safety of on-site personnel, ventilate or “air out”

methlabswithfresh,outdoorair(byopeningdoorsand

windows, and using fans, blowers and/or a negative air

unitwithaHEPAltrationsystem)before,duringand

after the remediation process. HVAC systems should be

shutdownandremainountilremediationoftheformer

meth lab is complete.

Pre-Remediation Ventilation

Ventilate the lab prior to the entry of cleanup personnel.

In some cases, law enforcement personnel will have

already ventilated the lab before conducting criminal

investigation activity or the gross removal of chemicals.

If the lab was sealed after these activities, ventilate the lab

again before remediation occurs. Ventilation should be

performed per the contractor’s recommendation or for a

minimum of 24 hours.

While several state guidelines recommend “baking,” or

heating the structure with the doors and windows closed

topromotethevolatilizationofchemicals,itseectiveness

has not been documented. Baking is sometimes used for

the remediation of mercury, so in cases of a P2P lab, this

step might be employed. However, it is believed that

baking may mobilize and redistribute chemicals, thereby

spreading contamination. For this reason, baking is not

recommended until further research is conducted.

Continued Ventilation

It is important to continue ventilation throughout the

remediationprocess(exceptwhenitwouldinterferewith

airmonitoring).Toprotectworkersandtolimitcross-

contamination, leave windows open and use fans, blowers

and/oranegativeairunitwithaHEPAltrationsystem

during cleanup. If using fans, blowers and/or a negative

air unit, personnel should take precautions to avoid

contaminant migration to areas that were not previously

contaminated. A negative air unit equipped with a HEPA

ltrationsystemlimitsorpreventsthetransferofairborne

contamination from dirty to previously cleaned areas.

Also, take precautions to avoid contamination of nearby

or adjacent structures during all ventilation activities.

Post-Remediation Ventilation

Ventilate the property after cleanup is completed. After

completion of all cleanup activities, contractors, owners

and future occupants should be on alert for any new

stainingand/orodors(thepresenceofwhichwould

indicatethatadditionalcleaningisnecessary).

3.4 Worker Safety and Health

AllproceduresshouldadheretoOSHAHAZWOPER

Standard, 29 CFR 1910.120 and other applicable state

and local worker safety and health requirements. Do not

begin remediation work until gross chemical removal is

complete, law enforcement personnel have cleared the

structure of defense measures placed by the lab operators

(suchasanti-personneldevicesor“boobytraps”)andthe

structure has been ventilated. Use the “buddy system”

when making initial entry for remediation work, in

case unforeseen dangers are encountered. In addition,

conduct air quality monitoring to ensure the atmosphere

is safe for entry.

Personnel who enter a former meth lab should have safety

andhealthtraining(40-hourHAZWOPERtraining),and

should use the appropriate level of personal protective

equipment(PPE)basedonthesite-specicconditions.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Types and Levels of Personal Protective

Equipment (PPE)*

Level A (greatest level of skin, respiratory and eye protection) —

positive pressure, full-facepiece self-contained breathing

apparatus (SCBA), or positive pressure supplied air respirator

with escape SCBA, approved by the National Institute for

Occupational Safety and Health (NIOSH); totally-encapsulating

chemical-protective suit; gloves, outer, chemical-resistant;

gloves, inner, chemical-resistant; boots, chemical-resistant,

steel toe and shank; and disposable protective suit, gloves

and boots (depending on suit construction, may be worn over

totally-encapsulating suit).

Level B (highest level of respiratory protection but lesser level

of skin protection) — positive pressure, full-facepiece SCBA,

or positive pressure supplied air respirator with escape

SCBA (NIOSH approved); hooded chemical-resistant clothing

(overalls and long-sleeved jacket; coveralls; one or two-piece

chemical-splash suit; disposable chemical-resistant overalls);

gloves, outer, chemical-resistant; gloves, inner, chemical-

resistant; boots, outer, chemical-resistant steel toe and shank.

Level C (concentration(s) and type(s) of airborne substance(s) is known

and criteria for using air purifying respirators are met) — full-face or

half-mask, air purifying respirators (APR) (NIOSH approved);

hooded chemical-resistant clothing (overalls; two-piece

chemical-splash suit; disposable chemical-resistant overalls);

gloves, outer, chemical-resistant; gloves, inner, chemical-

resistant.

Level D (work uniform affording minimal protection: used for nuisance

contamination only) — coveralls; boots/shoes, chemical-

resistant steel toe and shank.

*OSHA Standard 1910.120, Appendix B

PPE for meth labs may include protective eye glasses,

disposable gloves, foot coverings, steel toe boots and

long-sleeved coveralls or a disposable protective suit.

Decontaminate or discard, as appropriate, all clothing and

PPE worn during remediation.

Because meth can be injected intravenously, loose

hypodermic needles may be present in a former meth lab

and may pose a danger to those involved in remediation

activities. Therefore, wear heavy work gloves and thick-

soled leather shoes when collecting and removing trash,

bedding,clothing,drapes,furniture,carpet,ooringor

materials from any location that could conceal needles.

Dispose of all needles in a labeled sharps container

following state and local requirements or guidelines.

Use respiratory protection when removing carpet and

otherooringorworkinginhighlycontaminatedareas.

Respirators also should be used if the inhalation of

sampling materials and cleanup solvents poses a threat

to human health. Never eat, drink, smoke or store food

or beverages in a former meth lab prior to or during

remediation.

3.5 Preliminary Assessment

Once the materials and equipment used in the manufacture

of meth have been removed by law enforcement, a

preliminary assessment should be conducted. The goal of

the preliminary assessment is to provide information that

will inform the development of the sampling and cleanup

plan(ifneeded).Thepreliminaryassessmentshouldbe

documentedinawriensummaryandincludearecord

review and a site survey.

Record Review

To perform the record review, coordinate with state

and local health departments and review copies of law

enforcement or hazardous waste removal contractor

reports(ifavailable)forinformationonthedurationof

lab operation, manufacturing method, chemicals found,

cooking locations, storage locations, disposal areas

and observed contamination. This information, when

coupled with the professional judgment of a cleanup

professional(e.g.,cleanupcontractor,CIH/IH),can

provide a foundation for the cleanup plan. Information

gathered from those directly involved with the meth lab

should be evaluated carefully because they may not be

reliable sources.

Based on law enforcement or hazardous waste removal

contractor reports, or on the professional judgment of the

assessor, the record review can help to:

1. Establishthecookingmethod(s)employedduringthe

manufacturing process.

2. Determine the quantities of chemicals found at the

site and types of chemicals expected to have been on-

site, based on the cooking methods.

3. Identify areas of expected contamination.

Site Survey

After compiling all available information, conduct the

sitesurveytoconrmtheinformationgatheredduring

the record review, document actual conditions of the site

and provide information for developing the cleanup plan.

Whenever possible, document conditions of the site with

photographs.

While conducting the site survey, take precautions to

ensure worker safety and health. Contamination can be

removed prior to the preliminary assessment if it poses

an imminent threat to human or environmental health.

Thestructure(s)shouldbeventilatedbeforeentry,and

assessors should wear the appropriate PPE.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Assessors should notify law enforcement personnel

(orotherappropriateagencies)ifadditionalmaterials

likely to have been used in the manufacture of meth

are discovered.

To complete the site survey:

1. Compile a description and diagram of the site

that includes: address, description and location

ofallstructures;thelayoutoftheproperty;anda

description of adjacent properties and structures. For

structures, the diagram should document the size and

locationofallrooms(e.g.,basement,aic,closets),

howtheroomsconnectandtheirexpecteduse(e.g.,

bedroom,closet).Inaddition,thelocationofdoors,

windows, the ventilation system and appliances

should be noted on the diagram. This description

shouldincludeinteriorsurfaces(e.g.,walls,ceilings,

oors,countertops)andanyfurnishingsthatremain

on-site after gross removal.

2. Document areas of heaviest contamination. These

areascouldbeidentiedbyvisibleevidenceof

contamination(suchasstaining)orbasedonthe

professional judgment of the assessor. If visible signs

of contamination do not exist, this does not mean

there is no contamination. Residual meth should be

routinely expected throughout the structure.

3. Determineorconrmthecookingmethod(s)

employed during the manufacturing process.

4. Determine the presence of other potential hazards to

cleanup personnel or future occupants including lead,

asbestosandmercurywhichmayincludespecic

health concerns in their own right.

5. Examine the ventilation system for signs of

contamination(e.g.,rust).Ifcontaminationis

suspected, sample the cold air return.

6. Examinetheplumbingsystem(e.g.,sinks,toilets,

showers,tubs,drains)fordamage.Inaddition,the

assessor should identify the type of wastewater

disposalsystempresent(e.g.,sewerconnection,septic

system).

7. Investigate any adjacent or nearby structures for

avenuesofpotentialcontamination(e.g.,common

spaces,hallways,sharedventilationsystem).Cross

contamination can often occur in townhouses, motels/

hotels, apartments or duplexes.

8. Determineifoutsidedisposaloccurred(e.g.,burning,

dumping,burying,drainagetosepticsystem)

and caused soil, surface waters or groundwater

contamination. Common signs of outside disposal

include burned or dead vegetation and stained soil.

3.6 Pre-Remediation Sampling

The decision whether to conduct pre-remediation

sampling(andforwhichconstituents)isbestmadeona

property-specicbasis.Ownersandcontractorsshould

consult state and local requirements or guidelines when

making the determination whether to conduct pre-

remediation sampling.

Pre-remediation sampling can reduce costs by

streamlining the cleanup process and identifying

materials that are too contaminated to clean and should

simply be removed. Pre-remediation sampling also can

be useful in excluding certain portions of a property from

a cleanup, such as areas to which the operators of the lab

did not have access.

If pre-remediation sampling is conducted it should

be conducted using the same protocols used for post-

remediationsampling(seeSection 5.0).

Pre-remediation sampling also may be performed for the

following reasons:

• To ensure the safety and health of those working on a

site before or during remediation.

• To establish whether contamination exceeds state and

local requirements or guidelines.

• To inform the cleanup plan and process by identifying

the extent of contamination in areas of the former lab.

• To determine which materials can be cleaned and

which should be removed. This assessment can help

lower overall cleanup costs.

• To help quantify cost estimates for cleanup.

• To sample for lead and mercury, two elements

commonly associated with the P2P method of

production, if this method was employed.

• To corroborate or augment information that law

enforcementocersgatheredfromthosedirectly

involved with the meth lab.

• To meet pre-remediation sampling requirements of

a bank, insurance agency, mortgage holder, other

private entity or state and local authorities.

• To allow for the comparison of pre- and post-

remediation samples to show the reduction of

contaminants achieved through remediation. [Note:

The same sample collection method should be used for both

pre- and post-remediation sampling if parties intend to

compare results.]

• To establish a record of baseline conditions prior to

remediation.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

In other cases, pre-remediation sampling is not required

and may increase costs. Some states assume that all areas

of a former meth lab are contaminated and require that

the entire structure be cleaned. For some structures, it is

morecost-eectivetoremediatetheentirestructurethan

totakepre-remediationsamplesinanaempttoavoid

having to remediate certain areas.

3.7 Cleanup Plan

The information from the preliminary assessment and

pre-remediationsampling(ifconducted)shouldbeused

to develop the cleanup plan. This plan will guide the

remedial actions at the site and should:

• Describe security provisions in place for the site.

• Contain a summary of all information gathered in the

preliminary assessment.

• Provide information on the contractor, project

manager and site supervisor performing the cleanup

(ifapplicable).Thisshouldincludevericationand

documentationofthecontractor’scerticationand/or

qualications.

• Contain a list of emergency contacts and telephone

numbers.

• Determine whether utilities should be disconnected

from the structure until cleanup and remediation

activities are complete and make appropriate

provisions for power needs, if necessary.

• Determine what level of PPE workers should wear

while in the contaminated portion of the site. This

section should describe any safety and health

procedures(includingpersonneldecontamination

procedures)thatwillbefollowedthroughoutcleanup.

All procedures should adhere to OSHA and other

applicable state and local worker safety and health

requirements or guidelines. The location and route to

the nearest hospital or emergency service facility also

should be noted.

• Contain a shoring plan, if structural integrity was

determined to be a concern during the preliminary

assessment.

• Describe the cleanup methods to be used, including:

– alistoftheitemstoberemovedfromthestructure;

– alistofallsurfacesoritemstobecleanedon-site;

– proceduresforcleaning;

– areastobeencapsulated;

– locationsandproceduresforon-site

decontamination;and

– containmentplansforthecleanuptoprevento-site

contamination.

• Describe the plan for waste disposal that complies

with federal, state and local requirements or guidelines

regarding materials removed from the structure. This

plan applies to hazardous waste and solid waste,

as well as wastewater. The plan should include the

name of the disposal facility and documentation that

the facility is equipped to handle the types of wastes

generated(suchashazardousmaterials).

• List any permits that will be required for the cleanup.

• Describepre-remediation(ifapplicable)andpost-

remediation(ifapplicable)samplingmethods,

including where and how many samples will be

collected and the remediation standards that will be

used.

• List the personnel collecting the samples, the name of

the analytical laboratory and the analytical methods

for the samples.

• ListQualityAssurance/QualityControl(QA/QC)

practices that will be followed.

• Contain a schedule of anticipated actions.

• Outlinethepost-remediationwalk-throughandnal

reporttodocumenttheeectivenessofthecleanup.

Once developed, the cleanup plan should be accepted by

the property owner and the decontamination contractor,

and any necessary government approvals should be

sought and received.

3.8 Removal of Contaminated

Materials

After gross removal has occurred and the structure has

been ventilated for a minimum of 24 hours, properly

discard all materials that will be removed from the lab

per the cleanup plan. [Note: If you nd chemical containers,

equipment or apparatus from the lab left behind during the

gross removal step, stop work and contact local law enforcement

(or other appropriate agencies). If law enforcement does not

need these items and they can be handled safely, dispose of them

appropriately.]

Discardanyvisiblystained,odor-emiingordamaged

materials and decide whether to clean or discard other

items on a case-by-case basis using information from

thepreliminaryassessmentandacost-benetanalysis.

Although there is no single determinant that can be used

to decide which items should be discarded and which

items can be cleaned and kept, consider the following

during the decision-making process:

Potential for Contact — Consider whether inhabitants of

the structure are likely to come into contact with the item

regularly(suchasbedding).Discardcontaminateditems

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

with a high potential for human contact more readily than

items with a low potential for human contact. Take extra

consideration when deciding whether to discard items

thatchildrenarelikelytocomeintocontactwith(e.g.,

toys,boles)aschildrenmaybeespeciallyvulnerableto

environmental toxins.

Intrinsic or Emotional Value — Weigh the intrinsic or

emotional value of the item with how much it would

costtoeectivelycleantheitem.Ifsamplingwillbe

conducted, the cost of cleanup includes the cost of

sampling to ensure the item is cleaned. In many cases it

ismorecost-eectivetodisposeofanitemandreplace

it than it is to clean it. In some circumstances, however,

itemsofgreatemotionalvalue(e.g.,weddingalbums)

may be salvaged.

Porosity — Consider the porosity of the item or material.

In general, porous items and materials are easily

penetrated or permeated by hazardous gases, liquids or

residues. Non-porous surfaces are more resistant to this

type of contamination. As a result, contamination is often

found in porous items and on the surface of non-porous

items.Thus,itisgenerallymorediculttoeliminate

contamination from porous items and materials. Because

denitionsof“porous,”“semi-porous”and“non-porous”

dier,therecommendationsinSection 4.0 are organized

according to item or material.

Considering the potential for human contact, the intrinsic

and emotional value and the porosity of an item or

material may help guide decisions as to whether the item

or material should be discarded. For example, carpet

should be discarded because it has a high potential for

humancontact(especiallysinceyoungchildrentend

tocrawlontheoor),hasrelativelylowintrinsicand

emotionalvalueandisextremelyporous(makingit

diculttosuccessfullydecontaminate).

Items Brought into a Lab After the Cook

Has Vacated

In some unfortunate cases, innocent and unsuspecting

individuals and families move into former meth labs

before the structure has been properly cleaned. These

individuals/families later discover that their home

wasalab(e.g.,bytalkingtoaneighbor,ndinglab

paraphernaliaorexperiencinghealthsymptoms,etc.),

and their belongings may be contaminated. Given these

circumstances, contents brought into a former lab after

the cook has vacated should be given special consideration.

These items are likely to be less contaminated and,

therefore, may be easier to clean.

3.9 Waste Characterization

and Disposal Procedures

Some items or materials removed from a former meth lab

maybeclassiedashazardous—dependinguponfederal,

state and local requirements—and may not be appropriate

fordisposalatalocallandll.Refertotheappropriate

federal, state and local solid waste authority to determine

what disposal procedures are necessary. Additionally,

contactthelocallandlloperatorpriortodisposalto

ensure the facility will accept the wastes.

