Title: Developing a Strategy for a Multiagency Response to Clandestine Drug
Laboratories.
Series: Monograph
Author: Bureau of Justice Assistance
Published: June 1993, Reprinted July 2000
Subject: Drugs and Crime- General, Law Enforcement- General
109 pages
4,456,448 bytes

----------------------------

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----------------------------

BJA Bureau of Justice Assistance

Developing a Strategy for a Multiagency Response to Clandestine Drug
Laboratories

Monograph

NCJ 142643
June 1993
Reprinted July 2000

----------------------------

U.S. Department of Justice
Office of Justice Programs
810 Seventh Street NW. 
Washington, DC 20531

Janet Reno
Attorney General

Daniel Marcus
Acting Associate Attorney General

Mary Lou Leary
Acting Assistant Attorney General

Nancy E. Gist
Director, Bureau of Justice Assistance

U.S. Department of Justice Response Center
1-800-421-6770

Bureau of Justice Assistance Clearinghouse
1-800-688-4252

Bureau of Justice Assistance
World Wide Web Home Page
http://www.ojp.usdoj.gov/BJA

This document was prepared by Circle Solutions, Inc., under Cooperative
Agreement No. 91-DD-CX-0052 and Grant No. 95-DD-BX0075, awarded
by the Bureau of Justice Assistance, Office of Justice Programs, U.S.
Department of Justice. The opinions, findings, and conclusions or
recommendations expressed in this document are those of the authors and do
not necessarily represent the official position or policies of the U.S. Department
of Justice.

The Bureau of Justice Assistance is a component of the Office of Justice
Programs, which also includes the Bureau of Justice Statistics, the National
Institute of Justice, the Office of Juvenile Justice and Delinquency Prevention,
and the Office for Victims of Crime.

----------------------------

Acknowledgments

This monograph is the result of the collective efforts of a number of individuals
who generously lent their time and expertise and candidly shared their insight
and experience to make it possible. This is especially true of the individuals
involved in the clandestine laboratory law enforcement and cleanup guidelines
programs at the five Bureau of Justice Assistance (BJA) demonstration sites.

We would also like to thank Anna T. Laszlo and Michael S. McCampbell,
Circle Solutions, Inc., the principal authors; Marilyn S. Ayres, Circle Solutions,
Inc., for her contributions to chapter 2, Clandestine Laboratory Enforcement:
The Framework for Program Development; and Richard M. Ayres, Center for
Labor Management Studies, Fredericksburg, Virginia, for his contribution on
strategic planning.

Finally, we would like to thank the BJA Law Enforcement Branch Chief of the
Discretionary Grants Division, Luke Galant, for his consistent support in
bringing this document to print. 

----------------------------

Contents

Executive Summary

Foreword

Chapter 1 Introduction and Purpose
Hazards to Law Enforcement Officers and the Community
Clandestine Laboratory Enforcement Issues
Lessons Learned From the Demonstration Sites
The Purpose of the Monograph

Chapter 2 Clandestine Laboratory Enforcement: The Framework for Program
Development 
Corrosives, Combustibles, and Carcinogens: A Look at Basic Toxicology
Occupational Safety, Health, and Environmental Regulations: A Policymaker's
Primer

Chapter 3 Clandestine Laboratory Enforcement Program Components
Component 1: The Multidisciplinary Strategic Planning Team
Component 2: Interagency Agreements 
Component 3: Personnel and Training
Component 4: Equipment
Component 5: Personnel Medical Screening and Surveillance, and Data
Collection 
Component 6: Precursor Chemical Monitoring
Component 7: Clandestine Laboratory Cleanup
Component 8: Community Education and Awareness

Chapter 4 The Clandestine Laboratory Enforcement Program: Planning a
Strategy
Strategic Planning Defined
Need for Strategic Planning
Gaining Commitment for Strategic Planning
Environmental Analysis
The Strategic Planning Approach

Chapter 5 Establishing the Clandestine Laboratory Enforcement Program:
Practical Steps to Implementation 
Practical Steps to Implementation
o Worksheets 
o 5.1 Develop the Mission Statement
o 5.2 Environmental Analysis 
o 5.3 Organizational Assessment-Critical Issues 
o 5.4 Organizational Assessment-Strengths and Weaknesses
o 5.5 Program Results
o 5.6 Principal Participants' Expectations
o 5.7 Action Plans
o 5.8 Identifying Funding Resources and Options
o 5.9 Component Policies and Procedures
o 5.10 Communication Strategy
o 5.11 Training Plan

Glossary

Appendix A Tables of Chemical Toxicity and Routes of Exposure

Appendix A1 Types of Inhaled Toxicants and Their Effects
Appendix A2 Factors Influencing Toxicity

Appendix B Sample Roles and Responsibilities of CLEP Law Enforcement
Personnel 

Appendix C Sample Product Specifications, Personal Protective Equipment
(PPE) 

Appendix D Sample Respiratory Protection Program

Appendix E Sample Hazardous Assessment and Recognition Plan (HARP)
Instrument 

Appendix F Sample Clandestine Laboratory Exposure Report (CLER)
Instrument

Appendix G Highlights of the Model State Chemical Control Act 

Appendix H Sample Destruct Order 

Appendix I Sample Notification of Hazardous/Toxic Chemical Contamination
Letters

Appendix J Sample Hazardous Materials Incident Response Team (HIRT)
Program, Executive Summary

References 

Sources for Further Information 

o Expert Sources

o Federal Agencies

o Publications

o Training Programs

o BJA Contact

----------------------------

Executive Summary

Methamphetamine abuse, trafficking, and production is a fast-growing national
problem that has been likened to the crack cocaine epidemic of the early
1990s. In the past few years, methamphetamine abuse and production has
spread from the West to the Southwest and Midwestern regions of the country,
and is moving eastward into such states as Arkansas, Georgia, and even
Florida.

Methamphetamine is relatively simple to manufacture from commonly available
ingredients, including ephedrine, pseudoephedrine, red phosphorus,
hydrochloric acid, hydriodic acid, iodine, ether, alcohol, white gasoline, lye, and
anhydrous ammonia. These chemicals and the waste products produced during
the manufacturing process are dangerous to human health and the environment.

