EL DORADO COUNTY ENVIRONMENTAL MANAGEMENT DEPARTMENT POLICIES AND ...

astes and
related materials are properly disposed of and to oversee any additional cleanup of residual
contamination that may be necessary prior to allowing any re-occupancy of an affected
dwelling.
Response procedures for clandestine laboratories include all standard procedures normally
followed for other types of hazmat incidents. These procedures include assessment,
identification of hazards, developing an action/safety plan, performing the containment or
initial clean up, decontamination and documentation. Additional tasks specific to drug labs
may include the dismantling of an active lab, taking samples to be used as evidence,
obtaining approval for State funding of disposal, oversee the work of private contractors
and overseeing the cleanup of residual contamination. This policy will not restate standard
procedures. Rather, it focuses on tasks specific to clandestine drug labs.
1.
Response
Notifications of clandestine drug laboratories may come from the public, from
Central Dispatch or directly from the El Dorado County Narcotics Enforcement Task
Force (ENET). If the notification has not come from ENET, then ENET must be
notified immediately. Contact with an ENET detective must be established to
ascertain the nature and size of the lab. This information will determine the
appropriate response in terms of staffing levels and equipment requirements.
The first task unique to drug labs may be the dismantling of an active cooking
operation. If the site assessment reveals an active cooking operation and chemists
from the State Department of Justice (DOJ) are involved in the response, then those
chemists will be given the task of dismantling the laboratory equipment. If DOJ chemists are not involved, proceed with caution. Once the ENET detectives have
determined that any existing booby traps have been removed an entry can be made.
Power and water supplies connected to cooling equipment and condensers should be
left on. Power supplies to sources of heat should be disconnected first and reaction
vessels allowed to cool completely. With continuos air monitoring, equipment may
then be dismantled. Special attention must be given to safety, proper personal
protective equipment (PPE) selection, air monitoring, adequate ventilation and
decontamination.
The second and more common task specific to drug labs is the collection of samples
for evidence. Proper sampling methods include the use of clean equipment, container
labeling and chain of custody documentation. All samples shall be signed over to the
ENET detectives prior to leaving the site. The samples will be transported to the DOJ
lab for analysis.
The third specific task is the performance of a site assessment to determine what
contamination may exist. Hazardous waste contamination can be in the form of soil,
septic tank/leach field and surface contamination of dwellings and household items.
Potentially contaminated areas can be identified by interviews of suspects, and by the
presence of dead vegetation, unusual staining or chemical odors.
2.
Disposal of Hazardous Wastes and Materials
Over half of the laboratories discovered in El Dorado County have relatively small
amounts of hazardous waste. After samples are taken, these wastes can often be
disposed of through the household hazardous waste disposal program. Wastes should
be segregated into primary hazard categories onsite in order to be packaged in
accordance with our Departments standard lab packing protocol.
For laboratories having large quantities of waste, disposal funding may be obtained
through the Department of Toxic Substances Controls (DTSC) Illegal Drug Lab
Cleanup Account (IDLCA). If all funding criteria are satisfied, IDLCA funds may be
used for disposal of chemical wastes and for removal of grossly contaminated soil.
The written guidance for accessing funding is stored in the response van file cabinet.
Specific criteria for receiving funding include the wastes must be hazardous, the
responsible party is unwilling or unable to pay, and the incident occurred on private
property. Environmental Management responders must oversee private cleanup
contractors removal actions and provide written reports to DTSC.
All glassware, lab equipment, and any items involved in the manufacturing process
must be rendered useless. All glassware must be broken and control equipment
must be destroyed. This waste can then be packaged with compatible materials
destined for landfill. No materials contaminated with red phosphorous may be
packaged with this debris. If hypodermic needles are present they shall be placed
in a sharps container. If ammunition is discovered it shall be given to the ENET
detectives or if discovered later taken to El Dorado County Sheriffs Departments property and evidence storage area.
3.