Several state requirements and guidelines suggest that

all contaminated materials be wrapped and sealed before

they are removed from the site to avoid spreading the

contaminationtounaectedareas.Moststatesalsostress

the importance of disposing items in a manner to prevent

re-use(i.e.,salvaging).Forexample,couches,other

furniture and appliances should be physically destroyed

so that they cannot be re-used.

Bear in mind that asbestos and lead-based paint may

be present in the structure. This possibility should be

considered during the preliminary assessment, and all

suspect building materials should be properly sampled

and tested prior to disturbance or removal. If asbestos and

lead-based paint are present, and it is determined that they

should be removed, their removal and disposal should be

compliant with all federal, state and local requirements.

3.10 High Efciency

Particulate Air (HEPA)

Vacuuming

Vacuumtheoorsofthestructureafterremovingcarpets,

padsandotherooring(asnecessary),usingavacuum

withaHEPAlter.Additionally,useavacuumequipped

withaHEPAlteronwallsorotherhardsurfaces

to remove dirt and cobwebs prior to washing with a

detergent-watersolution(seeSection 3.13).Thisstepis

conducted in addition to detergent-water washing.

Use a commercial grade vacuum cleaner, equipped with

aHEPAdustcollectionsystem(HEPAlter).Bag-less

vacuum cleaners and household vacuums equipped with

HEPAlters,suchasthosepurchasedatretailstores,are

not recommended.

Several states suggest that vacuuming with a machine

equippedwithaHEPAltercanbeusedonsurfaces

thatcannotbecleanedwithdetergentandwater(e.g.,

porousmaterialssuchasupholsteredfurniture).While

vacuuming collects some particulate contamination,

it does not remove contamination entirely. Therefore,

vacuuming is not encouraged as a stand-alone

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

remediation technique but may be useful in select cases

when the decision has been made to save an item of

intrinsic or emotional value that cannot be washed with a

detergent-water solution.

While it is generally recommended that contaminated

unnishedstructuralwoodbepower-washed(and

thatawetvacbeusedtodrawoutexcesswater),

power-washing exposed wood may not be advisable

in structures susceptible to mold. In these cases, use

vacuuming as an alternative.

3.11 Initial Wash

After all materials and items that will not be cleaned have

been disposed of and the structure has been vacuumed

(withamachineequippedwithaHEPAlter),conductan

initialwashingofthewallsandoorstoremovemostof

thecontaminationusingadetergent-watersolution(see

Section 3.13).Conductingthisinitialwashwillnotonly

help to ensure the safety of those who enter the structure

(e.g.,contractors,subcontractors),butitalsowilllessen

thepossibilitythatcontaminationonthewallsandoors

will re-contaminate other areas of the structure later in the

remediation process.

3.12 Heating, Ventilation and

Air Conditioning (HVAC)

If a meth lab is in a structure with an HVAC system

orotherresidentialforcedairsystem(e.g.,kitchenor

bathroomexhausts)itcanbeexpectedthatfumes,dustand

other contaminants have collected in the vents, ductwork,

ltersandonwallsandceilingsneartheventilationducts.

It should be noted that a single HVAC system can service

multi-unitstructures(e.g.,apartments,storagefacilities),

and allow contamination to be spread throughout. To

limit this possibility, the HVAC system should be shut

downandremainountilremediationoftheformer

meth lab is complete. During the preliminary assessment,

sampling should be conducted in all areas/rooms/units

serviced by the HVAC system to determine the spread of

contamination and should be noted in the cleanup plan.

Contractors who specialize in cleaning ventilation

systems—or who have experience cleaning ventilation

systems in former meth labs—should be used to clean

HVAC systems. These contractors have specialized tools

and training to ensure thorough cleanup.

It is important to remember that not all ventilation system

ducts can be cleaned. For example, some ducts are lined

withberglassorotherinsulation(which,ifdamaged

duringcleaning,canreleaseberglassintolivingareas).

Also,exibleductworkfrequentlyhasaporousinner

surface and in most cases cannot be cleaned economically.

For this reason, the ductwork should be discarded and

replaced after the ventilation system is cleaned.

If it is determined that the HVAC system can be cleaned,

it should be cleaned early in the remediation process, after

the initial wash has been conducted. Once cleaned, the

HVAC system should be sealed at all openings to prevent

potential recontamination.

Severalstatesoerastep-by-stepexplanationofthe

ventilation system cleaning process. At a minimum, when

approaching a ventilation system constructed of non-

porous materials, ventilation contractors should:

1. Perform a walk-through of the structure to

establishaspecicplanfordecontaminationof

the ventilation system.

2. Follow safety and health procedures, in accordance

with OSHA and other applicable state and local

worker safety and health requirements or guidelines,

to protect workers and others in the vicinity of the

structure during the decontamination process.

3. Place protective coverings in areas where work is

being performed, including plastic or drop cloths

around each area where the duct is penetrated.

4. Shutoandlockoutallairhandlerunitsbefore

working on each air conveyance system.

5. Perform a visual inspection of the interior ductwork

surfaces and internal components.

6. Draw a negative pressure on the entire ductwork,

usinganegativeairunitwithaHEPAltration

system, throughout the cleaning process.

7. Remove and clean all return air grilles.

8. Clean the ventilation system using pneumatic or

electrical agitators to agitate debris into an airborne

state(beginningwiththeoutsideairintakeandreturn

airducts).Additionalequipmentmaybeusedin

the cleaning process, such as brushes, air lances, air

nozzles and power washers or vacuums equipped

withHEPAltersfollowedbywashingwitha

detergent-watersolution(seeSection 3.13).Controlled

containment practices should be used to ensure that

debris is not dispersed outside the air conveyance

system during cleaning.

9. Open and inspect air handling units, and clean all

components.

10. Removeandcleanallsupplydiusers.

11. Clean the supply ductwork using the techniques

described in item 8 above.

12. Reinstalldiusersandgrillesaftercleaningis

complete.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

13. Seal shut access points that were opened.

14. Bagandlabelalldebris,includingallairlters,and

properlydisposeofatalandll.

[Note: There are various types of forced-air systems, therefore,

the above steps may need to be modied based on the type of

system being cleaned.]

Controlling moisture in ventilation systems is one of the

mosteectivewaystopreventbiologicalgrowth(suchas

mold).Consequently,ifwetcleaningmethodsareused

(detergent-waterwashingorpower-washing),ventilation

systems need to be checked to ensure they have dried

thoroughly.

Cleaning methods should be left to the discretion

of ventilation contractors at each lab. Experts agree,

however, that no chemicals should be added to either

break down meth or disinfect ducts. Further research is

neededtodenethemosteectivemethodforcleaning

ventilation systems.

Another consideration is whether any residual

contamination in the HVAC system can re-contaminate

thestructureafterremediationiscomplete.Therstfew

minutes of system restart after cleaning is usually when

the greatest amount of dust is released. The potential

exists for this dust to cause post-remediation samples to

exceed state standards. Owners and cleanup contractors

should be aware of, and plan for, this possibility. As an

added measure of caution, the HVAC system should be

turned on prior to post-remediation sampling.

3.13 Detergent-Water

Solution Washing

Washceilings,walls,oors,furnitureandotherhousehold

items that will not be discarded with a detergent-water

solution. Most states recommend using a household

all-purpose cleaner. Follow the detergent manufacturer’s

recommendation to determine the concentration of the

solution. Cleaning should thoroughly cover the entire

surface, not just spots. The wash water does not have to

behot.Hotwaterhasnotbeenprovenmoreeectivethan

cold water for cleaning.

Where post-remediation sampling is required, the

walls should be cleaned until they meet the required

remediation standard. In states or local jurisdictions that

do not require post-remediation sampling, repeat the

cleaning and rinsing process three times before the walls

arerepainted(i.e.,encapsulated).Moststatesrecommend

cleaningfromceilingtooor.

Follow each wash with a thorough rinse using clean water

and a clean cloth rag. When washing, change cloth rags

and detergent-water solutions frequently. After washing,

dispose of cloth rags appropriately.

The use of harsh chemicals should be avoided. Consider

the following before using bleach, trisodium phosphate

(TSP),methanolandperoxide-basedproprietarycleaners:

Bleach — The interaction of bleach and meth is not

fully understood and their by-products are currently

unknown.

Until further research is conducted to

identifytheseby-productsandtheirhealtheects,

bleach should not be used as a cleaning agent in a

formermethlab.Theuseofbleachshouldbespecically

avoided if the Red Phosphorus/Hydriodic Acid method

of production was used to manufacture meth, as

thereactionbetweenbleachandiodine(usedinthis

method)couldproduceatoxicgas.

Trisodium Phosphate (TSP) — The use of TSP is

recommended by some states. TSP is a strong cleaning

agent, but it can also be irritating to the person using it.

Thereisalsoaphosphate-freeTSP(TSP-PF)thatmayoer

the power of TSP without the phosphates. It should be

noted that TSP-PF is a skin and eye irritant that may

cause burns.

Methanol — Although some states recommend using

methanol as a cleaning agent, the use of methanol should

beavoidedbecauseitproducesammablevaporsandhas

alowashpoint.

Peroxide-based Proprietary Cleaners — While some

studies indicate the use of peroxide-based proprietary

cleanersmaybeeectiveateliminatingmeth,itis

possible that the meth oxidizes to another compound.

Because it is unclear if any by-products remain after

the use of peroxide-based proprietary cleaners, the true

eectivenessofperoxide-basedproprietarycleaners

shouldbeveriedbeforetheycanberecommendedfor

cleaning former meth labs.

Wash Water Disposal

Wash water left over from the detergent-water washing

process usually will not be contaminated enough to

qualify as hazardous waste. In most cases, capturing and

testing the water before disposing of it is not necessary

(exceptinthecaseofaP2Plabwheremethproduction

uses mercury and lead and where the wash water may

poseadditionalhazards)andwillincreasecleanupcosts.

However, some states may require the testing of wash

water depending on the sensitivity of their hazardous

waste criteria. Generally, wash water can be disposed of

viathewastewatersystem(i.e.,sanitarysewer).

Sequence of Remediation to Prevent

Recontamination

While some states advocate cleaning the areas of highest

contaminationrst,itisoftenimpossibletoknowwhere

thoseareasare.Insteadofaemptingtocleanthemost

contaminatedareasrstandtheleastcontaminatedlast

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

(oralternativelytheleastcontaminatedrstandthemost

contaminatedlast),cleantheroomsandareasinthe

structure from the back to the front, sealing those areas

and continuing through the structure.

To avoid re-contaminating a room that has been cleaned,

seal the room and do not re-enter it. The room can be

cordonedoatdoorsandotheropeningsusingplastic

sheeting 4 to 6 mm thick. This practice will not only help

to minimize potential tracking of contamination into

already-cleaned rooms, but also could save time and

money spent re-cleaning areas. Taking these steps to

prevent recontamination is especially important when

post-remediation sampling will not be conducted. By

sealing each area/room after it has been cleaned, there can

bemorecondencethatrecontaminationwillnotoccur.

Cleaning Items On-site

To avoid contaminating another structure, items that will

not be discarded should be cleaned on-site. Once items

are cleaned, store the items in an already-cleaned room of

thestructure.Itmaybebenecialtobagorwrapcleaned

items in plastic to prevent recontamination. If allowed by

stateandlocalregulations,itemsmayalsobestoredo-

siteiftheyareproperlycleaned,sampled(ifrequired)and

bagged or wrapped in plastic. Do not bring items stored

o-sitebackintothestructureuntilafterthestructurehas

met remediation requirements or guidelines. Follow state

and local requirements or guidelines when cleaning or

disposing of items.

3.14 Post-Remediation

Sampling

The purpose of post-remediation sampling is to show

thatcleanupeectivelyreducedcontaminationand,thus,

the potential for exposure. Post-remediation sampling

also can verify that cleaning was completed and that

previously contaminated areas were cleaned to applicable

standards. If post-remediation samples return results

that exceed standards, the site should be cleaned again.

In some cases, when portions of the site or structure

cannot be cleaned, owners may consider encapsulation

orremovalifallowedbytheoversightagency(seeSection

3.15).Becausetheselectionofsamplingsitesgreatly

inuencestheresultsofpost-remediationsampling,

having an independent third-party conduct the sampling

may be appropriate and is a requirement in some states.

See Section 5.0 for more information.

3.15 Encapsulation

The extent to which meth and other lab-related chemicals

migrate through materials and potentially volatilize is

still unknown, though some research has shown that oil-

basedpaintcaneectivelyencapsulatemethamphetamine

contamination for up to 4.5 months.

Encapsulation should

never be used as a substitute for cleaning. However, sealing

with primers, paints and other sealants may provide a

protective barrier to help prevent the migration of volatile

chemicals to the surface of the material.

Generally, encapsulation should occur after surfaces

(e.g.,ceilings,walls,oors)havemettheapplicable

remediationstandards(i.e.,afterpost-remediation

sampling).Ifpost-remediationsamplingwillnotbe

conducted(althoughthisisnotadvised),allsurfacesand

materials should still be encapsulated after they have been

washed as thoroughly as possible.

If allowed by the oversight agency, encapsulation may be

performed before the remediation standard has been met if

the remediation standard cannot be met after at least three

repeated washings [especially in states with exceptionally

protectiveclearancelevels(suchas0.05µg/100cm

)]

oriftheremovalofthecontaminatedmaterial(suchas

concretefoundations)wouldcompromisetheintegrityof

the structure. If contamination is left in place under these

circumstances,itshouldbefullydisclosedinthenal

report and communicated to the proper authority and

property owner.

Oil-based paint, oil-based polyurethane or epoxies should

be used to encapsulate interior surfaces. To encapsulate

oors,mostexpertsrecommendtheuseofoil-based

polyurethane. It is generally recommended that a primer

thatwillnotdeteriorateovertimebeappliedrstinorder

toprovidearmbondbetweenthesurfaceandthenish

coat.Thoughnishcoatsareoftenappliedforaesthetic

purposes,theyalsooeradditionalprotection.

To achieve complete coverage, it may be necessary to

apply more than one coat of primer, paint or sealant.

Allow primers, paints or sealants to dry for the time

stipulated by the manufacturer before applying additional

coats. Further, encapsulated areas should be ventilated

thoroughly prior to sampling for meth lab wastes

remaining from the meth cooking process.

Several states recommend that products applied to

encapsulate surfaces be sprayed on and not hand-rolled.

This is a valid recommendation especially for textured

surfaces that cannot withstand physical agitation.

Initialresearchsuggeststhatsprayedonpaintbeer

encapsulates methamphetamine contamination, though

additional research in this area is warranted.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

3.16 Plumbing

Odors emanating from materials or household systems

(e.g.,plumbing,HVAC)informermethlabsmayindicate

contamination. When in doubt about the source, owners

should take precautions to protect occupant and/or

worker safety and health. Because meth chemicals are

frequently poured down the drain during active cooking,

concentrations of these chemicals may remain in the

traps of sinks and other drains. As a result, plumbing in

structuresmaybecompromisedandrequireaention

during remediation. Furthermore, plumbing connections

and outfalls for wastewater and/or gray water should be

veried.BecauseVOCsareoftencorrosiveorammable,

test plumbing for these chemicals during pre-remediation

samplingusingaphotoionizationdetector(PID).When

remediationofplumbingxturesbegins,allplumbing

trapsshouldbeushed.Ifwastewaterfromdetergent-

water washing is disposed of down drains within the

structure,thesystemshouldbeushedagainafter

remediation.

Visiblycontaminated(etchedorstained)sinks,bathtubs

and toilets should be removed and properly disposed

ofastheyarediculttoclean.Porcelainandstainless

steel,unlesspiedordamaged,maybecleanedin

the same manner as other hard, non-porous surfaces.

When staining is noted around sinks, toilets or tubs,

or if a strong chemical odor is coming from household

plumbing,theplumbingsystemshouldbeushedwith

generous amounts of water to reduce the concentration of

residual chemicals.

3.17 Sewer/Septic

Generally, meth lab waste chemicals discarded in sewer

systemsareushedfromthesystemwithinminutesor

hours of disposal. However, chemicals may remain in

the system longer if connections are on a line of very low

ow.Duringthepreliminaryassessment,itshouldbe

notediftheowinthelineislow.

Large volumes of meth lab wastes can pose a problem

iftheyareushedandendupinon-sitesepticsystems

or in privately-owned wastewater treatment systems or

thosesharedbysmallcommunities(e.g.,trailerparks,

apartmentcomplexes).Ifthereisevidencethatmeth

lab wastes may have been disposed of into the septic

systemorprivately-ownedsystem,eldscreeningof

the septic tank or privately-owned system should be

performed by an industrial hygienist, cleanup contractor

orotherqualiedperson.VOCsand/orapHthatistoo

high or too low may indicate the presence of hazardous

waste from the production process. Because some

cleaningagentskilltheoraofasepticsystem,itisnot

recommended that wastewater be disposed of in a septic

system. Evidence of waste disposal may include, but

isnotlimitedto:witnessstatements;etchedorstained

sinks,bathtubsortoilets;chemicalodorscomingfrom

plumbingorseptictank;visualobservationsofunusual

conditionswithinthetank(deadtank);orstressedor

deadvegetationintheleacheld.