Clandestine laboratories used to manufacture methamphetamine often house
substantial quantities of highly toxic, corrosive, and explosive chemicals. They
may be operated on an intermittent and transient basis in such locations as
hotel/motel rooms, barns, trailers, apartments, and rural sites. 

Laboratory operators display little regard for the environment, and as a result,
clandestine laboratory sites have been the scene of explosions, fires, toxic
fumes, environmental damage, and numerous injuries and deaths. For every
pound of finished product, five to six pounds of hazardous chemical waste is
produced. 

Seizing or "taking down" a lab requires a strategically precise enforcement
action, often involving Federal, State, and local law enforcement. Once seized,
the lab remains a potential hazardous waste site, often with large quantities of
potentially toxic chemicals, as well as an array of unknown corrosives,
carcinogens, and combustibles. Clandestine laboratory enforcement efforts,
unlike other narcotics cases, are complicated by the presence of these
hazardous materials. It is this complication that demands expansion of the
traditional narcotics task force investigation and prosecution to encompass
health, occupational safety, and environmental agencies' approaches.

In addition to the planning and organizational problems faced by traditional
narcotics task forces, clandestine laboratory enforcement programs (CLEPs)
must also address the following health, safety, and environmental issues:

o Selecting appropriate safety equipment, including respirators, and ensuring
their use by officers involved in clandestine laboratory enforcement.

o Establishing and maintaining a medical screening and surveillance program for
these officers.

o Determining how cleanup costs will be shared among the agencies involved. 

In 1987, the Bureau of Justice Assistance (BJA) funded demonstrations by five
agencies--the Washington State Patrol, the California Bureau of Narcotic
Enforcement, the Portland (Oregon) Bureau of Police, the New Jersey State
Police, and the Commonwealth of Pennsylvania's Office of the Attorney
General--to develop and implement CLEPs. The experience of these
demonstration sites in implementing their CLEPs indicates that a multi-
disciplinary approach to clandestine laboratory enforcement includes the
following components:

o A strategic planning team.

o Interagency agreements.

o Personnel and training.

o Specialized safety equipment.

o Medical screening and surveillance.

o Precursor chemical monitoring.

o Clandestine laboratory cleanup.

o Community education and awareness.

This monograph presents sample language from policies and procedures
developed by the demonstration sites to assist policymakers in formulating their
own program components.

This monograph is designed to help State and local law enforcement officials
plan, organize, and manage a comprehensive CLEP that includes these
components. The purpose of this monograph is to complement existing training
and operational manuals by addressing the strategic planning process that
allows the operational tasks to take place. The strategic planning approach to
developing and implementing an effective CLEP consists of five stages:

Stage 1: Mission formulation.

Stage 2: Organizational assessment.

Stage 3: Developing objectives.

Stage 4: Developing action plans.

Stage 5: Implementation.

Worksheets are included to assist policymakers with the process of strategic
planning. Upon completion of the worksheets, program planners will have a
strategy for developing and implementing a comprehensive CLEP, including:

o An analysis of existing laws, policies, and procedures that may impact
program developments.

o A training plan and communication strategy. A plan for identifying program
resources.

o An approach for garnering and maintaining program support both within the
department and with other agencies.

This monograph was developed to address the concerns of State and local
officials seeking to implement CLEPs. However, the principles and processes
of strategic planning, which form the foundation of a successful CLEP, are
equally applicable to any enforcement operation that requires the cooperation
and commitment of a number of agencies having differing priorities and
mandates.

----------------------------

Foreword

In 1987, the BJA Discretionary Grant Program funded a program to implement
a comprehensive cooperative effort to assist State and local law enforcement
agencies to develop strategies to discover, investigate, and close clandestine
laboratories. Five competitively selected sites and a technical assistance grant
were funded to develop a model strategy for eventual replication nationwide.

The demonstration sites consisted of the following agencies: the California
Bureau of Narcotic Enforcement; the Portland, Oregon Bureau of Police; the
Washington State Patrol; the New Jersey State Police; and the Pennsylvania
Office of the Attorney General. The technical assistance grantee was Circle
Solutions, Inc. In each of the demonstration sites, project staff interviewed key
agency staff; observed enforcement and prosecution activities; reviewed
policies, procedures, and training materials; and collected a wide range of other
data.

This monograph, which was first published in 1991 and revised in 1993 and
1998 reflects the best practices learned from the five demonstration sites. It has
been updated to include changes in policies and practices that have occurred
over the past several years. The monograph also includes numerous appendixes
that will provide models of forms and procedures for State and local agencies
to use in developing comprehensive clandestine laboratory enforcement
programs. The list of reference material, which is found at the back of the
monograph, has been expanded to include information on methamphetamine
trafficking, use, and production. Also, the table of subject matter experts has
been updated to include personnel from additional agencies that have recently
joined the fight against the Nation's growing clandestine drug laboratory
problem. 

----------------------------

Chapter 1

----------------------------

Introduction and Purpose

Methamphetamine abuse, trafficking, and production is a fast-growing national
problem that President Clinton has likened to the crack cocaine epidemic of the
early 1990s.[1] Methamphetamine, a highly addictive and violence-causing
synthetic stimulant, is also known by its street names as "crystal," "crank," "ice,"
and "speed." The drug may be injected, smoked, snorted, or taken orally.