Remediation of Residual Contamination
Prior to leaving the site, dwellings and any associated outbuildings must be posted
with a warning sign. The warning sign will state that a clandestine drug lab was
seized and there still may be hazardous substances onsite. If during the
environmental assessment the presence of contamination is tentatively identified or
suspected, the property owner must be contacted and sent a Notice and Order and
a copy of the drug lab protocol by certified mail. The Notice and Order advises
property owners of the situation and directs them to follow the drug lab protocol.
The protocol lists the steps which must be taken in order to ensure that any
contaminated buildings are not re-occupied prior to adequate clean up. Property
owners must contract with a certified industrial hygienist (CIH) to evaluate and
decontaminate the property if required, to qualify for re-occupancy approval.
4.
Re-occupancy of Affected Dwellings
The CIH will perform sampling of potentially contaminated areas. Based upon the
sampling results the CIH will prepare and submit a proposed cleanup plan to the
department for review. If the report indicates that no further action is required and
the department agrees with that report, a closure letter will be issued to the property
owner and re-occupancy of the building may then take place.
If the report indicates that additional cleanup is required the cleanup must be
performed by a hazardous waste handler and hauler. Reports proving proper
disposal must be received by our department. The need for confirmation sampling
will then be discussed with the CIH. If confirmation sampling and a final report by
the CIH confirm that the property has been properly cleaned, a closure letter will be
issued to the property owner and re-occupancy of the building may then take place.
Failure to properly complete the cleanup of the property will result in the recording
of a certificate of nuisance against the property at the County Assessors office.



Director of Environmental Management
Date
H:\docs\drugs\Drug Lab Policy DRUG LAB PROTOCOL
This protocol is designed to help you with the process of evaluating and decontaminating your property to qualify
for re-occupancy approval.
NOTE: IF THIS DEPARTMENT DOES NOT HEAR FROM YOU WITHIN 7 WORKING DAYS OF THE
RECEIPT OF THE DRUG LAB NOTICE, A CERTIFICATE OF NUISANCE AGAINST YOUR
PROPERTY WILL BE RECORDED AT THE EL DORADO COUNTY ASSESSOR=S OFFICE.
SECURING YOUR PROPERTY:
1.
Ensure that the building is not re-occupied. This may include changing the locks or boarding up the
building. The items inside the building may be contaminated with chemicals that were used to manufacture
illegal drugs. If you allow any of the items inside the building to be removed, you the property owner may
be personally liable if someone is exposed to chemical residue left over from the lab.
SAMPLING
2.
Contact a Certified Industrial Hygienist (CIH). Inform them that a drug lab was discovered on your
property and request an estimate of the costs to evaluate the property for re-occupancy. Also, tell them that
confirmation sampling may be needed at the end of any cleanup, and to provide you an estimate of the
costs. The CIH will need to contact this department to obtain information about the types of chemicals
used, the quantity involved, the manufacturing method and the locations of areas which may be
contaminated.
NOTE: CERTIFIED INDUSTRIAL HYGIENISTS CAN BE FOUND IN THE SACRAMENTO AREA
YELLOW PAGES UNDER INDUSTRIAL HYGIENE CONSULTANTS. THIS IS A
COMPETITIVE BUSINESS AND YOU MAY WANT TO OBTAIN ESTIMATES FROM MORE
THAN ONE CIH.
3.
Once you have contracted with a CIH, provide this department with the hygienist=s name. We may need
to be onsite during the sampling to ensure that our concerns are met. Test results should be available in
about two weeks after the sample are taken.
4.
Once you receive the sample results and the proposed cleanup plan, ensure that the CIH has also sent a
copy of this information to our department.
5.
We will review the analytical data and the proposed cleanup plan for completeness. If the results indicate
that no further actions are necessary and this department agrees with the report, a closure letter will be
issued to you and re-occupancy of the building may then take place.
CLEANUP
6.
If the property is contaminated, it must be cleaned up by a Hazardous Waste Handler and Hauler. The
cleanup will generate hazardous waste which will have to be documented and disposed of properly.
7.
Once the cleanup, either you or the company you hired must send a copy of all reports to this office along
with copies of the documents proving proper disposal.