Systems generally should not be pumped if they contain

onlyVOCs.However,iftheleacheldisnotfunctioning

due to wastes previously sent to the system, pumping

may be necessary. Monitoring for VOCs will determine

the proper course of action, and disposal of contaminated

material should comply with federal, state and local

disposal requirements. Wastewater sampling from septic

tanks may be appropriate in order to characterize waste

while using methods that minimize VOC losses.

Field

screening of septic systems should include pH testing

which may provide an indication of potential issues with

theleacheld.Fieldscreeningshouldbeusedtoevaluate

septic system contamination and should follow the steps

described below:

1. Priortosampling,sucientlyevaluatetheseptictank

to determine whether the tank consists of one or two

chambers.

2. Removetheaccesscoverfromtherst(oronly)

chamberandlocatetheoutletbae.

3. Moveanyoatingsurfacemaerawayfromthe

insertion point of the sludge sampler. Do not collect

anymaerinthesludgesampler.

a. For sampling locations in tanks with one chamber,

collectsamplesfromthebaeontheoutletendof

the chamber.

b. For sampling locations in tanks with two

chambers,collectsamplesfromthebaeonthe

outlet end of chamber one.

4. Follow instructions for correct usage of a sludge

sampler.

5. Insert the sludge sampler into the tank, lowering it

untilyouhittheboom.

6. Trap the sample inside the sludge sampler.

7. Removethesludgesamplerandlltwo40mLvials.

8. Samples may be taken without preservative or with

preservative in the vial. Sampling procedure is

determinedbythesampler’scondenceandabilityto

maintain sample integrity.

9. Place sample containers in a cooler with enough ice or

ice packs to maintain a temperature of 4° C.

10. Replace the access cover.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Remediation of septic systems should occur at the

end of the remediation process in order to ensure that

any chemicals disposed of into the septic system are

appropriatelyremoved.However,iftheleacheldisnot

functioning, remediation of the system should occur as

soon as possible, and no wash water or wastes should be

added to the system.

3.18 Outdoor Remediation

Meth cooks often discard waste chemicals outside the

structure. For this reason, the preliminary assessment may

include some outdoor sampling, especially if the ground

isvisiblystainedorotherwiseaected(e.g.,odors,burn

piles,deadvegetationorremnantsofreactionwaste).If

burn or trash pits, discolored soil or dead vegetation are

found, refer to state and local requirements or guidelines

(relatedtohazardousand/orsolidwaste)todetermine

the appropriate authority and/or agency responsible for

outdoor remediation.

3.19 Final Report

Analreportshouldbepreparedtodocumentthatthe

property has been decontaminated per applicable state

and local requirements or guidelines before the structure

can be considered acceptable for re-occupancy.

All inspections and assessments conducted during the

remediation process should be fully documented in

writing. The report should include the dates that activities

were performed and the names of the people/companies

who performed the work. Photographic documentation

of pre- and post-decontamination property conditions

and all sample locations also should be included. Any

documentssuchasdrawings,handwriennotesand

photographs should be signed, dated and included as part

of these cleanup records.

Thenalreportshouldinclude,ataminimum,the

following information:

Introduction — The introduction should include a

case narrative, site description and site assessment.

This information should have been collected prior

to the start of remediation during both the record

review and site assessment. The information should be

documentedinthePreliminaryAssessment(seeSection

3.5).Thetypeofinformationanddocumentationin

this section should include:

• Physical address of property, number and type of

structures present and description of adjacent and/or

surrounding properties.

• Law enforcement reports, documented observations

andpre-remediationsamplingresults(ifpre-

remediationsamplingoccurred)thatprovide

information regarding the manufacturing method,

chemicals present, cooking areas, chemical storage areas

and observed areas of contamination or waste disposal.

• Cleanupcontractor,CIH/IHorotherqualied

environmentalprofessionalstatementofqualications,

includingprofessionalcerticationanddescriptionof

experience in assessing contamination associated with

meth labs.

Methods—Thissectionofthenalreportshould

document cleanup and disposal activities. The cleanup

plan(seeSection 3.7)anddocumentationthatcleanup

was carried out according to the plan should be

incorporated in this section. The type of information and

documentation in this section should include:

• Worker safety and health information.

• Decontamination(e.g.,removal,encapsulation)

procedures for each area that was decontaminated.

• Waste management procedures, including handling,

naldispositionofwastesandwastedisposalrecords.

Results —Thissectionofthenalreportshould

document that the structure was cleaned to acceptable

levels. The type of information and documentation in this

section should include:

• A sampling plan, including sample collection,

handling and QA/QC.

• A description of the analytical methods used and

laboratory QA/QC requirements.

• Awriendescriptionofthelocationandresultsof

post-decontamination samples, including landmarks

for referencing individual sample locations.

• References to appropriate state and local requirements

or guidelines.

• Samplingresults,inwriting,certiedbythelaboratory

that performed the analyses.

Thenalreportshouldbesignedbythecleanup

contractor,CIH/IHorotherqualiedenvironmental

professionalwhoprepareditandsubmiedtothe

appropriate state and local authority. The property owner

and decontamination contractor should each retain a

copy of the report. The report may be reviewed by the

appropriate state and local authority responsible for

deeming the property suitable for re-occupancy. Decisions

about re-occupancy are made by the appropriate state and

local authority.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

4.0 Item- and Material-

Specic Best Practices

Section 4.0 provides possible best practices.

4.1 Walls

Removeandreplacewallsurfaces(especiallythosemade

ofabsorbentmaterials,suchasdrywallorplaster)that

showvisiblesignsofstainingorareemiingchemical

odors. Exceptions may be made if removal of the

contaminated material threatens the integrity of

the structure.

Cleansmooth,paintedwalls(i.e.,thosewithout“popcorn”

texture)usingadetergent-watersolution(seeSection 3.13).

Aftercleaning,conductpost-remediationsampling(if

applicable)andencapsulatewalls(seeSection 3.15).

Before textured walls are cleaned or removed, they

should be sampled for asbestos. Textured walls that do

not contain asbestos should be washed with a detergent-

water solution and encapsulated. If asbestos is present but

methisnot(orithasbeencleanedtoanacceptablelevel),

several states suggest sealing the surface with a spray-on

asbestos encapsulation product. If the wall meets neither

theremediationstandardformethnorasbestos,acertied

asbestos abatement contractor should remove

the material.

Removeanyabsorbentbuildingmaterial(suchas

insulation)thatshowsvisiblesignsofstainingoris

emiingchemicalodors.

4.2 Ceilings

Ceilings contain some of the heaviest concentrations

of residual meth. Although they have a low potential

for human contact, ceilings should be cleaned

thoroughly in case they are disturbed in the future.

Whenpresent,ceilingfansshouldalsobecleaned(or

discarded).Anyceilingsurfacethatshowsvisible

signs of staining or is emitting chemical odors should

be removed and replaced.

Smooth, painted ceilings that were not removed should

be washed with a detergent-water solution and then

encapsulated(seeSections 3.13 and 3.15).Encapsulating

ceilingsshouldnotbeusedasaninitialaempttoreduce

meth levels below clearance standards. The exception to

thisaresurfacesthatarenotamenabletocleaning(suchas

textured“popcorn”ceilings).

Textured(i.e.,“popcorn”orspray-on)ceilingsshould

be sampled for asbestos and meth contamination.

Textured ceilings that do not contain asbestos should be

encapsulated.

Becauseceilingtiles(suspendedoraached)arerelatively

inexpensive, discard tiles that show visible signs of

contamination or that were in areas of suspected high

contamination. Tiled ceilings should be sampled for

asbestos.

For both textured and tiled ceilings, if asbestos is present

and decontamination would disturb the material,

several states suggest sealing the surfaces with a spray-

onasbestosencapsulationproduct.Acertiedasbestos

abatement contractor should be consulted, following state

and local requirements or guidelines.

4.3 Floors

Beforeremovingorcleaningoors,considerthetype

ofmaterialfromwhichitwasmade.Resilientooring

such as sheet, laminate or vinyl tile can be kept unless

it is stained or melted. [Note: Vinyl ooring or underlying

mastic may contain asbestos. If it is removed, removal and

disposal should be compliant with all federal, state and local

requirements.] Porousooringmaterial,suchascorkor

unnishedwood,shouldberemovedanddiscarded.

Considerdisposingofoorsinhigh-tracareas,even

when distant from cooking areas, as they often contain

high levels of contamination.

Afterremovinganyprimaryooring(e.g.,carpeting,

vinyl,laminate)vacuumwithamachineequippedwith

aHEPAltertoremovecontaminateddustandother

debrisfromthesub-ooring.Inaddition,conductan

initialwashingofsub-ooringwithadetergent-water

solution(seeSection 3.13)priortobeginningthecleanup

of the rest of the structure.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Washoorsthatwillnotbereplacedwithadetergent-

watersolutionandre-sealtheoorswithaproductsuch

as polyurethane. Do not cover potentially contaminated

ooringwithnewooring,asthisremediationapproach

does not prevent unrestricted future use of the structure.

If ceramic or stone tiles are not removed, they should

be washed with a detergent-water solution and then

re-glazed depending on the porosity of the tile. It is

recommended that grout be ground down, re-grouted

and then sealed, or at a minimum, encapsulated with an

epoxy-based sealant.

4.4 Kitchen Countertops

Because kitchen countertops have high potential for

human contact and are food preparation surfaces, there

is debate as to whether they should be automatically

discarded or whether they can be kept as long as they meet

remediation standards. Thus, further research is needed to

determinethemigrationpotentialofmeth(andprecursor

chemicals)throughcommontypesofkitchencountertops.

Currently, several states suggest the following for various

types of countertop materials:

• All countertops with visible signs of contamination

(e.g.,etched,stained,emiingodors)shouldbe

discarded.

• Countertopsmadeofporousmaterials(e.g.,wood,

granite)shouldbediscarded.

• Countertops made of non-porous, solid materials can

be sanded down and washed with a detergent-water

solution(seeSection 3.13).

• Countertops made of stainless steel can be washed

with a detergent-water solution.

• Countertops made of ceramic and stone tile should

be removed when in high-contact areas. If ceramic or

stone tiles are not removed, they should be washed

with a detergent-water solution and possibly re-glazed

(dependingontheporosityofthetile).Ataminimum,

grout should be encapsulated with an epoxy-based

sealant or ground down, re-grouted and then sealed.

4.5 Concrete, Cement and

Brick

Exposed painted or unpainted concrete, cement and brick

shouldbewashedwithadetergent-watersolution(see

Section 3.13).Moststatesalsorecommendpower-washing

concrete and cement as long as a water collection system

such as a wet vac is used to absorb excess moisture.

Because brick is an especially pervious material, it can

absorb cleaning solutions used in the wet cleaning

method. [Note: It may not be possible (even following adequate

remediation) to achieve a neutral pH with concrete since it is

normally very basic.]

Other states discuss the use of HEPA microvacuums

rather than wet cleaning methods. However, HEPA

microvacuuming is very time consuming and does not

removecontaminationentirely(seeSection 3.10).

In areas of suspected high contamination, the removal

of concrete, cement and brick materials should be left to

the discretion of the cleanup contractor if the removal

could impact the integrity of the structure. In such

cases, encapsulation methods can be used after washing

procedures to add an extra layer of protection.

4.6 Appliances

Discard all appliances, electronics and tools that show

visible signs of contamination. Also dispose of large

and small appliances that could have been used in the

productionofmethorstorageofmethproducts(e.g.,

refrigerators, stoves, ovens, microwaves, hotplates, toaster

ovens,coeemakers).Inordertoprotecthandlersat

waste or recycling facilities who may come into contact

with appliances, the outside of appliances should be

washed before the items are discarded. Be sure to render

appliances unusable so that they will not be salvaged even

if they are brought to a recycling facility.

It is generally agreed that large appliances, electronics

and other tools should be evaluated on a case-by-case

basis. Further research is needed to determine whether

it is safe to continue to use appliances that were in a

former meth lab. Some states suggest washing with a

detergent-watersolution(seeSection 3.13)theexteriors

and interiors of large appliances that were not exposed

to high concentrations of meth and show no visual

contamination. All appliances with insulation should be

sampled and discarded if clearance standards are not met

(e.g.,dishwashers,refrigerators,storagefreezers).

Sampling and cleaning inside motors and circuitry

ofappliancesorelectronicsisextremelydicultand

expensive;therefore,itisusuallymorepracticaltodiscard

theseitemsthantoaempttosalvagethem.

4.7 Wood

When deciding whether to discard or clean wooden

materials or items, consider the porosity, the degree

ofexposure(e.g.,awoodenhandrailvs.asectionof

wainscotinghighonthewall),levelofcontaminationand

thequalityofthenish.Asageneralprinciple,discard(in

amannertopreventreuse)anywoodensurfaceoritem

thatshowsvisiblesignsofcontamination(e.g.,etched,

stained,emiingodors).

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

If wooden materials or items are not discarded, wash the

itemsusingadetergent-watersolution(seeSection 3.13).

Additionally, cleaned surfaces should be encapsulated

with a non-water based sealant.

Untreated wood will absorb moisture if detergent-water

washing or power-washing techniques are used. To

prevent the growth of mold, be sure to collect excess

waterusingawetvactodrytheunnishedwood.

Encapsulate the wood after cleaning and sampling.

4.8 Windows

Window glass can be cleaned at the same time as

walls. Glass should be triple-washed using a standard

household glass cleaner. Clean cloths and solution should

be used for each washing.

Wooden trim and hard plastic trim and tracking should

bewashedwithadetergent-watersolution(seeSection

3.13)andsealed.Ifwindowtrimcannotbeadequately

cleaned it should be removed and replaced.

4.9 Electrical Fixtures, Outlets

and Switch Plate Covers

It is generally agreed that electrical outlet covers and wall

switch plate covers should be replaced. These items are

low in cost, tend to be high collection points for meth and

have great potential for repeated human contact.

Ifelectricalxturesarenotdiscarded,washthemusing

adetergent-watersolution(seeSection 3.13).Shuto

powerbeforeremovingelectricalxtures,outletcovers

and switch covers. When using wet cleanup methods for

electricalxtures,ensurethatelectricalcontactpoints

donotgetwet,andthatthexturesarecompletelydry

before reassembly.

4.10 Dishes, Flatware and

Other Hard Non-Porous

Household Goods

Dishes,atwareandotherhardnon-poroushousehold

goods including ceramics, hard plastics, metals and

glass should be discarded to prevent reuse if they show

any signs of having been used during the meth cooking

process(e.g.,etched,stained,emiingodors).

Disposeofallplasticinfantboles,nipplesandany

infant/toddler eating utensils or dishes in a manner to

prevent reuse, regardless of their contamination level.

Usingadetergent-watersolution(seeSection 3.13)wash

all items made of ceramic, metal, hard plastic or glass that

were not used in the meth cooking process.

4.11 Toys and Other

Children’s Items

Infant toys that have the potential to be placed in the

mouth(e.g.,teethingring,pacier,rale)aswellas

anytoysthatshowvisiblesignsofcontamination(e.g.,

etched,stained,emiingodors)shouldbedisposedofin

amannerthatpreventsreuse.Stuedanimalsandother

poroustoysareverydiculttocleanandshouldbe

discarded. It is generally agreed that toys made of metal

or hard plastic may be washed using a detergent-water

solution(seeSection 3.13).Thedecisiontodecontaminate

or dispose of softer plastic toys, items with electronic

features or toys that have small crevices should be left

tothediscretionofthecleanupcontractor(butdisposal

ishighlyrecommended).Exceptionscanbemadefor

medicalitems(e.g.,eyeglasses,articiallimbs)iftheyare

eectivelycleanedtotheprescribedclearancelevels.

4.12 Carpets

Remove all carpet and discard it in a manner that prevents

reuse. Do not vacuum, steam-clean or shampoo carpet.

Carpet should be discarded rather than cleaned because it

isextremelydiculttoremoveallthecontaminationfrom

thebersandweaveofthecarpet.

Additionally,carpetpaddingandooringbeneath

carpet in a former meth lab are often contaminated.

Leaving the carpet in place could pose a threat to future

occupants who may decide to remove the carpet and

unknowingly come into contact with this contaminated

paddingorooring.

4.13 Clothing and Other

Fabrics

Discard clothing or other fabrics with visible staining or

contamination. Machine-washable clothing may be safely

cleaned in a washing machine.

If a washing machine is

used to wash potentially contaminated fabric, consider

the following:

• Use the washing machine available on-site. Do not

washcontaminatedfabrico-site.

• Run an empty load before washing the fabric.

• Wash fabric three times in small- to medium-

sizedloadsusingthecycleseingthatisnormally

recommended for the fabric type.