Until the late 1980s, methamphetamine trafficking was primarily associated with
outlaw motorcycle gangs in California who supplied users in various parts of the
United States.[2] However, in the past few years, available data shows that
methamphetamine abuse and production has risen significantly in the West and
Southwest regions of the country. The Drug Use Forecasting (DUF) statistics
released by NIJ in June 1997 show that methamphetamine use is highest in
western locations.[3] (Curiously, DUF data contained in this same report
shows a marked decrease in the presence of methamphetamine among
arrestees in eight cities that, in 1995, reported the highest amounts of the drugs.
These cities are Dallas, Denver, Los Angeles, Omaha, Phoenix, Portland, San
Diego, and San Jose.[4]) According to the Drug Abuse Warning Network
(DAWN), between 1989 and 1995, the estimated number of nationwide
emergency room drug abuse episodes doubled, and between 1991 and 1995
the number of methamphetamine-related deaths almost tripled.[5]

Other examples of the seriousness of the methamphetamine problem include:

o During a recent investigation by DEA, the Immigration and Naturalization
Service, and the Idaho Bureau of Narcotics, approximately 40 pounds of
methamphetamine were seized and 17 traffickers arrested.

o In Iowa's Polk County, which includes Des Moines, the number of drug
arrests, with methamphetamine accounting for 65 percent of the total, now
surpass drunk driving arrests.

o Law enforcement officials in Phoenix report that methamphetamine is largely
responsible for the 40-percent increase in the city's homicide rate in 1994. 

o A drug treatment official in Atlanta reports that methamphetamine tends to be
used by white, middle-class teenagers and young adults who have no links to
the crack scene.[6]

The methamphetamine problem is spreading from the West into the Midwest
and is moving eastward into such states as Arkansas, Georgia, and Florida. The
Midwest region of the country (Missouri, Iowa, Kansas, South Dakota, and
Nebraska) saw a 300-percent increase in clandestine laboratory (labs that
manufacture methamphetamine) seizures between 1992 and 1996, and the
DEA seized 236 laboratories in Missouri alone.[7] Nationally, the DEA seized
879 methamphetamine production laboratories in 1996, nearly a 170-percent
increase over 1995.[8] DEA statistics do not present a true picture of the
problem because this data only accounts for clandestine laboratory seizures in
which DEA participated. For example, the California Bureau of Narcotic
Enforcement seized 835 clandestine laboratories in 1996.[9] The true extent of
the problem is unknown because there is no centralized data collection agency
for reporting clandestine laboratories. 

The increase in clandestine laboratories and trafficking is primarily due to the
emergence of organized Mexican drug trafficking organizations and their
involvement in methamphetamine production and distribution. Sophisticated
Mexican polydrug organizations with links to Columbian traffickers have
replaced outlaw motorcycle gangs as the primary methamphetamine producers,
traffickers, and distributors in California. These traffickers establish large-scale
clandestine laboratories capable of producing 20 to 100 pounds of product.
[10 ] The scope of Mexican involvement with methamphetamine production is
supported by numerous data. According to the El Paso Intelligence Center
(EPIC), the amount of methamphetamine seized along the Southwest border
increased from 6.5 kilograms in 1992 to 653 kilograms in 1995--a hundredfold
increase, while the California Bureau of Narcotic Enforcement reported that
methamphetamine seizures increased from 636 kilograms in 1991 to 8,182
kilograms in 1995.[11] 

Although Mexican criminal organizations control a significant amount of the
production and distribution of methamphetamine, other organizations also
contribute to the problem. These include Asian gangs in Northern California,
Washington State, and British Columbia, in addition to continuing involvement
by outlaw motorcycle gangs.[12] A recent trend in Midwestern and other
States is the increase in small "mom and pop" stove-top clandestine
laboratories. These are operated by individuals or small groups who do not
appear to be affiliated with criminal organizations. They manufacture
methamphetamine for their own use and sell excess products to their friends
and family. These "mom and pop" laboratories are responsible for the huge
increase in methamphetamine production in Missouri, Oklahoma, and other
States.[13] 

Clandestine laboratories often house substantial quantities of highly toxic,
corrosive, and explosive chemicals, posing serious human health and
environmental risks. They may be operated on an intermittent and transient
basis. After operators "cook" a batch of methamphetamine, the laboratory is
often moved or stored and then is set up in another location.

----------------------------

Hazards to Law Enforcement Officers and the Community

Methamphetamine is relatively simple to make from commonly available
ingredients. Chemicals frequently used in methamphetamine manufacture
include ephedrine or pseudoephedrine (commonly used in asthma or cold
medicines), red phosphorus, hydrochloric acid, hydriodic acid, iodine, ether,
alcohol, white gasoline, lye, and anhydrous ammonia. These chemicals and the
waste products produced during the manufacturing process are dangerous to
human health and the environment.

Laboratory operators typically have little formal chemistry training or
education--relying instead on apprenticeship with other "cooks" and working
from handwritten recipes. They are often well armed, and their laboratories are
occasionally booby-trapped. Weapons ranging from handguns to high-powered
automatic firearms and explosives are commonly found at laboratory sites. 

Laboratory operators display little regard for the environment. As a result,
clandestine laboratory sites have been the scene of explosions, fires, toxic
fumes, environmental damage, and numerous injuries and deaths. For every
pound of finished product, 5 to 6 pounds of hazardous chemical waste is
produced.[14] This hazardous chemical waste is typically dumped into nearby
streams or onto the ground, or poured into local sewage systems. The amount
of waste material from a clandestine laboratory may vary from a few pounds to
several tons depending on the size of the laboratory and its manufacturing
capabilities. 

Once the laboratory is seized, hazardous waste and contaminated materials,
such as chemicals (solvents, reagents, precursor, by-products, and the drugs
themselves), glassware, and equipment must be disposed of in accordance with
numerous Federal, State, and local laws and regulations. As a result, special
training in health, safety, and environmental protection measures are necessary
for anyone who plans to raid or otherwise work at the site of a clandestine
laboratory.[15] In addition, cleanup costs often exceed $5,000 per laboratory
site and can reach over $100,000 for larger sites. In 1995 alone, the California
Bureau of Narcotic Enforcement spent $2.4 million and the DEA spent
approximately $8 million on cleanup.[16] 

A serious problem related to the environmental hazard issue is that of children
whose parents are operators of clandestine laboratories. The California Bureau
of Narcotic Enforcement is encountering a growing number of children under
the age of 13 in "mom and pop" clandestine laboratories. Approximately 40
percent of these children are found to have elevated toxic chemical levels in
their blood.[17] 

Most State and local law enforcement officers and agencies lack adequate
training in clandestine laboratory enforcement, safety procedures and
regulations, hazards, and other related health and safety issues. This represents
a serious threat to first responders, investigators, and the community in general.

