**Public Health Response to Clandestine Methamphetamine Laboratory
Sites**

# 2006 - 2007 

#  Environmental Public Health Leadership Institute Fellow:

# 

**Michael L. Allen B.S., M.S. R.S.**

*Ingham County Health Department*

*5303 S. Cedar St, Lansing, Mi 48910*

*Phone 517-887-4312, FAX 517-887-4560*

*[www.ingham.org](http://www.ingham.org/), <heallen@ingham.org>*

# Mentor:

**Brian Hubbard, MPH**

*Centers for Disease Control and Prevention*

*National Center for Environmental Health*

*4770 Buford Highway, NE*

*Mail Stop F-28*

*Atlanta, GA 30341-3724*

> ![](media/image1.jpeg){width="1.3756944444444446in"
> height="0.6368055555555555in"}

# EXECUTIVE SUMMARY:

The identification of significant numbers of Clandestine Drug Laboratory
(CDL) sites in Mid-Michigan has created a potential health risk for site
occupants and a generally unsatisfactory system for site clearance.
Methamphetamine production in Michigan, in particular, is solely based
on small scale production sites, almost solely in residential areas.
There are currently no federal or State of Michigan Standards or
Guidelines for CDL site clean-up or clearance, and no standardized
regulatory procedure for local officials. Many states have already
adopted clean-up standards but they cover a wide range of approaches
each with potential cost/benefit advantages and disadvantages. There is
also no source of collected data on site disposition after initial
identification. We do have data for incidence of discovered CDLs but no
prevalence data nor reliable data on clean-up methods or costs.

This project sought to identify stakeholders, incorporate their varied
needs and opinions, and develop state guidelines for clean-up and
clearance which encourage safe and rapid re-occupancy. This project also
seeks to create better partnerships between environmental health
agencies, housing agencies, and landlord. This project also seeks to
gather and disseminate data on site prevalence and disposition.

# INTRODUCTION/BACKGROUND:

There has been a significant increase in residential sites discovered
harboring CDL's, specifically manufacturing methamphetamines (meth)^1^.
The number of identified meth CDL's in the State of Michigan has
increased from 10 in 1999 to 341 in 2005 (available at:
[www.dea.gov](http://www.dea.gov/)). There are many reasons sited for
this increase, including; increased methamphetamine use^2^, increased
prosecution of other drug use^3^, ease of information transmission
(internet)^4^, and even the psychology of fads. Regardless of causation,
meth production is subject to economic forces.

Marijuana can be grown almost anywhere in the continental United States
but requires a sufficient area of "discrete" growing land or significant
investment in greenhouse equipment. Cocaine may be processed from coca
leaves but requires large amounts of coca leaf raw material. Such
economic constraints encourage the development of fairly large scale
production coupled with an equally large scale distribution network. The
result is fewer, but larger production sites and a large distribution
network (and subsequent crime).

Methamphetamine may be produced in small amounts, with readily available
ingredients^5^. Techniques and recipes are widely available. This has
encouraged the growth of many small production centers and reduced the
need for distribution networks^6^. Most meth production is small scale
and designed to service a small, close nit group of consumers, often
friends and family.

![](media/image2.wmf){width="6.122916666666667in"
height="2.0833333333333335in"}

This phenomena has brought a new version of classic drug related public
health problems and created a new public health issue^7^, how to deal
with the identified CDL site. There are several methods for production
of methamphetamine, all of which use chemicals that have the potential
of contaminating the production site. Additionally, all common meth
production techniques release methamphetamine itself into the air which
almost always contaminates the site^8^. Most of these sites are
residential. Because of the small scale of operations, CDL's are often
moved from site to site periodically, to prevent discovery by law
enforcement. Any one manufacturer therefore may contaminate many sites.

Most federal legislation has focused on the drug itself. The
*Comprehensive Methamphetamine Control Act of 1996 (MCA)* broadened the
controls on listed chemicals used in the production of methamphetamine
(information available at:
<http://www.fda.gov/cder/news/methamphetamine.htm> ). This was followed
by the *Combat Methamphetamine Epidemic Act of 2005*, a nationwide
measure to limit access to drugs containing ephedrine, pseudoepedrine,
and phenylpropanolamine. Both of these acts have acted to begin shifting
the economic forces away from small scale manufacturing. It remains to
be seen whether or not this will encourage the growth of large scale
manufacturing and distribution.