• Use a standard laundry detergent. Do not use

detergents with bleach, oxidizing detergents or fabric

softener.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

• Do not dry items between washes. After washing

itemsthreetimes,bagtheitemsandtakethemo-site

to dry.

• Run an empty load after contaminated items have

been washed before using the washing machine again.

Discard non-machine-washable fabrics in a manner that

prevents reuse. In some cases, exceptions may be made

for items of intrinsic value, such as a wedding dress, if

the owner understands and accepts the risk associated

with keeping it. Do not dry clean items, as doing so could

contaminate other people’s clothing.

4.14 Leather or Fabric

Upholstered Furniture

Discard upholstered furniture. In some cases, however,

furniturecanbestrippedofitsupholstery(including

cushions)andcleanedlikehardfurniturewithadetergent-

watersolution(seeSection 3.13).Destroyfurniturebefore

discarding it to prevent it from being reused.

4.15 Mattresses

Whilemoststatessuggestthatmaressesshouldbe

discarded,somenotethatamaresscanbesavedwhen:

• pre-remediation samples indicate low levels of meth in

thestructure;

• themaresswasfarremovedfromtheareaofcooking;

and

• themaresswasnotinaroomservicedby

the same HVAC system as the room in which meth

was cooked.

4.16 Paper Items/Books

Discard paper items and books found in the former

meth lab. Exceptions may be made for important legal

documents or photographs, papers or books of

historical value.

4.17 Mobile Residences

Mobile residences should generally be cleaned like any

otherstructureidentiedasamethproductionsite.

However, past experience with the cleanup of mobile

homes,campersandothermobileresidences(suchas

vehicles)indicatethattheymaycontainmoreporous/

absorbentmaterialsthanxedstructures.Forthisreason,

in some states, it has been found to be cost-prohibitive to

clean mobile residences. Demolition may be considered a

morecost-eectiveoption.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

5.0 Potential Sampling

Constituents, Theory

and Methods

5.1 Sampling Constituents

Sampling for meth is the most common way to establish

whether portions of a structure are contaminated.

Moststatessuggestpropertyownershireaqualied

environmental or health professional to conduct sampling

and testing. Because every meth manufacturing site is

unique,samplingplanswilldierandshouldbetailored

toeachspeciccase.Inmostcases,samplesformethare

collectedbywipesampling;however,manystateshave

established requirements or guidelines that dictate the

sampling methodology. In all cases, persons collecting

samples should use approved sampling methods as

prescribed by federal, state and local government agencies

(includingEPA,NIOSHandOSHA).Somestatesrequire

sampling for other constituents described below.

Volatile Organic Compounds (VOCs)

VOCsareemiedasgasesfromcertainsolidsorliquids.

VOCs include a variety of chemicals, some of which may

Quantitative State Remediation Standards

VOCs

States that set VOC standards for VOC air monitoring in their

remediation guidelines set the standard at less than 1 ppm.

States that set corrosive standards in their remediation

guidelines set a surface pH standard of 6 to 8.

Mercury

State standards range from 50 ng/m

to 3.0 µg/m

of mercury

in air. One state has a surface standard for mercury of 0.0054

µg/100 cm

Lead

State standards range from 40 µg/ft

(or its equivalent of 4.3

µg/100 cm

) to 10 µg/ft

(or its equivalent of 2 µg/100 cm

Meth

State standards range from 0.05 µg/100 cm

to 1.5 µg/100 cm

The most common standard is set at 0.1 µg/100 cm

See Appendix D: Meth Resources for links to individual state requirements

and guidelines.

havebothshort-andlong-termadversehealtheects.

VOCsareemiedbyawidearrayofchemicalsfound

in former meth labs, which include but are not limited

to: acetone, benzene, ether, freon, hexane, isopropanol,

methanol, toluene, Coleman fuel, naphtha, ronsonol

and xylene.

Monitoring for VOCs should be done for indoor air

quality(intheadultandchildbreathingzones),inthe

plumbing and/or septic system and over outdoor areas

with suspected soil contamination. VOC monitoring

should be conducted using a PID. Some states suggest

usingaSummacanisterforairmonitoring;however,

Summa canisters are expensive and sensitive enough

to detect compounds from normal household cleaning

activities,makingtheresultsdiculttointerpret.

pH is a term used to indicate the corrosiveness of a

substance as ranked on a scale from 1.0 to 14.0. Corrosives

commonly found in former meth labs include, but are not

limited to: hydrochloric acid, hypo phosphorous acid,

sodium hydroxide, sulfuric acid, anhydrous ammonia,

phosphoric acid and other common acids and bases. pH

samplingshouldbeusedtoconrmthatlevelsofacids

and bases do not pose a health hazard. pH sampling

should be conducted during pre-remediation sampling

and is done onsite with pH paper.

pH testing should occur on food preparation countertops,

stainedmaterials(wherethereisvisiblecontamination)

and anything that leads to the septic system. pH testing

should also occur within the septic system, on at least

three locations in each room within the areas with visible

contamination and within areas known to have been used

for storage or handling of chemicals. [Note: It may not be

possible (even following adequate remediation) to achieve a

neutral pH with concrete since it is normally very basic.]

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Lead, Mercury and Asbestos

Lead and mercury are commonly associated with

labs where the P2P method was used to produce meth.

If the P2P method was used, it is recommended to sample

for airborne mercury and take surface samples for lead.

In addition, former labs where meth is known to have

been manufactured for several years should be tested

for lead and mercury. Sampling for these constituents

may be complicated because lead-based paints may be

present in structures built prior to 1978, and mercury can

be found in structures built prior to 1990. A variety of

common household items also can contain small amounts

of mercury.

When conducting sampling for lead and mercury, be

sure to test the plumbing and septic systems, in addition

to the structure. If either mercury or lead is detected in

pre-remediation sampling, test for it after completing

cleanup activities.

Asbestos can be found in a variety of construction materials

in homes and other structures. Many construction products

on the market today still contain asbestos. In cases where

portionsofthestructure(e.g.,walls,oors,ceilings)will

be removed, an asbestos survey should be performed.

If a structure has a sprayed-on, “popcorn” ceiling, it

should be sampled for meth-related contamination. If not

contaminated, it should be left intact and/or encapsulated

because of the potential presence of asbestos.

[Note: When removing any materials contaminated with lead

or mercury, federal and state disposal requirements should be

followed. In addition, materials removed from the site should be

tested for asbestos per federal and state requirements.]

Iodine and Red Phosphorous

Sampling for iodine and red phosphorous generally is not

necessary, since these chemicals leave visible stains that

should be detected during the site survey. In most cases,

surfaces or appliances that are visibly stained will be

removed and will not need to be sampled.

5.2 Sampling Theory

When conducting sampling for meth contamination,

follow an authoritative sampling approach. This process

does not assign an equal probability of being sampled

to every part of the structure. Instead, authoritative

sampling targets areas suspected to have the highest

levels of contamination. The validity of this sampling

method depends on the professional judgment,

knowledgeandqualicationsofthepersonconducting

the sampling, who should have a detailed understanding

of the individual site conditions and the suspected

manufacturing method.

Several states reference two methods of authoritative

sampling, both of which are described in ASTM D631198

(2003),Standard Guide for Generation of Environmental

Data Related to Waste Management Activities: Selection and

Optimization of Sampling Design. A description of the two

methods, biased sampling and judgmental sampling, follows:

Biased sampling seeks to identify the “best” and “worst”

locationsatthesite,ratherthanndtheaverage

concentration of contamination. By sampling at

locations that are highly suggestive of contamination

(e.g.,cooksites,spillsites),thisapproachhelpsidentify

the maximum levels of contamination expected to be

present at the site. Biased sampling also is useful in post-

remediation sampling, since samples will be taken at the

locations known or expected to be most contaminated

before a site meets standards for reuse.

Judgmental sampling relies heavily on the experience of the

person conducting the sampling to gauge the “average”

concentration of contamination present in the structure.

Judgmental sampling can be useful if the person

conductingthesamplinghassucientinformationon

the former manufacturing activities at the site and the

necessary experience to select appropriate sampling

locations. Judgmental sampling can become less accurate

when only partial or incomplete information exists about

past activities at the site or when the person conducting

the sampling intentionally or accidentally selects

sampling locations that misrepresent the site.

Hypothesis Testing

Both biased and judgmental sampling should be

informedbydataqualityobjectives(DQOs).DQOs

establish the type, quality and quantity of data needed

and specify tolerable levels of potential decision errors.

DQOs should be established before environmental data

collection activities begin. Sampling plans should be

designedtomeetDQOs,becost-eectiveandminimize

the likelihood of error. [Note: For additional information on

QA/QC see Section 5.5.] Each sampling plan should set

forth a hypothesis, and sampling should be conducted to

either prove or disprove that hypothesis. The hypothesis

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

initiallysetforthwillbedierentforpre-remediationand

post-remediation sampling.

For pre-remediation sampling, the hypothesis being tested

is that the site is clean and that there is no evidence of

meth or its production. To test this hypothesis, a sampling

plan is devised to answer the question, “Is there evidence

of the presence of meth production in this area?” All data

gathered will be weighed against this question, including

information from the preliminary assessment as well

as samples collected. Data that disprove the hypothesis

suggest that the area is contaminated with meth or other

associated materials.

In post-remediation sampling, the hypothesis is that

the site has not been thoroughly cleaned. The owner or

contractor will seek to prove, through biased sampling,

that the site contains contaminant levels that exceed the

relevant standard. As the site is cleaned, the hypothesis

willbecomemorediculttoprove;instead,thesitewill

prove to be compliant. Once every habitable structure

on the site is deemed compliant, the site can be released.

Post-remediation sampling can be used as an oversight

mechanism to ensure cleaning was adequate. Post-

remediation sampling can also provide owners with a

liability shield, quantifying that the structure meets the

applicable standards.

5.3 Wipe Sampling Methods

Wipe sampling is the most often recommended method for

sampling surface concentrations of meth. There are two

conventional methods for wipe sampling: discrete and

composite.Inmanyremediationeorts,acombinationof

both composite and discrete sampling will be needed.

In discrete sampling, also known as “individual” sampling,

single samples are taken at spatially discrete locations.

This sampling technique should be used in areas that are

“hot spots” highly suggestive of contamination. Discrete

sampling should be performed in areas where there is a

highprobabilityofexposure(e.g.,countertops,ventilation

systems).

In composite sampling, multiple discrete samples are

combined and treated as a single sample for analytical

purposes. This sampling technique can be useful because

itismorecost-eective.Compositesamplingstrategies

should be used when the distribution of contamination is

expected to be homogeneous. Composite sampling can be

usedonpersonalitems(e.g.,furniture,photoalbums)and

other belongings that the owner would like to save.

NIOSH wipe sample methods 9106 and 9109 could be

consulted for additional information.

Many jurisdictions have prescribed methods for collecting

wipesamples.Beforeconductingasamplingeort,be

sure to consult and comply with applicable state and local

requirements or guidelines. In general, collecting discrete

wipe samples for surface meth contamination includes the

following steps:

1. Documentthearea(s)ofthestructuretobesampled

in a map or sketch.

2. Make a template of each individual area to be

sampled. This template should be made with chalk,

maskingtape,Teonoranothermaterialthatwillnot

contaminate the sample and is resistant to the solvent

being used. Most guidance documents suggest a

minimum sample area of 100 cm

3. Use a new set of clean, non-powdered impervious

gloves for each sample collected.

4. Wet the sample media with solvent.

5. Pressrmlywiththesamplemedia,usingcaution

to avoid touching the surface within the template.

Smoothsurfacesshouldbewiped;roughsurfaces

shouldbebloed.

6. When wiping the sampling area, two methods may

be used:

a. The square method involves wiping in a square

around the outside edge of the sample site and

wiping in concentric squares towards the center.

b. The “S” method involves wiping from side-to-

side in an overlapping “S” motion until the entire

sample surface is covered.

7. Fold the sample media with the sampled side in

without allowing the media to contact any other

surfaces.

8. Repeat the wiping method with the folded sample

media. If using the “S” method, wipe from top-to-

boomonthesecondpass.

9. Again, fold the media in half with the sampled side

in. Seal the sample media in a sample container and

label with the sample number and location.

10. Collect at least one sample media blank for every 10

samples collected. This media should be treated with

solvent and folded but not wiped.

For composite samples, the same procedure should be

used with the following considerations:

1. Use a single pair of gloves to collect all component

samples that will make up a composite sample.

2. All component samples that will make up a composite

sample should be placed in the same sample

container.

3. Use enough solvent on the sampling media to

properly collect all samples. The composite sample

should consist of no more than four discrete samples.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Sample Media

Sample media can consist of a number of materials,

which vary according to state and local requirements or

guidelines. Examples of recommended sample media

include:

• rayon/polyesterorcoongeneral-purposemedical

sponges;

• 11cmlterpaper(Whatman™40ashlessor

equivalent);

• lterpaper,includingWhatman™40,41,42,43,44,

540, 541, Ahlstrom 54, VWR 454, S&S WH Medium or

otherlterpaperwithequivalentperformance;and

• coongauzepad,includingJohnson&Johnsoncoon

squares or equivalent.

Solvent

Agreement has not yet been reached as to which solvent

should be used in sampling for meth. The three most

common lifting agents—deionized water, isopropyl

alcohol and methanol—are described below:

• Deionized water is safe for use and is generally

adequate for sampling surface concentrations of meth.

However, the use of deionized water as a solvent

requires an additional extraction step once the sample

is sent to the lab for analysis.

• Methanolisveryeectiveatpickingupmeth;

however, it may remove paint from wipe surfaces and

over-represent the levels of contamination available

throughnormalexposurepathways(suchastouching

awall).

• Intermsofsafetyandeectivenessformethsampling,

isopropyl alcohol lies somewhere between deionized

water and methanol.

It is important that sampling methods be performed in

a consistent fashion throughout the site. The degree to

which various solvents lift or extract contaminants from

the sampling surface will become more important as

remediation standards become health-based.

5.4 Microvacuum Sampling

Methods

Microvacuum sampling can be used to determine the

presence of meth contamination on porous materials

(e.g.,furniture,upholstery)thatcannotbesampledby

wiping. This method does not quantitatively represent the

mass of meth in the material, but the results may be used

qualitatively to indicate the presence of meth. Though less

sensitive than wipe sampling, microvacuums can be useful

for site-screening purposes or the evaluation of personal

items. Microvacuuming is not recommended for post-

remediation sampling when wipe sampling is possible.

When conducting microvacuuming, follow the appropriate

prescribedguidelines(e.g.,EPA,NIOSH,ASTM).

5.5 Quality Assurance/Quality

Control (QA/QC)

QA/QC in sample analysis does not begin in the lab, but

ratherintheeld.Thefollowingpracticesshouldbe

considered to maximize the integrity of samples:

• Coordinate with analytical laboratory to ensure proper

samplespecicationspriortoconductingsampling.

• Collect samples in a uniform manner.

• Ensure as few people as possible handle the samples.

• Collect at least one sample media blank, treated in the

same fashion but without wiping, for every 10 samples

collected.

• Handle sample media with stainless steel forceps,

tweezersorglovedngers.

• Change gloves with each sample to avoid cross-

contamination.

• Complete a sample label for each sample with

waterproof, non-erasable ink and note sample number,

date, time, location and sampler’s ID.

• Seal samples immediately upon collection and

document when seals are broken or replaced and

reseal open boxes of unused containers.

• Keepsamplesinasecure(locked)location.

• Properly store samples until they are transported to

thelabforanalysisperthelaboratory’sspecications.

• Deliver samples to the laboratory in a timely manner.

• The appropriate time frame for sample delivery

will depend on the sampling method, material and

laboratory protocol.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

6.0 Clandestine

Fentanyl Laboratory

Cleanup

6.1 Background

Fentanylisahighlypotentsyntheticopioid;

approximately 100 times stronger than morphine.

Pharmaceuticalfentanylwasrstdevelopedaspain

management treatment for cancer patients and is

generally obtained for abuse by theft or prescription

fraud. However, the most recent cases of fentanyl-related

harm, overdose and death in the United States are linked

to illegally manufactured fentanyl or clandestine fentanyl.

See Appendix F: Fentanyl Resources for more information.

In this document, “fentanyl” means fentanyl, fentanyl analogs

and any chemical structure modication to fentanyl (or its

analogs), including, but not limited to, isomers, esters, ethers

and salts. See Appendix G: Common Fentanyl Analogs for

information related to specic analogs.

“Clandestine fentanyl laboratory” means any location involved

in the illegal manufacturing or storage of fentanyl. This may

include manufacturing, compounding, converting, producing,

deriving, processing or preparing, either directly or indirectly

by chemical extraction, pill pressing, distribution, cutting,

diluting, synthesis or other activity that has the potential to

contaminate the property with fentanyl or any of its precursors.

While clandestine fentanyl is not yet widely manufactured

in the United States, it is processed in the United States

(cutwithheroinorpressedintotablets)andisan

emergingconcernthatposessignicantdangerstothose

who encounter the substance.