The chemical reactions that occur during the manufacturing process may
produce toxic vapors that are absorbed by wall and floor surfaces of buildings
housing clandestine laboratories. In addition, laboratory operators may vent
these vapors into the outside environment. Problems also occur when the
chemicals are stored at public locations such as self-storage facilities. The lack
of proper ventilation and temperature controls of these sites add to the potential
of fires, explosions, chemical leaks, and human exposure. Even more frightening
is the fact that laboratory operators often set up shop in locations such as hotel
rooms, exposing numerous innocent people to the possible toxic effects of
chemical reactions. 

Methamphetamine laboratories may contaminate water sources and/or soil.
Surface and ground water drinking supplies can be contaminated by dumping
waste products and chemicals into bathtubs, sinks, toilets, or creeks. Perhaps
the greatest risk of long-term exposure is assumed by unsuspecting inhabitants
who may use or live in buildings formerly used as clandestine laboratory sites.
Residual contamination may exist for years at these locations.

----------------------------

Clandestine Laboratory Enforcement Issues

Investigations of clandestine laboratories usually require traditional narcotics
investigative techniques (such as surveillance and the use of informants or
wiretaps). Seizing or "taking down" a laboratory, however, requires a
strategically precise enforcement action, often involving Federal, State, and
local law enforcement. Once seized, the laboratory remains a potential
hazardous waste site, often with large quantities of potentially toxic chemicals,
as well as an array of unknown corrosives, carcinogens, and combustibles. The
presence of these hazardous materials complicates clandestine laboratory
enforcement efforts, making them unlike other narcotics cases. This
complication mandates expanding the traditional narcotics task force
investigation and prosecution to encompass the approaches of health,
occupational safety, and environmental agencies. 

Therefore, the term "clandestine laboratory enforcement program" or "CLEP"
refers to a comprehensive program that encompasses all phases of planning,
investigation, seizure, dismantling, waste removal, and remediation of
contaminated property.

Thus, the issues surrounding health, occupational safety, and the environment
become inherent in the investigation and prosecution of clandestine laboratory
operators. The expertise required for the various aspects of laboratory seizures
and prosecutions makes the coordination of resources and programs among a
multidisciplinary team of Federal, State, and local agencies of utmost
importance.

Like any number of specialized narcotics task force operations, CLEPs face a
myriad of planning and organizational issues. Among these are the following:

o Developing and maintaining cooperation among the law enforcement,
environmental, health, and safety agencies that have a role in clandestine
laboratory enforcement.

o Recruiting and selecting appropriate personnel.

o Developing and implementing necessary personnel training.

o Funding in times of competing priorities.

o Addressing the legal obligations and liabilities of the agencies involved. 

o Coordinating investigations with traditional narcotics task forces. 

Unlike traditional narcotics task force operations, CLEPs must also address the
following health, safety, and environmental issues:

o Selecting appropriate safety equipment, including respirators, and making
sure officers involved in clandestine laboratory enforcement use it.

o Establishing and maintaining a medical screening and surveillance program for
these officers.

o Determining how cleanup costs will be shared among the agencies involved.

----------------------------

Lessons Learned From the Demonstration Sites

In 1987, the Bureau of Justice Assistance (BJA) funded five demonstrations to
develop and implement CLEPs at five agencies: the Washington State Patrol;
the California Bureau of Narcotic Enforcement; the Portland (Oregon) Bureau
of Police; the New Jersey State Police; and the Commonwealth of
Pennsylvania's Office of the Attorney General. Each of these sites developed its
program with an understanding that clandestine laboratory enforcement
necessitated a multidisciplinary approach, requiring expertise among narcotics
enforcement and prosecution officials as well as among fire and hazardous
materials (HAZMAT) teams and health and environmental officials. 

To establish and implement these CLEPs, Federal, State, and local law
enforcement officials in each site needed to identify common goals, delineate
their respective roles and responsibilities, devise interagency agreements among
themselves and other agencies, formulate enforcement strategies that would
ensure the personal health and safety of officers involved, and recognize their
responsibilities in safely and effectively disposing of the hazardous waste
remaining after the laboratory was seized.

Thus, a multidisciplinary approach to clandestine laboratory enforcement
includes the following components:

o A strategic planning team.

o Interagency agreements.

o Personnel and training.

o Specialized safety equipment.

o Medical screening and surveillance.

o Precursor chemical monitoring.

o Clandestine laboratory cleanup. 

o Community education and awareness.

Since their programs' inception, these officials have learned a great deal about
the changing nature and scope of clandestine drug laboratory operations and
how to develop and implement effective multidisciplinary responses. The
collective experience of these sites provides the foundation on which other
jurisdictions can design successful clandestine laboratory enforcement efforts. 

----------------------------

The Purpose of the Monograph 

This monograph is designed to help State and local law enforcement officials
plan, organize, and manage a comprehensive CLEP. Much has already been
written about how to conduct clandestine laboratory investigations, seizures,
and prosecutions. This monograph is intended to complement existing training
and operational manuals by addressing the strategic planning process that
allows the operational tasks to take place.

The monograph is based on a number of fundamental principles:

o A CLEP requires the commitment of a number of agencies (Federal, State,
and local law enforcement; health and environment; and fire/HAZMAT teams)
that have different, and sometimes conflicting mandates. Thus, the issues and
concerns a CLEP raises invariably require extensive discussion and negotiation.

o Developing a CLEP requires implementing strategic planning principles. 

o Managing the CLEP involves effective communication, inside and outside the
law enforcement agency. 

This monograph includes worksheets to help policymakers plan and implement
the CLEP process. Upon their completion, program planners will have a
strategy including:

o An analysis of existing laws, policies, and procedures that may have an
essential impact on program development.

o A training plan and communication strategy.

o A plan for identifying program resources. 

o An approach for gathering and maintaining program support both within the
department and with other agencies.

The principles and processes of strategic planning, which form the foundation of
a successful CLEP, are equally applicable to any enforcement operation that
requires the cooperation and commitment of a number of agencies that have
differing priorities and mandates. 