The *Children\'s Health Act of 2000* included provisions requiring the
reporting of discovered CDL's to their respective states and to the
federal Department of Drug Enforcement Administration. It also provides
money to law enforcement agencies for laboratory "clean-up". However,
this has been interpreted as funding the cost of securing the site by
law enforcement, and the removal and disposal of bulk chemicals found.
No moneys have been made available for site environmental investigations
or clearance.

There are also no federal guidelines for what constitutes a site
clearance. There are also no definitive studies on the potential health
risks associated with former CDLs.

Currently the State of Michigan (Public Act 307 of 2003) places
authority over site clearance on local housing code agencies. The
assumption on the part of the state legislature was that such agencies
would require these sites to be inspected and "cleared" before occupancy
to prevent hazardous chemical exposure to residents. The State of
Michigan did not provide a set of clean-up standards or guidelines or
any money. Local housing code officials are unprepared to make such
determinations.

The cost of inspection and clean-up can be significant. These costs are
highly dependent upon the specific requirements for clearance. There is
a wide variety of state guidelines for meth site clearance. Some require
extensive testing, some require state certified inspectors, and some
allow property owners to define their own clearance. CDLs established in
lower value homes are often either reopened illegally or abandoned.
Counties which have seen an increase in meth-lab homes begin
accumulating vacant "red-tagged" homes.

####### **Problem Statement***: Due to both cost of site clearance and lack of defined standards, identified CDLs have begun to accumulate in Michigan counties. These sites pose a potential (though inadequately defined) exposure risk to future occupants. These sites have either been reoccupied without adequate clean-up or abandoned altogether. There is a need in the State of Michigan for adequate but cost effect clean-up standards. There is a need throughout the United States for data on the disposition of these sites.* 

####### 

####### ***Behavior Over Time Graph:***

####### 

#######  

####### ***Causal Loop Diagrams and Applicable Aarchetypes:***

![](media/image3.wmf){width="9.876388888888888in"
height="5.819444444444445in"}

####### ***10 Essential Environmental Health Services:***

Describe how your project seeks to enhance or fulfill one or more of the
10 Essential Environmental Health Services and/or the three (3)
functions described in the IOM report: assessment, policy development
and assurance.

![](media/image4.png){width="3.75in" height="3.8125in"}

####### ***National Goals Supported*** 

1\. CDC Health Protection Goals are available at:
<http://www.cdc.gov/about/goals/default.htm>. Among these goals are
specific goals for physical sites, including residential sites (Healthy
Homes). This project seeks to ensure safe reoccupancy of potentially
contaminated residential sites. The work done here will assist in
developing a better working relationship between environmental and
public health and housing agencies. The lessons learned have application
to other residential, environmental issues such as mold remediation.
Also these site based goals include communities (Healthy Communities).
There is considerable data accumulating that many community factors
influence the health of residents, these factors include quality of
neighborhoods including abandoned properties. This project seeks to
reduce property abandonment.

2\. The National Strategy to Revitalize Environmental Public Health
Services can be found at
<http://www.cdc.gov/nceh/ehs/Docs/nationalstrategy2003.pdf> . Among the
listed goals is Goal IV, Create Strategic Partnerships. This project
seeks to create a missing partnership. This is the partnership between
environmental health, housing agencies, and landlords. I am a founding
member of the Michigan Association of Housing Officials and the only
representative from either state or local public or environmental health
agencies in the organization. I am also the first state or local
government, environmental agency representative on the Mid-Michigan
Landlord Association (or any of the Michigan landlord organizations).
The State of Michigan Clandestine Drug Laboratory Guidelines Task Force
brought together landlords, housing officials, environmental consultant
firms, and state and local environmental agencies to develop workable
guidelines.

Environmental Health Competency Project: Recommendation for Core
Competencies for Local Environmental Health Practitioners can be found
at: <http://www.apha.org/ppp/Env_Comp_Booklet.pdf> . Among the core
competencies listed is: **" B2** Economic and Political Issues: "

  ------------------------- -------------------- ------------------------
  Specific Core Competency  Project              Process
                            Applicability        

  Understand and maintain   CDLs present a       Data collection and
  awareness of basic        specific economic    analysis on site
  economic issues.          case unlike most     dispositions.
                            drug production.     

  Understand local history  CDLs incidence is    Data collection and
  and community             not static and       analysis on site
  demographics, as well as  project will help    dispositions.
  cultural and political    clarify historic and 
  issues and sensitivities. future trends.       