Clandestine fentanyl is predominantly synthesized illicitly in

ChinaandtrackedintotheUnitedStatesviainternational

mail, express consignment or across the Southwest or

Northern borders.

Fentanyl is sold through illegal drug

marketsforitsheroin-likeeect.Fentanylisoftenadded

to heroin or cocaine to increase its potency, or it can be

disguised as highly potent heroin. Many users believe that

they are purchasing heroin and do not know that they are

insteadpurchasingfentanyl-lacedheroin–whichoften

results in accidental overdose deaths. Some common street

names of fentanyl are Apache, China Girl, China Town,

China White, Dance Fever, Goodfellas, Great Bear, He-Man,

Poison and Tango & Cash.

In addition to the high toxicity, one of the dangers of

encountering fentanyl is the particle size, which ranges

from0.2-2.0microns(2.0micronsis0.002millimeters).

This small particle size means fentanyl is easily airborne.

Becausefentanylcanbeencounteredasaverynedustor

aerosol and toxic dose may depend on the type of fentanyl

(analog),extracautionshouldbeusedwhenfentanylis

present. To a great extent, solubility of opioids are pH

dependent with most analogs having favorable pHs in the

5-7 range. Fentanyl powders are slightly soluble in water,

with an aqueous solubility of 0.2g/L.

6.2 Prevalence

Pharmaceutical fentanyl products are currently available

aslozenges(lollipops),tablets,sublingualandnasal

sprays, transdermal patches and injectables. Clandestine

fentanyl is typically found in powders or pressed tablet

forms. Clandestine fentanyl is the most prevalent and the

mostsignicantsyntheticopioidthreat(notincluding

heroin)intheUnitedStatesandwillverylikelyremain

the most prevalent synthetic opioid threat in the near

term. As previously noted, fentanyl availability is

primarily by itself or mixed with heroin.

According to the Centers for Disease Control and

Prevention(CDC),in2018thereweremorethan31,000

deaths in the United States involving synthetic opioids

(otherthanmethadone),whichincludesfentanyl.

Synthetic opioid-involved death rates increased by 10%

from 2017 to 2018 and accounted for 67% of opioid-

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

involved deaths in 2018.

A CDC report published in 2019

notes that the number of drug overdose deaths involving

fentanyl was stable in 2011 and 2012, with just over 1,600

each year. From 2013 through 2016, the number of deaths

approximately doubled each year, rising sharply to 18,335

deaths in 2016.

Illicit fentanyl drug operations present multiple exposure

pathways and various forms of fentanyl including

powders, tablets and solutions. Makeshift laboratories are

often found in apartments, houses, garages and storage

facilities.Theseoperationsareknownascuinghouses,

and are commonly associated with heroin. As a result, it

should be assumed that heroin-repackaging operations

likely have fentanyl derivatives present as well.

Synthesizing Fentanyl

Fentanylisacompletelysyntheticµreceptor–

stimulatingopioidthatwasrstsynthesizedbythe

Janssen Company in the 1960s. Because the Janssen

method requires advanced chemistry knowledge and

skills, illicit fentanyl is generally manufactured using the

Siegfriedmethod(rstsynthesizedintheearly1980s)

oramodiedversionoftheSiegfriedmethod.Whilethe

number of fentanyl synthesis laboratories in the United

States is low, hazards may include:

Flammabilityhazards:

• Solventvapors;

• Water-reactivesolids;and

• Explosive salts.

Corrosivityhazards:

• Hydrochloricacid;

• Glacialaceticacid;and

• Sodium hydroxide.

Toxicityhazards:

• Fentanylitself;

• Chlorinatedsolvents(potentialcarcinogens);and

• Inhalation and/or dermal hazard.

6.3 Protection/Precautions/

Planning

As discussed in Section 1.2, EPA does not intend this

information to set, establish or promote quantitative

cleanup standards but rather provide guidance and

suggestions for addressing clandestine fentanyl

contamination. Those using this information also should

consult the appropriate state and local requirements or

guidelines for fentanyl remediation.

Clandestine fentanyl use has risen sharply in the United

States in the last few years so it is possible that home

purchasers or retail space renters could encounter

clandestine fentanyl. Workers can potentially encounter

powder, pill or liquid forms of clandestine fentanyl.

Additionally, the small particle size and water solubility

offentanylmeansexposurecanoccurvianedustor

aerosol. Exposure to fentanyl can happen through:

• Inhalation;

• Ingestion;

• Mucosal(touchingeyes,noseormouthwith

contaminatedhandsorgloveorairborneparticles)or

• Dermal(absorbedthroughtheskin).

As when dealing with any hazardous substances, it

is recommended that all procedures adhere to OSHA

HAZWOPERStandard,29CFR1910.120andother

applicable state and local worker safety and health

requirements. EPA suggests that remediation work not

begin until gross chemical removal is complete and law

enforcement personnel have cleared the structure of

defensemeasuresplacedbythelaboperators(suchas

anti-personneldevicesor“boobytraps”).Usethe“buddy

system” when making initial entry for remediation work,

in case unforeseen dangers are encountered. In addition,

conduct air quality monitoring to ensure the atmosphere

is safe for entry.

It is recommended that personnel who enter a former

clandestinelabhavesafetyandhealthtraining(40-hour

HAZWOPERtraining),andusetheappropriatelevel

ofPPEbasedonthesite-specicconditions.Hazards

and risks associated with any planned work should

beassessedonacase-by-casebasis(seeAppendix H:

Fentanyl Lab Remediation Diagrams).Thisassessmentwill

help determine how to minimize exposure to fentanyl.

As when dealing with other hazardous substances it is

recommended that personnel:

• Wear appropriate PPE for the planned work tasks.

• Use appropriate remediation work practices.

• Use appropriate decontamination processes.

• Follow standard operating procedures established for

handling, transporting and disposing of fentanyl and

fentanyl-contaminated materials.

• Avoid eating, drinking or smoking after handling

fentanyl-contaminated surfaces or material until they

have exited the work area and followed all the steps

required for personal decontamination.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

When illicit drugs may be present, PPE might include

at a minimum nitrile gloves, eye protection and proper

respiratoryprotection(properlyt-testedN95mask

orsimilarlevelofprotection).Itmightalsoinclude

foot coverings, long-sleeved coveralls or a disposable

protectivesuit.PPEneedswilldependonspecicsite

conditions and might change from site to site. In addition

to wearing appropriate PPE it is recommended that

workers also:

• Avoid performing tasks or operations that may cause

fentanyltobecomeairborne(usingfansorrunning

HVACunits).

• Do not touch the eyes, nose or mouth after touching

any surface that may be contaminated, even if

wearing gloves.

• Wash hands with soap and water after working in

an area that may be contaminated, even if gloves

were worn.

• Cover all open wounds.

• Donotusehandsanitizer(oranyalcoholbased

cleaner)orbleachtocleanskinthatmayhavecome

into contact with illicit drugs.

• Wash hard surfaces with water and household

cleaner. Change the water frequently to prevent

spreading contamination. Rinse surfaces with clean

water after washing.

• OnlyuseaHEPA-lteredvacuumoncarpet,

upholstery and fabric surfaces.

Even with proper precautions, accidental exposure is still

possible. Workers need to be aware of fentanyl exposure

symptoms, which may include:

• Slowed,shallowbreathing;

• Pale,clammyskin;

• Decreasing consciousness, increasing drowsiness,

confusion;

• Lowbloodpressure;

• Pinpointpupils;or

• Euphoria.

Itisimportanttobeawareofexposuresymptomsand

seekmedicalaentionasappropriateforthoseworking

inasuspectedclandestinefentanyllab. Additionally,

theAmericanCollegeofMedialToxicology(ACMT)and

theAmericanAcademyofClinicalToxicology(AACT)

recommends having naloxone kits with syringes or pre-

packaged naloxone applicators containing enough doses and

individual applicators for all personnel available on site.

6.4 Remediation Standards

Clandestinefentanyllabsdierfrommethlabsbecause

fentanyl is not widely manufactured in the United States

atthistime.Fentanylistypicallyprocessedbycuing

the fentanyl with heroin, cocaine or other more benign

adulterants and pressing it into tablets. However, meth is

manufactured or cooked in labs in the United States. As

such, meth labs have multiple hazardous substances of

concern. With clandestine fentanyl labs, the contaminant of

concern is typically only fentanyl.

Smallamountsoffentanylareextremelydangerous;

the lethal dose of fentanyl is generally accepted to be 2

milligrams(mg),

see Figure 1. For more information

on analogs including lethal doses, see Appendix G:

Common Fentanyl Analogs. The lowest limit of detection

currently available for fentanyl by laboratory analysis is

1nanogram(ng).AsofAugust2021,therearenostate

or federal standards in the United States for determining

when a closed fentanyl laboratory has been successfully

remediated. The Province of Alberta, Canada established

Figure 1: Lethal Dose of Fentanyl

First Responders

First responders [i.e., law enforcement, reghters and

emergency medical services (EMS) personnel] are exposed

to a slightly different set of risks compared to the public. See

the following resources for more information specic to rst

responders:

Preventing Occupational Exposure to Emergency Responders:

https://www.cdc.gov/niosh/topics/fentanyl/toolkit.html

ACMT and AACT Position Statement: Preventing Occupation

Fentanyl and Fentanyl Analog Exposure to Emergency

Responders:

https://www.acmt.net/_Library/Positions/Fentanyl_PPE_

Emergency_Responders_.pdf

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

a remediation benchmark of less than 1.0 ng of fentanyl

particulatepercubicmeterofair(ng/m

).Thisbenchmark

could be considered successful for air samples and <1.0 ng

per100squarecentimeters(ng/100cm

)forwipesamples

(1,000,000ng=1mg).

This is not a health-based clearance

value. Health-based clearance levels may be lower and

would depend primarily on the fentanyl analog.

6.5 Remediation Techniques

Many of the same steps and techniques that are utilized

for meth lab cleanup may apply to clandestine fentanyl

lab cleanup. The remediation techniques provided below

reference the appropriate sections of the meth cleanup

guidelines discussed earlier in this document and note

anyspecicdierencesbetweentheremediationsequence

and techniques.

Remediation Sequence and Techniques

The clandestine fentanyl remediation sequence is very

similar to what is described for methamphetamine in

Section 3.0. With the following exceptions: the area should

notbeventilatedandaneutralizationsolutionshould

beappliedtoinactivatefentanylbeforevacuuming

orremovingofitems.Care should also be taken not to

agitate areas or surfaces where fentanyl may be found

before applying the neutralization solution. The high

toxicity and small particle size of fentanyl when compared

to methamphetamine can make ventilation a potentially

dangerous situation for those performing remediation

(forexampleratherthanreducingtheconcentration

offentanylintheair,disturbingthenepowdersmay

increasetheconcentrationandriskofexposure).

Similar to what is outlined in Section 3.2,oneoftherst

suggested steps in clandestine fentanyl remediation

is hiring the appropriate contractor. Consider hiring

a contractor who has hazardous waste expertise and

iscertied(ifcerticationisrequiredbythestate)to

conduct cleanup operations at known or suspected

clandestine fentanyl labs. Contractors should, at a

minimum,completethe40-hourHAZWOPER

training(OSHA29CFR1910.120).

The main remediation technique used for fentanyl is

applying a neutralization solution. This solution is used

todestroyorinactivatefentanyl.Tobeeective,the

neutralization solution should remain on contaminated

surfaces for the prescribed contact time. [Note:

Neutralization solutions should not be used on skin.] Use

low-pH soap and water to decontaminate skin surfaces.

When a neutralization solution is used on respirators,

other PPE or other sensitive equipment, rinse the

equipment with water after the prescribed contact time.

Similar to meth, the sequence in the list below begins after

gross removal has occurred and any law enforcement

investigation has concluded. When cleaning clandestine

fentanyllabs(dependingonthelevelofcontamination),

the following may be considered:

1. Do not use compressed air or dry sweeping to clean

the contaminated work area.

2. Usealow-pressuresprayerlledwith

neutralization solution.

3. Gently spray the entire contaminated work area,

including all surfaces of all porous and non-porous

materials and all items marked “for disposal.”

4. Spray visible powders, solids, liquids and gels until

theyarefullyweed.Spraythesurfaceofbuilding

Alberta Health’s Fentanyl Remediation: Guidance for

Remediators, Regulatory Agencies and Professionals includes

a great deal of relevant information intended to assist agencies

and professionals needing to manage risks related to property

or materials contaminated with fentanyl. The report outlines

assessment and remediation procedures of property or

materials contaminated with fentanyl.

For more information, visit:

https://open.alberta.ca/publications/fentanyl-remediation

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

materials and nonporous contents on site until they

are fully coated. Spray porous contents on site until

thesurfaceisweed.

5. Spray surfaces adjacent to any area where fentanyl

was detected or suspected to be present, based on the

results of the preliminary site assessment. The spray

should cover a radius of at least 3 feet beyond the

known/suspected contamination. Be careful while

spraying, to avoid making the powders or liquids

airborne: be mindful of the spray velocity, angle,

application method, etc.

6. Spraythesurfacesofallxturesorcoveringsthat

could absorb airborne fentanyl powder or that could

hide or contain spaces where airborne fentanyl

powdercouldhaveseledandcannotbeeasilyor

safelydecontaminated(e.g.,electricaloutlets,outlet

covers and electrical boxes, baseboards, trim, light

xtures,ventcovers/grilles,appliancelters,etc.).

[Note: Ensure that all other hazards have been isolated

(e.g., lock-out and tag-out electrical power supply to

electrical sockets and boxes).]

7. Allow the recommended neutralization time per

product direction for all steps.

8. Make sure to spray surfaces behind and inside the

removedxturesandcoverings.

9. Consider using 6-mil waste bags and using either a

goose-neck or overhand knot to secure the bags before

sealing with duct tape.

10. Apply neutralization solution to the exterior of the

waste bags and allow the necessary neutralization per

product direction before the next step.

11. Placewastebagsinsideasecondwastebag(i.e.,

double-bag)andimmediatelytransferwastetothe

equipment and waste decontamination unit.

After the fentanyl is neutralized with the solution

for the proper amount of time, these general residual

decontamination procedures may be followed:

1. Do not use compressed air or dry sweeping to clean

the contaminated work area.

2. UseavacuumequippedwithaHEPAltertoclean

loose dry material.

3. Clean all surfaces in the work area by damp-wiping

and mopping with warm water until there is no

visible residue.

4. Start damp-wiping at the ceiling of the room and

worktowardtheoor.

5. Minimize water pooling in the work area by collecting

wash water with a wet vacuum equipped with a

HEPAlter.

6. Cordonoareasaftereachareaiscleanedtoavoid

re-contamination.

7. Placewasteintotear-proofwastebags(6-mil

minimum)atregularintervals,securebagwitha

goose-neck or overhand knot and seal with duct tape.

8. Dispose of hazardous waste in accordance with state

and local requirements or guidelines.

6.6 Item- and Material-

Specic Best Practices

In general, the guidance provided in Section 4.0 applies

toclandestinefentanyllabsaswell.Themaindierence,

following the guidelines stated above is, everything

shouldbesprayedwithaneutralizingsolutionbefore

cleaningordisposal. It is suggested that items not

be vacuumed until they have been sprayed with the

neutralizing solution. Similar items are recommended for

disposalduetoporosity,dicultycleaningorfutureuse.

6.7 Potential Sampling

Constituents, Theory

and Methods

Sampling constituents for clandestine fentanyl labs

diersabitfromwhatisdiscussedinSection 5.1

primarily because at the time of publication of this

document, the main source of clandestine fentanyl

in the United States is from illicit international labs.

WithintheUnitedStates,trackerstypicallyacquire

syntheticopioidsandprocessthembycuing,mixingor

pressing into pill form. As such, clandestine fentanyl labs

would not be expected to have the same constituents

as associated with meth labs. Air and surface sample

wipes to detect fentanyl and not other constituents

are suggested when determining the level of fentanyl

contamination of a site.

Similar to meth remediation sampling, sample locations

for fentanyl should be selected based on areas suspected to

have the highest level of contamination using authoritative

sampling methods. See Section 5.2 for more information.

The same sampling methods described in Section

5.3 should be used. Additionally, Appendix E of

AlbertaHealth,GovernmentofAlberta(2020)Fentanyl

Remediation Guidance for Remediators, Regulatory Agencies

and Professionals provides useful information related to

sampling. NIOSH wipe sample methods 9106 and 9109

could be consulted for additional information.