Notes

1. Ft. Lauderdale Sun-Sentinel, April 30, 1996.

2. U.S. Drug Enforcement Administration, Methamphetamine Precursor
Chemical Control in the 1990s, April 1997.

3. National Institute of Justice, Drug Use Forecasting 1996, Annual Report on
Adult and Juvenile Arrestees, June 1997.

4. National Institute of Justice.

5. U.S. Department of Justice, National Methamphetamine Strategy Update,
May 1997.

6. Office of National Drug Control Policy, Methamphetamine Facts and
Figures, January 1997.

7. Office of National Drug Control Policy.

8. U.S. Drug Enforcement Administration.

9. Thomas J. Gorman, California Bureau of Narcotic Enforcement, "Children in
Clandestine Laboratories: the California Experience," paper presented May 29,
1997, at the National Methamphetamine Drug Conference, Omaha, Nebraska.

10. U.S. Drug Enforcement Administration.

11. U.S. Department of Justice.

12. U.S. Drug Enforcement Administration.

13. Personal communication with the Kansas City (Missouri) Police
Department's Drug Unit Commander (May 1997) and the Chief Agent,
Oklahoma Bureau of Narcotics (May 1997).

14. Substance Abuse and Mental Health Services Administration, Proceedings
of the National Consensus Meeting on the Use, Abuse and Sequelae of Abuse
of Methamphetamine with Implications for Prevention, Treatment and
Research, 1997.

15. Bureau of Justice Assistance, Developing a Strategy for a Multiagency
Response to Clandestine Drug Laboratories, June 1993.

16. Substance Abuse and Mental Health Services Administration.

17. Gorman.

----------------------------

Chapter 2

----------------------------

Clandestine Laboratory Enforcement: The Framework for Program
Development

Unlike other narcotics enforcement actions, clandestine laboratory enforcement
actions are complicated by the presence of hazardous chemicals that may have
an immediate impact on an officer's safety and cause acute and chronic health
problems.[1] Consequently, policymakers need a basic understanding of the
chemicals that officers will encounter in clandestine laboratories, their known
and probable effects, and the measures that can be taken to prevent exposure.
Policymakers also need to have a working knowledge of the legal and liability
issues they may face both with respect to their employees and the community in
which the laboratory is located. These health and legal/liability issues form the
rationale for the CLEP components detailed in chapter 3.

The present chapter addresses two critical areas for policymakers. The first,
basic toxicology, includes a discussion of chemicals that are known to be
harmful to humans, their negative health effects, and their methods of invading
the body. A myriad of unknown chemicals may also be present in clandestine
laboratories, with even more harmful effects than the known substances.[2] The
second area addressed concerns basic Federal and State regulations that
govern the CLEP operation: directives from the Occupational Safety and
Health Administration (OSHA), the Environmental Protection Agency (EPA),
and the Drug Enforcement Administration (DEA). 

The chapter is not meant to be a comprehensive discussion of medical and legal
principles; rather, it is an introduction to issues that will help policymakers
formulate their CLEPs. Program planners should regularly consult with State
and local health officials, toxicologists, and legal counsel for detailed
descriptions of these health, safety, and legal issues. 

----------------------------

Corrosives, Combustibles, and Carcinogens: A Look at Basic Toxicology    

Little is known at present about the potential long-term health or reproductive
risks resulting from exposure to the known, as well as unknown, narcotics and
precursor chemicals present in clandestine laboratories. Certain chemical
reagents, illicit drugs, and drug precursors have been implicated in lasting
disabilities among law enforcement officers.[3] Inasmuch as there have been no
epidemiological studies of enforcement officers or clandestine laboratory
operators exposed to clandestine laboratory toxins, scientists can only make
educated guesses about potential acute and chronic health effects.

However, recognizing this potential and understanding the factors that
determine whether a particular chemical will have short- or long-term effects
can be very beneficial in formulating policies addressing protective equipment,
medical screening and surveillance, and safety procedures.

Recognizing the Complexity and Diversity of Hazards

Recognizing the vast complexity and diversity of hazards associated with
clandestine laboratory enforcement is a first, critical step for the policymaker
who is responsible for setting protective guidelines for employees and for
ensuring the fitness of the site for reoccupancy. (Appendix A contains a list of
chemical compounds that may be found in clandestine laboratories, including
each compound's physical state, exposure symptoms, and health effects.) It is
important to remember that, added to the already complex nature of clandestine
laboratory enforcement, some combinations of chemicals produce different
effects than those each produces separately; that is, some combinations
increase the toxic effect of the separate chemicals, while others decrease the
toxicity, as will be discussed below.[4] 

Inasmuch as efforts to control one hazard may create or impede control of
other hazards, it is critical for policymakers to be able to identify the levels as
well as types of protection needed for specific, varying situations. For example,
some chemicals used in methamphetamine production present a danger of injury
from fire or explosion.[5] Risk of injury or toxicity from chemical exposure
depends on the toxic properties of the particular chemicals, as well as their
quantity, form, concentration, and duration and route of exposure.

Toxic Materials: How They Invade and Threaten the Body

A toxic material is capable of producing local or systemic detrimental effects in
the human body. The effects associated with toxic material may be temporary
or permanent, immediate or delayed, mild or severe.[6] Toxic materials injure
the lungs or the skin or do damage to the liver and the kidneys or the nervous
system. Some may induce cancers. Other toxins such as teratogens cause
malformation of the embryo or result in genetic damage, cancer, or
reproductive failure.

Toxic materials encountered in clandestine laboratories enter the body through
the following methods, in order of importance: inhalation, absorption, and
ingestion. Some materials may enter the body by more than one of these routes
of exposure.[7]

Inhalation. Inhalation is the most common exposure route for toxic materials in
clandestine drug laboratories. Once absorbed by the respiratory tract, toxins
may reach other organs via the bloodstream or the lymphatic system.

