Other Remediation Issues to Consider During Meth Lab Cleanups
By Peter D. Cappel, Gobbell Hays Partners, Inc.
pcappel@ghp1.com
Meth labs can be very dangerous for law
enforcement personnel. Following the bust, first responders are also
exposed to a variety of hazards. Aside from the operators of the lab, the
hazards for law enforcement and first responders may include: hazardous
chemicals, booby traps, used syringes, abandoned weapons, etc.
Typically first responders will remove bulk
chemicals from the lab, however, some hazardous materials may be left
behind. In addition to any bulk chemicals that remain in the lab,
contamination caused by the illegal drug manufacturing is frequently
present. To successfully remediate a property contaminated by the
operation of a meth lab it may be necessary to disturb building materials,
building fixtures, personal contents, mechanical systems, etc. These
activities may disturb other hazardous and/or regulated materials
unrelated to the drug lab, such as asbestos, lead-based paint (LBP), mold,
poly chlorinated biphenyls (PCBs), mercury, chlorinated fluoro-carbons
(CFCs) and others.
The purpose of this article is to remind those
of us involved with meth lab cleanups that there are other hazards to be
aware of when dealing with these projects.
Asbestos-Containing Materials (ACMs)
If it is anticipated that the lab cleanup will disturb suspect
asbestos-containing materials, an asbestos inspection should be
conducted. The Colorado Department of Public Health and Environment
(CDPHE) through Regulation No. 8, The Control of Asbestos, 5 CCR 1001-10,
Part B (“Regulation No. 8”), sets forth the requirements for asbestos
inspections prior to renovation and demolition activities. Also,
Regulation No. 8 references a list of suspect asbestos-containing
materials that can be used in determining whether a planned meth lab
cleanup may impact ACM. This list is also provided by the Environmental
Protection Agency (EPA) and can be found in Appendix G of Managing
Asbestos Place (also commonly referred to as the EPA ”Green Book”).
Note that meth lab cleaning activities, while not always considered
traditional demolition or construction activities, may still disturb ACM.
CDPHE recommends that all buildings be inspected prior to any renovation
or demolition activities, regardless of the date of construction. Please
refer to Regulation No. 8 for particular requirements which can be found
at http://www.cdphe.state.co.us/op/regs/airregs.asp.
In addition to Regulation No. 8, the
Occupational Safety and Health Administration (OSHA) has both a
Construction Standard (1926.1101) and a General Industry Standard
(1910.1001) for asbestos. Copies of these standards can be obtained at
www.osha.gov. Also, you should be aware that EPA and local agencies have
additional requirements related to asbestos that may be applicable to your
projects.
Lead-Based Paint (LBP)
Lead-based paint may be present in some older buildings. Lead was
used as an additive in paints up until 1978. If painted surfaces are to
be impacted in buildings constructed around 1978 or earlier, an inspection
for LBP should be conducted prior to disturbing painted surfaces. OSHA,
EPA and CDPHE have regulations that apply to lead and lead-based paint.
In addition to paint, lead may be found in plumbing lines, plumbing
fixtures, and solder in fixtures such as drinking fountain components;
batteries and other items commonly found in buildings. Prior to
disturbing these materials they should be inspected for lead or assumed to
contain lead and handled in accordance with applicable regulations.
Recycling of some lead-containing items may be a viable option. Proper
disposal of lead-containing materials will be necessary.
Mold
When conducting assessments for meth labs, if any historical water
damage is identified in the building, mold growth may be present. If the
lab cleanup plan entails removal of buildings components such as walls,
floors, ceilings, shower enclosures or tubs, a contingency plan should be
provided in the event that mold growth is found. Currently there are no
regulations within Colorado pertaining to mold. However, if mold is found
during the cleanup of a lab, industry standards for mold remediation
should be followed. These standards include, without limitation, EPA’s
Guidance Document – Mold Remediation in Schools and Commercial
Buildings available at
www.epa.gov/iaq and New York City Guidelines, New York City
Department of Health and Mental Hygiene Bureau of Environmental and
Occupational Disease Epidemiology Guidelines on Assessments and
Remediation of Fungi in Indoor Environments.
Other Potential Hazards
Several other potential hazards that may be encountered and planned
for may include materials such as PCBs, mercury and CFCs. PCBs may be
found in various electrical components with transformers and capacitors.
For example, the capacitors in older fluorescent light fixture ballasts
may contain PCBs. Also, mercury may be present in fluorescent light tubes
and HVAC system thermostats. PCBs and mercury require special handling
and disposal. Recycling liquid mercury in thermostats through a qualified
firm may be an option. Finally, CFCs which are found in refrigerators and
air conditioning units must be recovered by a qualified contractor before
disposal of the appliance.
Summary
In summary, there are many hazards that will be encountered during a
meth lab assessment and cleanup. This article has just brushed the
surface of a variety of environmental, health and safety issues that may
be encountered and is not intended to cover all applicable regulations or
hazards. You are encouraged to review the standards and guidelines
mentioned above and research other applicable regulations.
When developing a scope of work for the
cleanup of a lab it will be necessary to consider other hazards that will
be encountered. The pre-planning stage is the time to investigate and
address these other issues. A properly developed scope of work can
include engineering controls, worker protection, work practices and
material handling for a variety of hazardous and/or regulated materials.
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