When sampling, quality assurance and quality control

measures should be considered to maximize the integrity

of samples. For more information, see Section 5.5.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Endnotes

1. WhiteHouseOceofNationalDrugControlPolicy(2006)Synthetic Drug Control Strategy: A Focus on Methamphetamine

and Prescription Drug Abuse, pg. 39

hps://www.justice.gov/archive/olp/pdf/synthetic_strat2006.pdf

2. WhiteHouseOceofNationalDrugControlPolicy(2006)Synthetic Drug Control Strategy: A Focus on Methamphetamine

and Prescription Drug Abuse, pg. 39

hps://www.justice.gov/archive/olp/pdf/synthetic_strat2006.pdf

3. UnitedStatesDrugEnforcementAdministration(2021)2020 Drug Enforcement Administration NDTA National Drug Threat

Assessment, pg. 25

hps://www.dea.gov/documents/2021/03/02/2020-national-drug-threat-assessment

4. NationalJewishMedicalandResearchCenter(2004)Methamphetamine Contamination on Environmental Surfaces Caused by

Simulated Smoking of Methamphetamine

hp://www.wvdhhr.org/rtia/pdf/smoked%20meth.pdf

5. UnitedStatesDrugEnforcementAdministration(2021)2020 Drug Enforcement Administration NDTA National Drug Threat

Assessment, pg. 23

hps://www.dea.gov/documents/2021/03/02/2020-national-drug-threat-assessment

6. WhiteHouseOceofNationalDrugControlPolicy(2006)Synthetic Drug Control Strategy: A Focus on Methamphetamine

and Prescription Drug Abuse, pg. 39

hps://www.justice.gov/archive/olp/pdf/synthetic_strat2006.pdf

7. UnitedStatesEnvironmentalProtectionAgency(EPA)Oce of Children’s Health Protection

hps://www.epa.gov/children

8. ColoradoDepartmentofPublicHealth(2005)Support for Selection of a Cleanup Level for Methamphetamine at Clandestine

Drug Laboratories

hps://www.colorado.gov/pacic/sites/default/les/HM_clean-up-level-support.pdf

9. CaliforniaDepartmentofToxicSubstancesControl(2007)Development of a Health-Based Meth Cleanup Standard

hps://dtsc.ca.gov/erp/drug-lab-removals-erp/

10. NationalJewishMedicalandResearchCenter(2005)A 24-Hour Study to Investigate Chemical Exposures Associated with

Clandestine Methamphetamine Laboratories

hps://pubmed.ncbi.nlm.nih.gov/19065282/

11. NorthCarolinaDepartmentofHealthandHumanServices(2005)Illegal Methamphetamine Laboratory Decontamination and

Re-Occupancy Guidelines, pg. 13

hps://www.methlabcleanup.com/NC%20Standards.pdf

12. AlaskaDepartmentofEnvironmentalConservation(2007)Guidance and Standards for Cleanup of Illegal Drug-Manufacturing

Sites, pg. 27

hps://dec.alaska.gov/media/11560/drug-lab-guidance.pdf

13. ColoradoDepartmentofPublicHealthandEnvironment(2005)6 CCR 1014-3, Regulations Pertaining to the Cleanup of

Methamphetamine Laboratories, Appendix C

hps://www.sos.state.co.us/CCR/GenerateRulePdf.do?ruleVersionId=1464&leName=6%20CCR%201014-3

14. CaliforniaDepartmentofToxicSubstancesControl(2004)Preliminary Analysis of the Ecacy of Using Cleaning Products to

Break Down Methamphetamine

Link Unavailable

15. Serrano,Martyny,Koord,Contreras,andVanDyke(2012)Decontamination of Clothing and Building Materials Associated

with the Clandestine Production of Methamphetamine, Journal of Occupational and Environmental Hygiene, vol. 9:3, pgs. 185-197

hps://www.researchgate.net/publication/259912612_Decontamination_of_Clothing_and_Building_Materials_

Associated_with_the_Clandestine_Production_of_Methamphetamine

16. Serrano,Martyny,Koord,Contreras,andVanDyke(2012)Decontamination of Clothing and Building Materials Associated

with the Clandestine Production of Methamphetamine, Journal of Occupational and Environmental Hygiene, vol. 9:3, pgs. 185-197

hps://www.researchgate.net/publication/259912612_Decontamination_of_Clothing_and_Building_Materials_

Associated_with_the_Clandestine_Production_of_Methamphetamine

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

17. Serrano,Martyny,Koord,Contreras,andVanDyke(2012)Decontamination of Clothing and Building Materials Associated

with the Clandestine Production of Methamphetamine, Journal of Occupational and Environmental Hygiene, vol. 9:3, pgs. 185-197

hps://www.researchgate.net/publication/259912612_Decontamination_of_Clothing_and_Building_Materials_

Associated_with_the_Clandestine_Production_of_Methamphetamine

18. WashingtonStateDepartmentofHealth,DivisionofEnvironmentalHealth(2005)Guidelines for Environmental Sampling at

Illegal Drug Manufacturing Sites, pg. 12

hps://www.doh.wa.gov/portals/1/Documents/Pubs/334-106.pdf

19. AmericanIndustrialHygieneAssociation(2007)Clandestine Methamphetamine Laboratory Assessment and Remediation

Guidance, pg. 22

hps://online-ams.aiha.org/amsssa/ecssashop.show_product_detail?p_mode=detail&p_product_serno=1322

20. Serrano,Martyny,Koord,Contreras,andVanDyke(2012)Decontamination of Clothing and Building Materials Associated

with the Clandestine Production of Methamphetamine, Journal of Occupational and Environmental Hygiene, vol. 9:3, pgs. 185-197

hps://www.researchgate.net/publication/259912612_Decontamination_of_Clothing_and_Building_Materials_

Associated_with_the_Clandestine_Production_of_Methamphetamine

21. UnitedStatesEnvironmentalProtectionAgency(2000)Data Quality Objectives Process for Hazardous Waste Site

Investigations

hps://www.epa.gov/quality/data-quality-objectives-process-hazardous-waste-site-investigations-epa-qag-4hw-

january-2000

22. CentersforDiseaseControlandPrevention,NationalInstituteforOccupationalSafetyandHealth(NIOSH)(2011)

Manual of Analytical Methods (NMAM), Fifth Edition

hps://www.cdc.gov/niosh/docs/2003-154/pdfs/9106.pdf

hps://www.cdc.gov/niosh/docs/2003-154/pdfs/9109.pdf

23. DrugEnforcementAdministration(2020)Drug Fact Sheet – Fentanyl, pg. 1

hps://www.dea.gov/factsheets/fentanyl

24. OceofNationalDrugControlPolicy(2019)Advisory to the Chemical Manufacturing Industry on Illicit Activity and Methods

Related to the Manufacturing of Fentanyl and Synthetic Opioids, pg. 2

hps://www.state.gov/wp-content/uploads/2020/02/Fentanyl-Advisory-Manufacturing-Tab-A-508.pdf

25. AlbertaHealth,GovernmentofAlberta(2020)Fentanyl Remediation Guidance for Remediators, Regulatory Agencies and

Professionals, pg. 9

hps://open.alberta.ca/publications/fentanyl-remediation

26. CentersforDiseaseControlandPrevention(2020)Synthetic Opioid Overdose Data

hps://www.cdc.gov/drugoverdose/data/fentanyl.html

27. SpencerMR,WarnerM,BastianBA,TrinidadJP,HedegaardH.(2019)Drug overdose deaths involving fentanyl, 2011–2016

National Vital Statistics Reports, vol 68 no 3. Hyasville, MD: National Center for Health Statistics

hps://www.cdc.gov/nchs/data/nvsr/nvsr68/nvsr68_03-508.pdf

28. DrugEnforcementAdministration(2019)Guidelines for Law Enforcement— Cleanup of Illicit Hazardous Environments

LawEnforcementSensitive/ForOcialUseOnlyinformation;notavailableforwidespreadrelease

29. AmericanCollegeofMedicalToxicology(ACMT)andAmericanAcademyofClinicalToxicology(AACT)(2018)Position

Statement: Preventing Occupational Fentanyl and Fentanyl Analog Exposure to Emergency Responders

www.acmt.net/_Library/Positions/Fentanyl_PPE_Emergency_Responders_.pdf

30. UnitedStatesEnvironmentalProtectionAgency(2018)Fact Sheet for OSCs: Fentanyl and Fentanyl Analogs

hps://www.epa.gov/sites/production/les/2018-07/documents/fentanyl_fact_sheet_ver_7-26-18.pdf

31. AlbertaHealth,GovernmentofAlberta(2020)Fentanyl Remediation Guidance for Remediators, Regulatory Agencies and

Professionals, pg. 72

hps://open.alberta.ca/publications/fentanyl-remediation

32. ListmodiedfromAlbertaHealth,GovernmentofAlberta(2020)Fentanyl Remediation Guidance for Remediators, Regulatory

Agencies and Professionals, pg. 33

hps://open.alberta.ca/publications/fentanyl-remediation

33. ListmodiedfromAlbertaHealth,GovernmentofAlberta(2020)Fentanyl Remediation Guidance for Remediators, Regulatory

Agencies and Professionals, pg. 34

hps://open.alberta.ca/publications/fentanyl-remediation

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Key Contributors

• Leigh Anderson, Utah Department of Environmental Quality

• Curry Blankenship, Cherokee Nation Environmental Programs

• Lisa Boynton, U.S. Environmental Protection Agency

• Colleen Brisnehan, Colorado Department of Public Health and Environment

• JeBurgess,MD,MPH,UniversityofArizona

• Steven Connolly, New Mexico Environment Department

• Ryan Costello, Agency for Toxic Substances and Disease Registry

• Jace Cujé, U.S. Environmental Protection Agency

• Jim Faust, Idaho Department of Health and Welfare

• Anna Fernandez, Hawaii Department of Health

• Sherry Green, National Alliance of Model State Drug Laws

• Deb Grimm, Montana Department of Environmental Quality

• Leo Henning, Kansas Department of Health and Environment

• Thomas Hunting, Arkansas Department of Environmental Quality

• Erik Janus, University of Maryland University College

• James Justice, U.S. Environmental Protection Agency

• Larry Kaelin, U.S. Environmental Protection Agency

• Karen Keller, Utah Department of Environmental Quality

• ShaleceKoard,UtahDepartmentofHealth

• Kim Leingang, Kentucky Division of Waste Management

• Kathy Marshall, Illinois Department of Public Health

• John Martyny, PhD, CIH, National Jewish Health

• Greg McKnight, Washington State Department of Health

• James Michael, U.S. Environmental Protection Agency

• Terrel Mitchell, Cherokee Nation Environmental Programs

• Jim Morrison, Tennessee Department of Environment and Conservation

• Lukas Oudejans, U.S. Environmental Protection Agency

• Robert Pangelinan, Drug Enforcement Administration

• Marilyn Parker, North Carolina Department of Health and Human Services

• Bill Rees, Utah Department of Environmental Quality

• Rick Rosky, National Meth Chemicals Initiative Southwest Meth Initiative

• Charles Salocks, California Environmental Protection Agency

• Will Service, North Carolina Division of Waste Management

• BreSherry,OregonHealthAuthority

• Kent Schierkolk, Kansas Department of Health and Environment

• Brian Schlieger, U.S. Environmental Protection Agency

• Larry Souther, Minnesota Department of Health

• Ed Thamke, Montana Department of Environmental Quality

• Scot W. Tiernan, Alaska Department of Environmental Conservation

• Ellen Treimel, U.S. Environmental Protection Agency

• Greg Art Vollmer, New Mexico Environment Department

• Corey Yep, California Department of Toxic Substances Control

• Cathy Young, U.S. Environmental Protection Agency

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Appendix A: Primary Methods of Meth

Production and Associated Hazards

One-Pot Lab Prole

Precursor: Pseudoephedrine

Product: d-Methamphetamine

Method: Ephedrine reduction using ammonium nitrate,

lithium metal, sodium hydroxide, ether and

hydrochloric acid

Other Names: “Shake and Bake” Lab or “Six Pack” Lab

Unique Hazards: Heat generated by reaction can degrade structural

integrity of plastic reaction vessel and may result in

a release of ammable liquids and vapors

Reaction of water with sodium or lithium metals

can cause lithium to tear through plastic vessel

and ignite the ammable liquids and vapors,

resulting in re

Discarded reaction vessels carry residual

chemicals that are muddy brown in color and can

be toxic and ammable

Use of acid gas generators

Variations: Use of other non-polar solvent in place of ether

Use of other ammonium salts

Nazi/Birch Reduction Lab Prole

Precursor: Ephedrine or Pseudoephedrine

Product: d-Methamphetamine

Method: Ephedrine reduction using anhydrous ammonia

and lithium, sodium metal or elemental potassium

and hydrochloric acid

Other Names: “Lithium-Ammonia” Lab or “Sodium Metal” Lab

Unique Hazards: Reaction of water with sodium or lithium metals

as well as mixing sodium metal with sodium

hydroxide increases ammability potential

Irritant toxicity hazard from concentrated

ammonia atmospheres

Use of corrosive acids and bases

Use of acid gas generators

Variations: Use of an acetone/dry ice bath to keep original

anhydrous ammonia mixture from evaporating

prematurely

Recovery of lithium ribbon from camera batteries

Red Phosphorus/Hydriodic Acid Lab Prole

Precursor: Ephedrine or Pseudoephedrine

Product: d-Methamphetamine

Method: Ephedrine reduction using red phosphorus,

hydriodic acid and hydrochloric acid

Other Names: “Red P” Lab, “Tweaker” Lab, “HI” Lab or

“Mexican National” Lab

Unique Hazards: Phosphine gas production

Conversion of red phosphorus to white

phosphorus

Iodine and hydriodic acid vapors

Use of corrosive acids and bases

Variations: Use of acid gas generators

Use iodine and water to make hydriodic acid

Use hypophosphorus acid instead of red

phosphorus

Use liquid from tablet extraction directly in

reux step

P2P Amalgam Lab Prole

Precursor: Phenyl-2-Propanone (phenylacetone)

Product: Mixture of l-Methamphetamine (50%) and

d-Methamphetamine (50%)

Method: P2P reduction using methylamine, mercuric

chloride and hydrochloric acid

Other Names: “Biker” Lab or “Prope Dope” Lab

Unique Hazards: Methylamine could cause severe eye

and skin irritation and may cause blindness,

ammable in high concentrations, a skin

absorbent and a central nervous system

(CNS) toxicant

Use of lead acetate and highly toxic mercuric

chloride

Use of corrosive acids and bases

Occasional use of methylamine compressed

gas cylinders

Use of acid gas generators

Variations: Acidify the oil layer directly (i.e., delete solvent

washing step)

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Appendix B: Costs Associated with Meth

Lab Cleanup

As explained previously in this document, meth labs range from crude makeshift operations to technologically

advanced facilities and are found almost anywhere: in private residences, motel and hotel rooms, apartments and

trailers. Because no two meth labs are alike, the cost of cleanup varies. The Institute for Intergovernmental Research

estimatedthattheaveragecostofcleanupcanrangefrom$5,000–$150,000.*Thefollowingvariablesmayimpactthe

cost of meth lab remediation:

Size of Property and Structure

• Larger labs are usually more costly to remediate simply because there is more surface area to clean.

Property Accessibility

• Methlabsaresometimesfoundinremotelocations.Ifthelabisinanareathatisdiculttoaccess,costs

will increase.

Contractor Rates

• Contractor rates vary depending on geographical location.

Amount of Debris

• Aconsiderableamountofdebrisisgeneratedduringmethlabcleanup(e.g.,carpet,contaminatedhouseholditems).

• The more contaminated debris that needs to be discarded, the more the cleanup will cost.

Presence of Asbestos

• If asbestos is found in materials that have to be cleaned or removed, the cost of the cleanup may increase.

Contamination Level

• Labs with high levels of contamination may cost more to clean than labs with lower levels of contamination.

Pre- and Post-Remediation Sampling

• Pre-remediationsamplingmaybeusefulinsomecases(seeSection 3.6);othersmaynotrequirepre-remediation

sampling.

• The results of post-remediation samples demonstrate whether previously contaminated areas have been cleaned

to an acceptable level. Although post-remediation sampling may increase costs, it is an important step in meth lab

remediation and should not be skipped.

Inclusion of Refurbishment Costs

• Thecostofcleanupwillincreaseifoneincludesrefurbishmentactivities(e.g.,repainting,re-carpeting)withinthe

scope of “cleanup.”

*TheMethamphetamine Problem: Question and Answer Guide, Institute for Intergovernmental Research

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Appendix C: Properties of Chemicals

Associated with Meth

The tables below provide high-level information about the properties of the chemicals associated with meth

production.Thesechemicalsmaybeextremelyhazardousandtoxic;andexposuretothemcancausesignicanthealth

eects.[Note: Taken from documentation developed by EPA’s Oce of Research and Development (ORD).]

Chemical and CAS Number Form Hazard Health Effect Fate and Transport

Acetic Acid (64-19-7) [Reacts

with phenylacetic acid to yield

Phenyl-2-Propanone (P2P)]

[syn: ethanoic acid, glacial

acetic acid]

Colorless

liquid with

pungent odor.

Corrosive and

ammable.