The respiratory tract is the only organ system with vital functioning elements that
is in constant, direct contact with the environment. The lungs have the largest
exposed surface area of any organ other than the skin; many toxic materials can
produce acute or chronic diseases of the respiratory tract when they are
inhaled.[8] (For types of inhaled toxicants and their effects, see appendix A1.)

Inhalation may result in injury from corrosive substances, with symptoms
ranging from shortness of breath to cough to chest pain. Many solvents are
absorbed into the body through the lungs and, in sufficient dose, may cause
symptoms of intoxication, dizziness, lack of coordination, nausea, and
disorientation.[9] 

Many chemicals will also produce hypoxia (oxygen deficiency) as a result of the
body's defense mechanisms. When an irritant enters the body it causes swelling
and leakiness of the tissues, which results in the accumulation of fluid and
prevents oxygen absorption.[10]

Absorption. Of the three major avenues of contamination, absorption through
the skin is another important route. Toxic materials, including dangerous,
invisible vapors, may be absorbed through the skin, sweat glands, sebaceous
(oil) glands, and hair follicles, causing both local and systemic effects.
Absorption through skin exposure to corrosive substances may result in skin
burns, as well as the symptoms that occur with inhalation of these substances;
e.g., shortness of breath, cough, and chest pain.

Absorption rate depends on a number of factors, including, but not limited to,
the condition of the skin and properties of the chemical involved. Some factors
that enhance absorption rate are nonintact skin, increased skin hydration,
increased skin temperature (which causes sweat glands to open, secrete sweat,
and dissolve solids, as well as to increase blood flow to the skin), increased
concentrations of the chemical substance, altering of the skin's normal pH of
5,[11] and adding of surface-active agents or organic chemicals.[12]

Many toxic materials produce systemic effects. To produce a systemic effect,
the toxic material must be absorbed and distributed inside the body to an organ
distant from the entry point. The organ targeted most often by systemic toxicity
is the central nervous system, followed by the liver and kidneys. Additional
organs affected may be the heart, spleen, and the reproductive system.[13]

Ingestion. Toxic materials on hands, cigarettes, and in food or drink may be
ingested by mouth. Materials ingested pass through the stomach and may be
absorbed into the bloodstream, after which they may move directly to the liver
or other organs or tissues.[14] Damage to the mouth, esophagus, stomach, and
intestines can result from ingesting strong acids or bases or other corrosives
such as mercuric chloride.

Acute vs. Chronic Exposure

Exposure to a toxic material may be acute or chronic. The term "acute
exposure" refers to exposure that occurs in a short time. In the context of
clandestine laboratories, acute exposures often happen with high concentrations
of toxic materials. Thus, the idea of severity is frequently incorporated into the
term. The body can display an immediate or delayed reaction to the toxic
exposure.[15] 

In the context of clandestine laboratories, "chronic exposure" usually refers to
exposure to a low concentration of toxic material that occurs over time. A
latency period usually occurs prior to the body's response to the toxic
exposure. Chronic exposure effects on the body may be reversible or
irreversible.[16] 

Effects of Toxic Exposure 

The effects on the body of toxic exposure depend primarily on the chemical's
type, concentration or dosage, and the duration of exposure. Toxic effects vary
from one chemical to another. Many toxic chemicals are nonselective in their
actions on the body; others act on specific areas of the body. (Refer to
appendix A for examples.) Local exposure affects the nose, eyes, mouth,
throat, skin, and the respiratory and gastrointestinal tracts; absorption does not
have to occur. With systemic exposure, absorption does occur, and the site of
damage may be remote from the contact site. In many cases, both local and
systemic damage occurs.[17] 

Concentration, or dosage, is the most important factor in determining whether a
particular chemical will produce toxic effects. Essentially, the dose makes the
poison. A low chemical concentration may have no effect on the body; high
concentrations may adversely affect the body, depending on the chemical's
properties.[18]

Measurement of Toxicity

A toxic material that is normally thought of as harmless may induce a toxic
response if added to the human body in sufficient amount. Toxic potency,
therefore, is defined by the amount of the toxic material and the response that is
produced in the human body.[19] Comparison of an organism's response to a
given material at specific varying doses (amounts of exposure) is known as
"dose-response." For factors influencing toxicity, see appendix A2. 

Exposure Risk Issues

Potentially, five groups of individuals may be vulnerable to toxic chemicals in
clandestine laboratories: (1) laboratory operators involved in the "cooking"
process; (2) first responders, such as law enforcement officers and
fire/HAZMAT teams; (3) cleanup contractors; (4) neighbors of active
laboratories; and (5) residents of buildings formerly used as laboratories. Risks
of exposure vary according to a number of factors, including whether a
laboratory is an active or inactive (former) site.[20]

Risks of Active and Inactive, or Former, Laboratories. An active laboratory
should be considered unsafe for entry except by trained personnel using
appropriate personal protective equipment (PPE). The greatest risks are fire
and explosion due to the relatively large amounts of solvents normally found at
the sites. A chemical spill can result in air concentrations strong enough to
produce adverse effects from inhalation of solvents, corrosives, or cyanide. The
levels of airborne chemicals and the corresponding risk for exposure vary
depending on the cooking method, quantity and form of the chemicals present,
room size, and ventilation.[21]

Another potential risk of toxic exposure in an active laboratory may occur as a
result of "booby traps." A trip wire can be set to drop a chemical into another
chemical, resulting in the release of a highly toxic gas.[22]

In an inactive, or former, laboratory where equipment and chemicals have been
removed, residual amounts of some substances may persist on building surfaces
and furnishings prior to cleanup. Most substances present in the active
laboratory, such as gases or volatile solvents, should dissipate rapidly with
ventilation. (Ventilation of some types of chemicals from labs in populated
areas, such as those making the synthetic opiate fentanyl, should occur only
under controlled circumstances.) Airborne contaminants and chemical spills
may pose a health risk to first responders especially, because they may be
repeatedly exposed to unknown toxic substances.[23]

Cleanup and Reoccupancy Risks. In addition to first responders and other
agency officials performing initial site assessments, disposal contractors and
persons reoccupying the premises before cleanup occurs are at risk for adverse
health effects from toxic materials. These persons may be exposed to high
concentrations of toxic chemicals for short periods of time and should be aware
of the symptoms of acute exposure from solvents, cyanides, corrosives,
irritants, and metals and their salts. When such symptoms occur, the exposed
person should leave the premises or remove the source itself. Reentry should
not occur unless proper ventilation has reduced the airborne toxins or unless a
self-contained breathing apparatus is used.[24]

A basic understanding of the health effects of toxic chemicals commonly found
in clandestine laboratories aids in comprehending the various Federal and State
occupational safety, health, and environmental regulations that govern the
response to clandestine laboratories.