  Enforce regulations       CDL currently have a Development of
  equitably and             weak regulatory      State-wide guidelines.
  consistently - but with   status.              
  an awareness of the                            
  political realities of                         
  the work                                       

  Develop and present       Many other states    Review of other state
  options                   have already         statutes was done at the
                            developed guidelines outset of the Michigan
                            or standards with a  State Task Force.
                            wide variety of      
                            approaches.          

  Understand the economic   Need to bring in a   State Task Force
  and political             variety of           included environmental
  underpinnings and         stakeholders.        and public health
  implications of broader                        agencies, housing
  agency                                         authorities, landlords,
  priorities/decisions.                          and environmental
                                                 consultants.
  ------------------------- -------------------- ------------------------

#######  {#section-5 .unnumbered}

# PROJECT OBJECTIVES/DESCRIPTION/DELIVERABLES:

####### Program Goal: 

####### *To reduce residential, chemical exposures to Michigan citizens through the creation of a cooperative, relationship between Public and Environmental Health Agencies, Housing Agencies, Law Enforcement, and Property Owners (in particular Landlords), both formal and informal, both at the local and state level.* 

####### ***Health Problem:*** 

####### ***Potential exposure to precursor chemicals or methamphetamine.*** 

####### ***Potential social health impacts derived from abandoned residential sites.*** 

####### ***Outcome Objective:*** 

####### ***To reduce potential exposure to future residents of identified CDL sites.*** 

####### ***To develop a cooperative relationship between Environmental Health, Housing and Landlords.*** 

####### ***Determinant:*** 

####### ***Adoption of cost effective State of Michigan CDL Clean-up Guidelines***

####### ***Presentation of Guidelines to both Michigan Association of Housing Officials (MAHO) and Michigan Landlord Association.*** 

####### ***Provide analysis of site accumulation data.*** 

####### *Impact Objective:* 

-   Lower rates of CDL prevalence.

####### ***Contributing Factors:*** 

-   Lack of definitive exposure studies.

-   Lack of national standards.

-   Lack of prevalence data and site post-identification tracking.

-   Varied and sometimes competing objectives by stakeholders.

####### ***Process Objectives***

-   To assist in development of a regulatory framework a non-traditional
    environmental health problem from the earliest stages. This would
    allow me to research and analyze a variety of regulatory approaches,
    including economic impact.

####### The main process objective was to initiate a better working relationship between public and environmental health agencies, housing and code enforcement officials, and the housing community (starting with landlord associations). I have been surprised at how little interaction these separate groups have. I was a founding member of the Michigan Housing Officials Association (MAHO) nearly 15 years ago. In the intervening years I have remained the only environmental health agency representative. I believe this project has (and will further help) helped at both the local (Ingham County) level and the state level. 

####### To assist in developing a cost effective standard for CDL clean-up in Michigan. 

####### To gather and analyze accumulated data for identified sites. Data include, date of site identification, site use (rental, owner occupied), reoccupation date. 

# METHODOLOGY:

####### ***Events and Activities:***

-   Work on State task force, analyze a range of other state approaches
    (siting advantageous and disadvantages), and incorporate stakeholder
    viewpoints. Produce clean-up guidelines by February 28, 2006.

-   Bring together housing officials in Ingham County to develop
    partnerships not only on CDL's but all environmental health related
    housing issues, November 2006.

-   Hold clean-up standard presentation state wide to housing official
    and landlord association conferences, June 2007 and August 2007,
    both of which I scheduled as a speaker.

-   Create data for incidence, prevalence, and associated property
    parameters in 3 Michigan counties, summer 2007. Parameters include:

    -   Date of identification

    -   Use of site prior to identification

    -   Responsible agency

    -   Type of occupancy restriction

    -   Type of clean-up activity and responsible party (owner,
        consultant firm)

    -   Date returned to service.

    -   Tax assessment value of property

    -   Cost of clean-up

    -   Median housing cost of neighborhood (census block)

# RESULTS:

1.  The State of Michigan Methamphetamine Site Task Force was initiated
    June of 2006. It has completed work on what I believe to be a cost
    effective clean-up standard, will be submitted to legislative
    committee on March 1^st^, 2007. General text will be available at:
    [http://www.legislature.mi.gov](http://www.legislature.mi.gov/) .

2.  Am on agenda for presentation of Guidelines to MAHO (June 2007) and
    Mid-Michigan Landlord Association (August 2007).