Vapors cause eye irritation. Exposure to high

concentrations causes inammation of airway

and ulcers of eyes. IDLH: 50 ppm; NIOSH REL:

TWA 10 ppm (25 mg/m

) STEL 15 ppm (37 mg/

); OSHA PEL: TWA 10 ppm (25 mg/m

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)

(Reacts with phenylacetic acid

to yield of P2P)

[syn: acetic oxide, acetyl oxide]

Colorless

liquid with

strong acetic

odor.

Corrosive and

ammable.

Vapors cause eye irritation. Exposure to high

concentrations may lead to ulcerations of the

nasal mucosa and can severely damage the

eye. IDLH: 200 ppm. NIOSH REL: C 5 ppm (20

mg/m

); OSHA PEL: TWA 5 ppm (20 mg/m

Dissolves slowly in water.

Specic 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]

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: 2,500 ppm; NIOSH REL: TWA 250 ppm

(590 mg/m

); OSHA PEL: TWA 1,000 ppm (2,400

mg/m

Miscible in water. Not

persistent. Readily

biodegrades in soil or water.

Ammonia (7664-41-7) (Used

in Nazi/Birch method) [syn:

anhydrous ammonia]

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: 300 ppm; NIOSH REL:

TWA 25 ppm (18 mg/m

) STEL 35 ppm (27 mg/

); OSHA PEL: TWA 50 ppm (35 mg/m

Lighter than air gas, likely to

dissipate into atmosphere.

Ammonium Hydroxide (1336-

21-6) (Found during synthesis

in Nazi/Birch and One-Pot

methods)

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. ACGIH TLV: TWA

25 ppm; OSHA PEL: TWA 50 ppm, STEL 35 ppm

NIOSH REL: TWA 25 ppm, STEL 35 ppm.

Toxic to aquatic life. 28%

solution has high vapor

pressure and is likely to

evaporate if spilled.

Ammonium Sulfate (7783-20-2)

(Used with sodium hydroxide to

produce anhydrous ammonia

for use in One-Pot method)

[syn: sulfuric acid diammonium

salt]

Brownish

gray to white

odorless

granules or

crystals.

Corrosive. Irritant and corrosive to the skin, eyes,

respiratory tract and mucous membranes.

Exposure to liquid or rapidly expanding

gases may cause severe chemical burns

and frostbite to the eyes, lungs and skin. Skin

and respiratory related diseases could be

aggravated by exposure. Exposure limits N/A.

Possibly hazardous short term

degradation products are not

likely. However, long term

degradation products may

arise. The product itself and

its products of degradation

are not toxic.

Benzaldehyde (100-52-7)

(Precursor for amphetamine or

P2P) [syn: benzoic aldehyde,

articial essential oil of almond,

benzenecarbonal]

Colorless

liquid, bitter

almond odor.

Combustible. Mild irritant to lungs. Central nervous system

depressant. Exposure limits N/A.

If released in sufciently large

quantities, can migrate to

shallow water table. Slightly

soluble in water with specic

gravity of 1.05. Moderately

biodegradable.

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Benzyl Chloride (100-44-7)

(Precursor for P2P)

[syn: chloromethyl benzene,

alpha- chlorotoluene]

Colorless to

pale yellow

liquid with

pungent

aromatic odor.

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

NIOSH REL: C 1 ppm (5 mg/m

)

[15-minute]; OSHA PEL: TWA 1 ppm (5 mg/m

Not persistent. Hydrolysis

in moist conditions. Readily

biodegradable.

Benzene (71-43-2) (Solvent) Colorless

liquid with

aromatic odor.

Flammable. Vapor in high concentrations may cause

dizziness, headache, coughing. Chronic

exposure may cause anemia or leukemia.

IDLH: 500 ppm; NIOSH REL: Ca TWA 0.1 ppm

STEL 1 ppm; OSHA PEL: (1910.1028) TWA 1 ppm

STEL 5 ppm.

Mobile in soils. Lighter than

water and slightly soluble.

Will biodegrade over time.

MCL of 5 µg/L.

Chloroform (67-66-3) (Solvent) Colorless

liquid with a

pleasant odor.

May explode

if it comes

into contact

with certain

materials,

including

aluminum

powder,

lithium and

perchlorate.

Irritation eyes, skin; dizziness, mental dullness,

nausea, confusion; headache, lassitude

(weakness, exhaustion); anesthesia; enlarged

liver, suspect carcinogen. IDLH: 500 ppm;

NIOSH REL: Ca STEL 2 ppm (9.78 mg/m

)

[60-minute]; OSHA PEL: C 50 ppm (240 mg/m

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)

(Used in Nazi/Birch reduction,

Red Phosphorus/Hydriodic Acid

and One-Pot methods)

[syn: petroleum ether,

petroleum naptha, petroleum,

distillate]

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.

IDLH: 1,100 ppm; NIOSH REL: TWA 350 mg/m

1,800 mg/m

[15-minute]; OSHA PEL: TWA 500

ppm (2,000 mg/m

3).

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.

Diethyl Ether (60-29-7) (Solvent)

[syn: ether, ethyl ether, ethyl

oxide]

Clear

colorless

liquid with

sweet

pungent odor.

Highly

ammable.

Inhalation may cause headache, drunkenness

and vomiting. IDLH: 1,900 ppm; NIOSH REL:

none; OSHA PEL: TWA 400 ppm (1,200 mg/m

Spilling of small amounts to

ground or soil will likely result

in volatilization. Expected to

be mobile in soil and resistant

to biodegradation.

Ephedrine (299-42-3) (Precursor

for meth)

Odorless

white crystal.

None. Skin and respiratory irritant. Exposure limits

N/A.

Not available.

Ethanol (64-17-5) (Solvent)

[syn: ethyl alcohol, ethanol,

anhydrous alcohol, ethyl

hydroxide, methyl carbinol]

Clear

colorless

liquid with

pleasant odor.

Highly

ammable.

Respiratory irritant. Central nervous system

suppressant. IDLH: 3,300 ppm; NIOSH REL:

TWA 1,000 ppm (1,900 mg/m

); OSHA PEL: TWA

1,000 ppm (1,900 mg/m

Miscible with water. Large

spills may reach water table.

Very biodegradable.

Ethylamine (75-04-7) (Used in

P2P method)

[syn: ethanamine,

monoethlamine]

Gas with

ammonia-like

odor.

Highly

ammable

and corrosive

liquid.

Vapor irritates the mucous membranes,

respiratory system and eyes; in high

concentrations it may affect the central

nervous system; liquid may irritate eyes

and skin; if ingested may be irritating and

poisonous.

OSHA: TWA 10 ppm (18 mg/m

If released to soil, ethylamine

is expected to have very high

mobility. Volatilization from

moist soil surfaces is not

expected to be an important

fate process based upon its

cationic state.

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Formic Acid (64-18-6)

(Reacts with phenyl-2-

propanone and methylamine to

produce methamphetamine)

Colorless

fuming

liquid with a

pungent odor.

Corrosive and

moderate re

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; NIOSH REL: TWA 5

ppm (9 mg/m

); OSHA PEL: TWA 5 ppm

(9 mg/m

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 re hazard and tendency

to react explosively with

oxidizing agents should not be

ushed into sanitary sewer.

Normal Hexane (110-54-3)

(Solvent)

Clear

colorless

liquid with

slight odor.

Highly

ammable.

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:

1,100 ppm; NIOSH REL: TWA 50 ppm (180 mg/

); OSHA PEL: TWA 500 ppm (1,800 mg/ m

When spilled on the ground

expected to evaporate. If it

penetrates the ground, not

likely to leach (log K

of >

3.0) to groundwater. Not very

soluble and lighter than water.

Moderate biodegradation

expected.

Cyclohexane (110-82-7)

(Solvent)

Clear

colorless

liquid with

faint ether-like

odor.

Highly

ammable.

Causes irritation to respiratory tract. High

concentrations have a narcotic effect. Chronic

exposure may cause skin effects. IDLH: 1,300

ppm; NIOSH REL: TWA 300 ppm (1,050 mg/ m

);

OSHA PEL: TWA 300 ppm (1,050 mg/m

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.

Hydrochloric Acid (7647-01-0)

(Used to gas out meth product)

[syn: muriatic acid, hydrogen

chloride]

Clear colorless

liquid with

pungent odor

(hydrogen

chloride

dissolved in

water).

Corrosive and

poison.

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; NIOSH REL: C 5 ppm

(7 mg/m

); OSHA PEL: C 5 ppm (7 mg/m

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)

(Used in Red Phosphorus

method) [syn: hydrogen iodide

(aqueous solution)]

Clear colorless

liquid with

pungent odor

(hydrogen

iodide

dissolved in

water). Yellow

to brown upon

exposure to

light and air.

Corrosive and

poison.

Vapors cause severe irritation and burns to

respiratory tract. Liquid may cause burns to

skin. Exposure limits N/A.

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 Sulde (7783-06-4)

(Reacts with iodine suspended

in water to yield hydriodic acid

for use in the Red Phosphorous

method; sometimes mistakenly

used as substitute for hydrogen

chloride gas)

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 difculty, headache,

drowsiness, dizziness, disorientation, tremors,

hallucinations, coma and death. Long-term

exposure can cause loss of appetite, weight

loss, irregular heart beat, headache, nerve

damage, lung congestion, paralysis and brain

damage. IDLH: 100 ppm; NIOSH REL: C 10

ppm (15 mg/m

) [10-minute]; OSHA PEL: C 20

ppm 50 ppm [10-minute maximum peak].

Hydrogen sulde is heavier

than air and may accumulate

in low-lying areas.

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Hypophosphorus Acid (6303-

21-5) (Used in place of red

phosphorus)

Clear

colorless

and odorless

liquid.

Corrosive

and reactive.

Strong

reducing

agent, heat

may cause

re 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. Exposure

limits N/A.

Not available.

Iodine (7553-56-2)

(Reagent in synthesis of

hydriodic acid)

Solid purple

crystals or

akes 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: 2 ppm; NIOSH

REL: C 0.1 ppm (1 mg/m

); OSHA PEL: C 0.1

ppm (1 mg/m

Slightly soluble in water (300

mg/L) with very low vapor

pressure.

Iodine, Tincture (No CAS

number) (Reagent in synthesis

of hydriodic acid)

Dark red

solution

(mixture

of ethanol,

iodine crystals

and sodium

iodide).

Flammable

(ethanol).

See description for ethanol and iodine. Not available.

Isopropyl Alcohol (67-63-0)

(Solvent)

[syn: 2-propanol, isopropanol,

dimethyl carbinol]

Colorless

liquid with

slightly bitter

taste.

Flammable. Inhalation of the vapor in high concentrations

and ingestion of the liquid may result in

headache, dizziness, mental depression,

nausea, vomiting, narcosis, anesthesia and

coma; liquid may damage eyes severely.

OSHA: TWA 400 ppm (980 mg/m

Possibly hazardous short term

degradation products are not

likely. However, long term

degradation products may

arise. The product itself and

its products of degradation

are not toxic.

Lead Acetate (6080-56-4)

(Reagent in P2P synthesis)

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 effect on the mental

development of children (lower IQ). IDLH: 100

mg/m

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.

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Lithium (metal) (7439-93-2)

(Used in Nazi/Birch and One-

Pot methods)

Soft, odorless

silvery-

white metal.

Yellowish

upon

exposure to

moist air.

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. Exposure limits N/A.

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.

Lithium Aluminum Hydride

(16853-85-3)

(Hydrogenation in multiple

processes)

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. Exposure limits N/A.

Can ignite with friction. LiOH

may be mobile in soil.

Mercuric Chloride (7487-94-7)

(Reagent in meth synthesis

using P2P method)

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: 10 mg/

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 of into

surface water it will have

negative effects on the biota.

Methyl Alcohol (67-56-1)

(Solvent; HEET Gas Line

Antifreeze is 99% methanol)

[syn: methanol, wood alcohol,

carbinol]

Clear

colorless

liquid.

Flammable

and poison.

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: 6,000 ppm; NIOSH REL: TWA

200 ppm (260 mg/m

) STEL 250 ppm (325 mg/

); OSHA PEL: TWA 200 ppm (260 mg/m

Methanol is miscible in and

lighter than water. When

released to the ground in

sufcient 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 P2P method)

[syn: methanamine,

aminomethane]

Clear colorless

gas with rotten

sh/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: 100 ppm; NIOSH REL: TWA

10 ppm (12 mg/m

); OSHA PEL: TWA 10 ppm

(12 mg/m

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 K

−0.57). Methylamine is

biodegradable.

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Methyl Ethyl Ketone (78-93-3)

(Solvent)

[syn: 2-butanone, methyl

acetone]

Clear,

colorless

liquid with a

sharp mint-like

odor.

Extremely

ammable.

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 effects. Chronic

exposure may cause dermatitis or central

nervous system effects. IDLH: 3,000 ppm;

NIOSH REL: TWA 200 ppm (590 mg/m

) STEL

300 ppm (885 mg/m

); OSHA PEL: TWA 200

ppm (590 mg/m

Methyl Ethyl Ketone is fairly

soluble in water (239,000

mg/L) and has a log K

of 0.29. If released to

the ground it will partially

evaporate, and if the release

has a sufcient quantity

to enter the subsurface

will leach to shallow

groundwater. It does not

biodegrade readily.

Nitric Acid (7697-37-2)

(Used with sodium hydroxide to

produce anhydrous ammonia

for use in One-Pot method)

[syn: ammonium nitrate,

ammonium saltpeter,

ammonium salt]

Clear

colorless to

yellowish

liquid with

suffocating

acrid odor/

white,

odorless solid

crystals.

Corrosive

oxidizer.

Inhalation causes extreme irritation of upper

respiratory tract. Skin contact can result in

deep ulcers and staining of skin. IDLH: 25

ppm; NIOSH REL: TWA 2 ppm (5 mg/m

) STEL

4 ppm (10 mg/m

); OSHA PEL: TWA 2 ppm (5

mg/m

Incompatible with most

materials.

Nitroethane (79-24-3)

(Precursor for P2P synthesis)

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: 1,000 ppm; NIOSH REL:

TWA 100 ppm (310 mg/m

); OSHA PEL: TWA 100

ppm (310 mg/m

With small spills on an

impervious or wet ground,

evaporation may be signicant.

After entering the subsurface,

likely to move through the soil

to shallow groundwater (log

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) (Used in

P2P method)

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 and redness. Absorbed through skin.

Prolonged exposure can cause dermatitis

and liver damage. IDLH: 750 ppm; NIOSH REL:

none; OSHA PEL: TWA 100 ppm (250 mg/m

Possibly hazardous short

term degradation products

are not likely. However, long

term degradation products

may arise. The products of

degradation are more toxic.

Perchloric Acid (7601-90-3)

(Used in P2P method)

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. Exposure limits N/A.

May form sensitive explosive

mixtures with organic

materials.

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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 uid, is made

up of Naphthas (Solvent)

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; NIOSH

REL: TWA 350 mg/m

C 1,800 mg/m

[15-minute];

OSHA PEL: TWA 500 ppm (2,000 mg/m

Naphthas are hydrophobic

and lighter than water.

In sufcient 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 P2P synthesis)

[syn: benzeneacetic acid,

alpha-toluic acid]

Solid white

crystal with a

oral odor.

None. Contact is irritating to skin and eyes.

Inhalation may cause upper respiratory

tract irritation. Potential teratogen.

Exposure limits N/A.

Not available.

Phenyl-2-Propanone (103-

79-7) (Precursor for meth or

amphetamine synthesis)

Clear,

moderately

viscous liquid.

None. Irritating to eyes and skin. Inhalation may lead

to headache, nausea and dizziness.

Exposure limits N/A.

Not available.

Phosphine (7803-51-2)

(Unintended byproduct of Red

Phosphorous method)

Colorless gas

with a sh- or

garlic-like

odor. [Note:

commercially

made product

has odor

phosphine

itself is

odorless.]

Flammable

and poison.

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: 50 ppm; NIOSH REL: TWA 0.3

ppm (0.4 mg/m

) STEL 1 ppm (1 mg/m

); OSHA

PEL: TWA 0.3 ppm (0.4 mg/m

Heavier than air. May

accumulate in low spots.

High reactivity will minimize

environmental effects.

Phosphoric Acid (7664-38-2)

(Precursor for meth)

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: 1,000 mg/m

; NIOSH

REL: TWA 1 mg/m3 STEL 3 mg/m

; OSHA PEL:

TWA 1 mg/m

When released in sufcient

quantities may reach shallow

groundwater.

Neutralization leaves

phosphate.

Pseudoephedrine (90-82-4)

(Precursor for meth)

Nearly

odorous,

white

crystalline

powder.

None Contact with skin or eyes may result in

irritation. Inhalation may result in respiratory

irritation. Exposure limits N/A.

Completely soluble in water

with a log K

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

P2P from phenylacetic acid

in the presence of acetic

anhydride)

Colorless

to yellow

liquid with a

nauseating

sh-like odor.