----------------------------

Occupational Safety, Health, and Environmental Regulations: A Policymaker's
Primer 

Numerous Federal, State, and local laws govern the activities of law
enforcement and other agencies dealing with clandestine laboratories. Although
active laboratories pose a greater risk than former sites from chemicals,
explosion, and fire, both environments should be considered dangerous. This
section discusses certain Federal laws with which law enforcement and other
agencies must comply when they become involved with a clandestine
laboratory. Local agencies should become familiar with applicable State and
local laws, as they may be more stringent than Federal regulations outlined in
this chapter.

Employee Health and Safety Regulations

Agencies involved with clandestine laboratory operations fall under OSHA
regulations (29 Code of Federal Regulations (CFR) Part 1910) that require the
following actions by employers, including State and local government agencies:

o Communicating clear, unambiguous warnings to employees, as well as
providing educational programs on the hazards of chemical substances. These
warnings and educational programs apply not only to investigators and others
who come in contact with chemicals in the field, but also to personnel who
analyze the seized chemicals.

o Training all employees who may be exposed to hazardous substances in how
to recognize and handle safety and health hazards at laboratory sites, in the use
of protective equipment, and in safe work practices. Requirements include an
initial 40 hours of safety training, followed by 3 days of field experience and 8
hours of annual refresher training. All specialized training must meet OSHA
standards.

o Providing specialized protective equipment to employees who will be
exposed to hazardous chemicals. The equipment must meet National Institute
for Occupational Safety and Health (NIOSH) standards. Examples of
specialized equipment include chemical-resistant suits, self-contained breathing
apparatus, boots, gloves, and goggles.

o Examining and monitoring the health of employees exposed to hazardous
substances; this should include a thorough medical screening prior to training or
working in clandestine laboratories. In addition, a continuous medical
surveillance program is required to identify any signs of possible exposure to
hazardous substances. All cases of employee exposure must be documented
carefully for future medical reference.

o Providing information to employees regarding any hazardous conditions in
their work environments. It is important to note that any time employees may be
exposed to hazardous substances, they have the right to know their specific
risks. Law enforcement agencies, for example, should provide training on the
known dangers in clandestine laboratories and should also make officers aware
of the fact that a broad range of unknown dangers also exist at these sites. In
addition, since the evidence room may contain hazardous substances, specific
information regarding the exact substances known to be present should be
posted in that room. 

Specific information should be provided to female employees involved in
CLEPs regarding such issues as their increased vulnerability to toxic chemicals
due to gender-specific ratios of body fat and the increased risks to their
reproductive systems associated with exposure to hazardous materials. After
being informed of their risks through proper procedures, female employees
should be allowed to make their own decisions regarding assignment to CLEPs. 

Where agencies fail to adhere to these requirements, supervisors can be held
strictly and personally liable for situations involving employee exposure to
hazardous substances and the resulting adverse health effects.

Hazardous Waste Regulations

Law enforcement agencies that seize clandestine laboratories may find they
have become generators of hazardous waste as defined by Federal laws and
regulations. EPA regulations that implement the Resource Conservation and
Recovery Act (RCRA) define a generator of hazardous waste as "any person,
by site, whose act or process produces hazardous waste...or whose act first
causes a hazardous waste to become subject to regulation" (40 CFR 260.10).
The following Acts and their regulations apply to agencies discovering
hazardous waste materials in excess of certain minimum quantities: 

1. The RCRA, as amended by the Hazardous and Solid Waste Act (40 CFR
260B263), governs transportation, storage, and disposal of hazardous waste.

2. The Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), governs emergency responses for
release of hazardous substances into the environment and cleanup of inactive
hazardous waste disposal sites (40 CFR 300). 

3. The Hazardous Materials Transportation Act regulates packaging, marking,
labeling, and transporting hazardous wastes (49 CFR, 170, 171, 172). 

4. The Occupational Safety and Health Act regulates safety conditions in the
workplace (29 CFR 1910.120); these provisions cover site incidents, and
supervisors are held strictly and personally liable for violations of this section.

5. The Occupational Safety and Health Act establishes employee right-to-know
provisions (29 CFR 1200).

6. State and local regulations (these may be more stringent than Federal
regulations).

To avoid confusion, State and local agencies are advised to follow the DEA
policy of treating all waste at clandestine laboratories as potential RCRA
hazardous waste, no matter how small the amount found. This will reduce
agency liability and remove guesswork from site personnel decisions regarding
seizure of equipment and chemicals. By taking this action, agencies fall under
certain EPA and Department of Transportation (DOT) regulations regarding
transporting, storage, and disposal of hazardous waste.[25]

Active Sites May Be Subject to CERCLA. In addition to the regulations listed
above, active laboratory sites may be subject to CERCLA, as amended by
SARA. This regulation established a "Superfund" to finance the cleanup of the
worst hazardous waste sites and set criteria for emergency notification of
releases of hazardous substances.

In certain cases, clandestine laboratories may pose imminent, substantial health
hazards that require an immediate response or a more long-term cleanup. A
responding agency that suspects that a chemical released at a clandestine lab is
a hazardous substance as defined by CERCLA should contact the National
Response Center, which is staffed by several agencies, including EPA, the U.S.
Coast Guard, and the Federal Emergency Management Agency (FEMA) to
initiate the response process (see Sources for Further Information). On a
national scale, clandestine drug laboratories rarely meet the criteria defined by
CERCLA. 