**Next Steps**:

1.  Compilation of Eaton and Clinton county CDL data.

2.  Release of site data for Clinton, Eaton, and Ingham counties July
    2007.

**Expected Outcomes:**

1.  Initial data from Ingham and Clinton counties place average turn
    around at about 9 months.

2.  Most residential sites have not had any formal review of clean-up or
    clearance.

3.  Most are rental properties.

4.  Most new tenants are aware of CDL history, but most gained knowledge
    through neighbors not landlord.

5.  Owner performed clean-ups are difficult to extract. Most landlords
    have also included other "remodeling" activities with clean-up.

# CONCLUSIONS:

This project was successful in assisting the development of State of
Michigan Guidelines for the Clean-Up of Clandestine Drug Laboratories.
These guidelines will be submitted by the task force by February 28^th^,
2007. The task force included many stakeholders. These guidelines, when
adopted, will need to be presented to various stakeholders, including
landlords and housing officials. I have already been asked to present
them at state wide conferences. This has and will lead to better
relationships between environmental health, law enforcement, housing
agencies, and landlords.

This project now has access to a considerable amount of site data. This
data will be analyzed for several parameters including use, re-occupancy
times and rates, and clearance costs. This will assist environmental and
housing professionals to better estimate the extent of CDLs, and the
effect of various regulatory approaches.

# LEADERSHIP DEVELOPMENT OPPORTUNITIES:

#######  ***Michael L. Allen***

This project has allowed me the opportunity to participate at a state
wide level in analyzing options for and developing a regulatory approach
to an environmental issue which presents unique concerns. It has allowed
me to take the lead in developing new partnerships between environmental
health and groups such as housing officials and landlords. I have been
encouraged to run for (and will submit my application April 2007) the
Michigan Association of Housing Officials (MAHO) Board, to bring the
public and environmental health perspective to the association. In both
these aspects I have been able to work from the very foundation of this
problem. This has allowed me to research and become familiar with the
economic and social aspects of residential contamination.

# ABOUT THE EPHLI FELLOW

Michael L. Allen B.S., M.S., R.S. received both BS and MS from Michigan
State University, Medical Technology and Biochemistry. Mr. Allen's
previous employment and studies were at Michigan State University
Pesticide and Plant Pathology Laboratories; biomechanics of pesticide
uptake and distribution. Currently he is the toxicologist and
environmental epidemiologist for Ingham County Health Department,
responsible for toxicological profiles and investigations, oversight of
contamination sites, and all indoor air or residential exposure
programs. He is a member of the Society for Risk Analysis, the Michigan
Society of Toxicology, and the Michigan Society for Infection Control.
He is a founding member of the Michigan Association of Housing
Officials. He is a regular speaker throughout the state on a variety of
topics including toxic exposures and indoor air.

# REFERENCES

1.  Dana Hunt Ph.D. ; Sarah Kuck ; Linda Truitt Ph.D., Methamphetamine
    Use, Lessons Learned, National Institute of Justice/NCJRS

2.  The Drug and Alcohol Services Information System, DASIS Report:
    Primary Methamphetamine / Amphetamine Treatment Admissions:
    1992-2002, September 2004. Available at:
    <http://oas.samhsa.gov/2k4/methTX/methTX.pdf>

3.  The National Drug Control Strategy The White House February 2006
    Available at:
    <http://www.whitehousedrugpolicy.gov/publications/policy/ndcs06/ndcs06.pdf>

4.  In July of 2006 Jennifer Granholm, Governor of Michigan, signed into
    law P.A. 0257 of 2006 creating criminal penalties for the
    publication of methamphetamine production techniques on the
    internet.

5.  Scott MS, Dedel K. ***Clandestine Methamphetamine Labs, 2nd
    Edition*,** Office of Community Oriented Policing Services,
    August 2006. Available at:
    <http://www.cops.usdoj.gov/mime/open.pdf?Item=274>

6.  Jolene Hernon, Methamphetamine: An Update on an Emerging Problem,
    *National Institute of Justice Journal* Dated: October 2000 Pages:8
    to 9

7.  Public Health Consequences Among First Responders to Emergency
    Events Associated With Illicit Methamphetamine
    Laboratories---Selected States, 1996-1999**\
    ***JAMA,* Dec 2000; 284: 2715 - 2716.

8.  Acute Public Health Consequences of Methamphetamine Laboratories -
    16 States, January 2000-June 2004, *MMWR* April 15, 2005 /
    54(14);356-359

9.  Smith J, Canton EM, Weight-based administration of dalteparin in
    obese patients. *Am J Health--Syst Pharm*. 2003; 60-683-7.

10. So on and so forth.