Flammable. Skin and eye irritant. Short-term inhalation

may cause irritation, headache, drowsiness,

dizziness and 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: 1,000 ppm; NIOSH REL:

TWA 5 ppm (15 mg/m

); OSHA PEL: TWA 5

ppm (15 mg/m

Pyridine is miscible in water

and has a log K

of 0.65.

As such, when released

in sufcient quantity it

should move freely through

the subsurface, and lesser

amounts will leach with

rainfall. Very biodegradable.

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Red Phosphorus (7723-14-0)

(Used in Red Phosphorus

method for meth production)

Odorless red

to violet solid.

Less reactive

than white

or yellow

phosphorus.

Flammable

and explosive

when mixed

with organic

materials. In

the presence

of water

vapor and

oxygen

decomposes

to form

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 and cardiovascular effects can

result. Exposure limits N/A.

Harmful to aquatic

organisms. Insoluble in

water. Will remain on ground

surface if released.

Sodium (7440-23-5)

(Catalyst in Nazi/Birch method)

Silvery white

solid.

Flammable

and

Corrosive.

Severe

re 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. Exposure limits N/A.

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) (Used to make sodium, a

catalyst in Nazi/Birch method;

Drano® contains 30-60% by

weight of sodium hydroxide)

Colorless to

white solid

(akes, beads,

pellets).

Corrosive

and poison.

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: 10 mg/m

; NIOSH REL: C 2 mg/m

; OSHA

PEL: TWA 2 mg/m

Dissolves in water with

release of heat, creating a

high pH solution.

Sodium Thiosulfate (7772-98-

7) (Used in Red Phosphorous

method to remove remaining

iodine from solution)

[syn: sodium hyposulte,

“hypo”, antichlor, sodothiol,

sulfothiorine, ametox]

Powder;

odorless

crystals or

granules.

None. Moderately toxic by subcutaneous routes

Exposure limits N/A.

Possibly hazardous short

term degradation products

are not likely. However, long

term degradation products

may arise. The product

itself and its products of

degradation are not toxic.

Sulfuric Acid (7664-93-9)

(Reagent and main component

in generating HCl; Battery

acid is sulfuric. Used battery

acid may contain high

concentrations of lead. Liquid

Fire Drain Cleaner contains

sulfuric acid) [syn: oil of vitriol,

hydrogen sulfate]

Colorless

to yellow

viscous,

odorless

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: 15 mg/m

; NIOSH REL: TWA 1 mg/m

;

OSHA PEL: TWA 1 mg/m

Miscible with water with

evolution of heat. In sufcient

quantity may leach to shallow

groundwater. Release to a

surface water may be

toxic to aquatic organisms

if sufcient energy is not

available for quick dilution.

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Chemical and CAS Number Form Hazard Health Effect Fate and Transport

Thionyl Chloride (7719-09-7)

(Reacts with ephedrine or

pseudoephedrine to form

intermediary) [syn: sulfurous

oxychloride]

Pale yellow to

red liquid

with a

pungent

characteristic

odor.

Corrosive

and poison.

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. IDLH: none; NIOSH REL: C 1 ppm

(5 mg/m

); OSHA PEL: none.

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 P2P synthesis)

White heavy

crystalline

powder.

None. Irritant to skin and eyes. May cause mild

irritation to respiratory system when inhaled.

Thorium is a conrmed human carcinogen

producing anglosarcoma, liver and kidney

tumors, lymphoma and other tumors of the

blood system. Chances of developing cancer

increase with increased exposure. Exposure

limits N/A.

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) (Solvent)

[syn: methyl benzene,

phenylmethane]

Clear

colorless

liquid with an

aromatic odor.

Flammable

and poison.

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: 500 ppm; NIOSH REL:

TWA 100 ppm (375 mg/m

) STEL 150 ppm (560

mg/m

); OSHA PEL: TWA 200 ppm C 300 ppm

500 ppm [10-minute maximum peak].

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).

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

(Solvent)

Colorless liquid

with sweet

odor.

None. Inhalation may cause irritation, irregular

heartbeat, headache, symptoms of

drunkenness and kidney and liver damage.

IDLH: 100 ppm; NIOSH REL: Ca TWA 10 ppm

(45 mg/m

) [skin]; OSHA PEL: TWA 10 ppm (45

mg/m

) [skin].

Slightly soluble in water

(4,420 mg/L). Has a log K

2.07; unlikely to sorb to soil. If

released in sufcient 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-

Triuoroethane (76-13-1)

(Solvent)

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: 2,000 ppm;

NIOSH REL: TWA 1,000 ppm (7,600 mg/m

)

STEL 1,250 ppm (9,500 mg/m

); OSHA PEL:

TWA 1,000 ppm (7,600 mg/m

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

Triuoroethane 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 specic gravity),

it should move through

the subsurface and with

sufcient head, through the

water table. 1,1,2-Trichloro-

1,2,2-Triuoroethane does not

readily biodegrade.

C — Ceiling REL

Ca — Potential Carcinogen

CAS — Chemical Abstracts Service

HCl — Hydrochloric Acid

HI — Hydrogen Iodide

IDLH — Immediately Dangerous to Life or Health

LiOH — Lithium Hydroxide

Li2O — Lithium Oxide

logK

— Octanol-Water Partition Coefcient

MCL — Maximum Contaminant Level

NIOSH REL — NIOSH Recommended Exposure Limit

OSHA PEL — OSHA Permissible Exposure Limits

SO2 — Sulphur Dioxide

STEL — Short-Term Exposure Limit

TWA — Time Weighted Average

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Appendix D: Meth Resources

Because state requirements and guidelines change frequently, please consult your appropriate municipal, county,

orstateagencyforthemostuptodateinformation.Stateswith**referenceEPAguidanceonclandestinedruglab

cleanup. Links provided below were active at the time of publication.

State Resources

Alaska

hps://dec.alaska.gov/spar/csp/meth-lab/

Arkansas

hps://www.adeq.state.ar.us/poa/cscpc/

California

hps://dtsc.ca.gov/erp/drug-lab-removals-erp/

Colorado

hps://www.colorado.gov/pacic/cdphe/methlabcleanup

Connecticut

hps://portal.ct.gov/-/media/Departments-and-Agencies/DPH/dph/environmental_health/eoha/pdf/

METHLABCLEANUPPROTOCOLpdf.pdf

Florida

hp://www.oridadec.org/webles.nsf/WF/KGRG-6UJQUQ/$le/METHAMPHETAMINEGuideline.pdf

Georgia

hps://dph.georgia.gov/sites/dph.georgia.gov/les/related_les/site_page/EnvHealthChemHazMethLabBrochure.pdf

Hawaii

hps://health.hawaii.gov/heer/les/2019/11/methfactsheet062107.pdf

Idaho

hps://healthandwelfare.idaho.gov/health-wellness/environmental-health/clandestine-labs

Illinois**

hp://www.idph.state.il.us/envhealth/factsheets/meth-cleanup.htm

Indiana

hps://www.in.gov/meth/2335.htm

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Iowa

hp://publications.iowa.gov/9239/1/meth_lab_cleanup.pdf

Kansas**

hp://www.kdheks.gov/methlabs/ml_cleanup.html

Kentucky

hps://eec.ky.gov/Environmental-Protection/Waste/superfund/methamphetamine-lab-cleanup/Pages/default.aspx

Louisiana

hps://internet.deq.louisiana.gov/portal/Portals/0/remediation/meth_cleanup_guidelines.pdf

Michigan

hps://www.michigan.gov/documents/mdch/MI_Guidelines_459934_7.pdf

Minnesota**

hps://www.health.state.mn.us/communities/environment/meth/

Missouri**

hps://health.mo.gov/atoz/pdf/MethLabCleanupGuidelines.pdf

Montana

hps://deq.mt.gov/cleanupandrec/programs/meth

Nebraska

hps://www.methlabcleanup.com/NE%20FinalRegs.pdf

New Mexico**

hps://www.env.nm.gov/hazardous-waste/clandestine-drug-laboratories-cleanup-guidance-3/

North Carolina**

hps://epi.publichealth.nc.gov/oee/a_z/meth.html

hps://epi.publichealth.nc.gov/oii/pdf/methguidelines.pdf

Ohio**

hps://odh.ohio.gov/wps/wcm/connect/gov/b5bc46c7-2138-4115-9e46-426690c1bbe6/

methlabcleanup.pdf?MOD=AJPERES&CONVERT_TO=url&CACHEID=ROOTWORKSPACE.Z18_

M1HGGIK0N0JO00QO9DDDDM3000-b5bc46c7-2138-4115-9e46-426690c1bbe6-mjNgGNd

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Oklahoma

hps://www.deq.ok.gov/wp-content/uploads/land-division/Guidelines-for-Cleaning-Up-Former-Methamphetamine-

Labs.pdf

Oregon

hps://www.oregon.gov/oha/PH/HEALTHYENVIRONMENTS/HEALTHYNEIGHBORHOODS/

CLANDESTINEDRUGLABS/Pages/index.aspx

South Dakota**

hps://denr.sd.gov/des/wm/hw/hwmeth.aspx

Tennessee

hps://www.tn.gov/environment/program-areas/rem-remediation/meth.html

Utah

hps://deq.utah.gov/environmental-response-and-remediation/cercla-comprehensive-environmental-response-

compensation-and-liability-act/clandestine-drug-lab-cleanup-program

Virginia**

hps://www.vdh.virginia.gov/home/guidelines-for-cleanup-of-residential-property-used-to-manufacture-

methamphetamine/

Washington

hps://www.doh.wa.gov/AboutUs/ProgramsandServices/EnvironmentalPublicHealth/EnvironmentalHealthandSafety/

DrugLabCleanup/

West Virginia

hp://www.wvdhhr.org/rtia/Meth.asp

Wisconsin**

hps://www.dhs.wisconsin.gov/chemical/clean-lab.htm

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Other Resources

AssociationofStateandTerritorialSolidWasteManagementOcials(2006)Clandestine Drug Laboratory

Remediation: A Guide to Post Emergency Response

hp://www.astswmo.org/les/policies/CERCLA_and_Brownelds/removals/Drug-Lab-Paper-nal.pdf

Arbuckle,ShawnL.,EricJ.Esswein,NicolaErb,JohnW.Martyny,CharlesS.McCammonJr.,MikeVanDyke(2007)

Chemical concentrations and contamination associated with clandestine methamphetamine laboratories, Journal of Chemical

Health & Safety, pgs. 40-52

hps://www.sciencedirect.com/science/article/abs/pii/S187155320700014X#:~:text=Reference%20Levels%20%20%20%20

Chemical%20%20,%20%20None%20%201%20more%20rows%20

Contreras,John,ShaleceKoord,JohnW.Martyny,KateA.Serrano,MikeV.VanDyke(2011)Variability and Specicity

Associated with Environmental Methamphetamine Sampling and Analysis, Journal of Occupational and Environmental Hygiene,

vol. 8:11, pgs. 636-641

hps://pubmed.ncbi.nlm.nih.gov/21962231/

NationalJewishMedicalandResearchCenter(2004)Chemical Exposures Associated with Clandestine Methamphetamine

Laboratories Using the Anhydrous Ammonia Method of Production

hps://www.env.nm.gov/wp-content/uploads/sites/12/2019/10/Ammonia_Meth.pdf

UnitedStatesDepartmentofJustice/DrugEnforcementAdministration(2020)Methamphetamine Fact Sheet

hps://www.dea.gov/factsheets/methamphetamine

UnitedStatesEnvironmentalProtectionAgency(2008)RCRA Hazardous Waste Identication of Methamphetamine

Production Process By-products

hps://archive.epa.gov/epawaste/hazard/web/pdf/rtc-meth.pdf

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Appendix E: Meth Lab Remediation

Diagrams

Cleanup Plan Development

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Site Remediation

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Appendix F: Fentanyl Resources

Federal Resources

U.S. Environmental Protection Agency (EPA)

UnitedStatesEnvironmentalProtectionAgency(2018)Fact Sheet for OSCs: Fentanyl and Fentanyl Analogs

hps://www.epa.gov/sites/production/les/2018-07/documents/fentanyl_fact_sheet_ver_7-26-18.pdf

UnitedStatesEnvironmentalProtectionAgency(2018)Fentanyl Toxicity, Exposure and Risk

hps://www.epa.gov/sites/production/les/2018-11/documents/decon_presentation_010.pdf

Centers for Disease Control and Prevention (CDC)

CentersforDiseaseControlandPrevention(2020)Synthetic Opioid Overdose Data

hps://www.cdc.gov/drugoverdose/data/fentanyl.html

CentersforDiseaseControlandPrevention,NationalInstituteforOccupationalSafetyandHealth(2019)Illicit Drug

Tool-Kit for First Responders

hps://www.cdc.gov/niosh/topics/fentanyl/toolkit.html

CentersforDiseaseControlandPrevention,NationalInstituteforOccupationalSafetyandHealth(2020)Illicit Drugs,

Including Fentanyl

hps://www.cdc.gov/niosh/topics/fentanyl/risk.html

CentersforDiseaseControlandPrevention,NationalInstituteforOccupationalSafetyandHealth(2019)Using

Naloxone to Reverse Opioid Overdose in the Workplace: Information for Employers and Workers

hps://www.cdc.gov/niosh/docs/2019-101/pdfs/2019-101.pdf?id=10.26616/NIOSHPUB2019101

SpencerMR,WarnerM,BastianBA,TrinidadJP,HedegaardH.2019)Drug Overdose Deaths Involving Fentanyl, 2011–

2016. National Vital Statistics Reports; vol. 68 no 3. Hyasville, MD: National Center for Health Statistics

hps://www.cdc.gov/nchs/data/nvsr/nvsr68/nvsr68_03-508.pdf

Drug Enforcement Administration (DEA)

UnitedStatesDepartmentofJustice/DrugEnforcementAdministration(2020)Fentanyl Fact Sheet

hps://www.dea.gov/factsheets/fentanyl

United States Department of Justice/United States Drug Enforcement Administration, Strategic Intelligence Section

(2018)Fentanyl Remains the Most Signicant Synthetic Opioid Threat and Poses the Greatest Threat to the Opioid User Market

in the United Stateshps://www.dea.gov/sites/default/les/2018-07/PRB-DIB-003-18.pdf

National Institutes of Health (NIH)

NationalInstitutesofEnvironmentalHealthSciences(2018)Prevention of Occupational Exposure to Fentanyl and

Other Opioids

hps://tools.niehs.nih.gov/wetp/public/hasl_get_blob.cfm?ID=11206

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

State Resources

California

CaliforniaLegislativeInformation(2019)AB-1596 Hazardous Substances: Contaminated Property: Fentanyl Cleanup

hps://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201920200AB1596

Minnesota

MinnesotaDepartmentofHealth(2019)Fentanyl Exposures and Cleanup

hps://www.health.state.mn.us/communities/environment/hazardous/docs/fentanylexpcln.pdf

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Appendix G: Common Fentanyl Analogs

Fentanylanalogshaveasimilarchemicalstructuretofentanylwithsimilareects.Smallstructuralchangesinthe

compound can result in a seemingly endless number of variations of the drug with potentially unknown potency. The

following are a few of the more common analogs known at the time of publishing.

Analog Description

Carfentanil Extremely potent fentanyl analog, 10,000 times more potent than morphine (100 times more potent than

fentanyl). Not intended for human use, but for use as large mammal tranquilizers. The lethal dose of

carfentanil is generally accepted to be approximately 0.02 mg.

3-Methylfentanyl Approximately 6,300 times stronger than morphine and 28 times more potent than fentanyl. A "designer"

opiate that has caused more than 100 overdose deaths in California since 1979. High potency makes it an

attractive target to clandestine drug producers.

Sufentanil Approximately 7.5 times as potent as fentanyl. Typically used to help relieve pain.

Remifentanil Remifentanil is used in anesthesia and to manage pain.

Furanylfentanyl Estimates of the potency of furanylfentanyl vary but suggest that they are less potent than fentanyl. Has

no currently accepted medical use in the United States. Over the course of 4 months in 2016, seven fatal

intoxications involving furanylfentanyl occurred in Sweden.

Acetylfentanyl Estimates of the potency of acetylfentanyl vary but suggest that they are less potent than fentanyl. Never

licensed for medical use.

Sources: PubMed and ChemMed

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Appendix H: Fentanyl Lab Remediation

Diagrams

Cleanup Plan Development

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Site Remediation

U.S. EPA Voluntary Guidelines for Methamphetamine and Fentanyl Laboratory Cleanup

Appendix I: Photo Credits

Front cover inset and page 8 photo credit: Tacoma-Pierce County, Washington Health Department.

Pages 9 and 25 photos credit: National Jewish Health.

Page32photocredit:U.S.DrugEnforcementAdministration(DEA).

United States

Environmental Protection

Agency

Ofﬁce of Land and Emergency

Management (OLEM)

EPA-540-B-21-002

August 2021

epa.gov