Compliance Officer's Role. Agencies that deal with clandestine laboratory
enforcement or cleanup should consider appointing someone to act as a
compliance officer to ensure the agency meets all applicable regulations. The
compliance officer should keep abreast of all changes in existing laws and any
new laws that may affect agency activities. 

Unlike other narcotics law enforcement efforts, clandestine laboratory
investigations and seizures require a policymaker's clear understanding of the
potential health and safety risks to involved personnel, including law
enforcement, other first responders, and cleanup contractors, and the agency's
legal responsibilities regarding occupational health and safety, as well as
environmental protection. It is important to note that supervisors are held strictly
and severely liable for failure to adhere to OSHA employee health and safety
regulations, including the providing of information to employees regarding any
hazardous conditions in their work environments. 

Notes

1. Drug Enforcement Administration, Health Services Unit, Potential Health
Hazards at Clandestine Laboratory Units, October 1985.

2. Drug Enforcement Administration, U.S. Environmental Protection Agency,
and U.S. Coast Guard, Guidelines for the Cleanup of Clandestine Drug
Laboratories, March 1990.

3. U.S. Senate Committee on the Judiciary, Drug Production and the
Environment, April 11, 1991.

4. Amdur, Mary, John Doull, and Curtis D. Claussen, Casarett and Doull's
Toxicology: The Basic Science of Poisons, 4th edition, New York: Pergamon
Press, 1991.

5. Skinner, Harry F., "Methamphetamine Synthesis via Hydriodic Acid/Red
Phosphorus Reduction of Ephedrine," Forensic Science International
48(123-124), 1990; Cantrell, T.S., John Boban, Leroy Johnson, and A.C.
Allen, "A Study of Impurities Found in Methamphetamine Synthesized From
Ephedrine," Forensic Science International 39(39-53), 1988.

6. Kittle, Lew J., Interim Guidelines for Contamination Reduction and Sampling
at Illegal Drug Manufacturing Sites, Washington (State) Department of Health,
Office of Toxic Substances, 1992.

7. Amdur, Doull, and Claussen.

8. Kittle.

9. Kittle.

10. Amdur, Doull, and Claussen.

11. A pH of 5 is moderately acidic. The letters pH stand for "hydrogen ion" and
the numbers represent negative logarithms, from an acid extreme of 0 to an
alkaline extreme of 14, with 7 representing neutrality.

12. Amdur, Doull, and Claussen.  

13. Amdur, Doull, and Claussen.

14. Amdur, Doull, and Claussen.

15. Amdur, Doull, and Claussen.

16. Amdur, Doull, and Claussen.

17. Amdur, Doull, and Claussen.

18. Amdur, Doull, and Claussen.

19. Amdur, Doull, and Claussen.

20. Kittle.

21. DEA, EPA, and U.S. Coast Guard.

22. DEA, EPA, and U.S. Coast Guard.

23. DEA, EPA, and U.S. Coast Guard.

24. Kittle.

25. EPA regulations (40 CFR Parts 261, 262, and 263); DOT regulations (49
CFR Parts 171, 172, 173, 178, and 179).

----------------------------

Chapter 3

----------------------------

Clandestine Laboratory Enforcement Program Components

A comprehensive CLEP requires a number of components to ensure that
coordinated enforcement efforts are safely and effectively implemented. This
chapter discusses eight specific components that make up such a program.
Each of these components is based on an understanding of the health and safety
risks inherent in clandestine laboratories, the legal responsibilities of
organizations to minimize occupational hazards, and the ultimate goals of seizing
the laboratory and successfully prosecuting the operator(s). Policymakers are
encouraged to consider carefully the rationale presented for each component
and to remain aware of State statutes and regulations that may impact
components of their specific programs.

Throughout this chapter, sample language from the policies and procedures
developed by the BJA demonstration sites is presented to help policymakers
formulate their own program components. However, these samples should be
considered only as blueprints; they will require modifications to meet the needs
of individual jurisdictions.

----------------------------

Component 1: The Multidisciplinary Strategic Planning Team

Creating a multidisciplinary strategic planning team to develop the strategic plan
discussed in chapter 4 and to coordinate the roles and responsibilities of the
participating agencies can be a key factor in the successful CLEP operation.
This body can be effective in identifying concerns about the program operation
and garnering support from their respective agencies, examining existing policies
and procedures and identifying linkages to the CLEP, and planning the
communication strategy and providing recommendations for training.

The strategic planning team's overall goals should:

o Advocate safe entry, seizure, and cleanup of clandestine laboratories. The
chemical and physical hazards in laboratories pose serious, acute, and chronic
health threats for law enforcement officers and other first responders. In
addition, in cases of fire or explosion, other individuals and property can be in
danger. The strategic planning team has a vital role in informing local law
enforcement, fire, and other agencies of the potential risks and the methods of
protecting both individuals and property from hazards.

o Coordinate a uniform investigative and cleanup response. The team can be
instrumental in developing response guidelines, protocols, and standard
operating procedures for law enforcement agencies, hazardous materials teams,
environmental response agencies, and State and local health departments. The
team can also develop written interagency agreements that describe how two
or more agencies will work together. 

The planning team may be formed as a state- or countywide body. For
example, the Washington State Controlled Substances Act (Revised
Code of Washington 69.50) and amendments to the Act have set forth the
principles of a coordinated, cooperative response effort.[1] Thus, the
Washington State Clandestine Laboratory Steering Committee was the planning
team formed with representatives from State agencies, but with the provision
that "local health departments may want to establish an interagency,
county-wide steering committee on illegal drug labs if none exists."[2]
Washington State's Clandestine Laboratory Steering Committee includes
representatives from the following agencies:

o Washington State Patrol, local law enforcement agencies, narcotics task
forces (including county prosecutors), and DEA.

o Fire departments' HAZMAT divisions and local HAZMAT teams.

o State Department of Ecology.

o State and local departments of health.

o State Board of Pharmacy.

o Attorney General's Office.

o State Real Estate Board.

Additional, or "ad hoc," members may be invited to attend specific meetings of
the committee. These members may include representatives from the medical
community, child protective services, and other State and local professional
associations with an interest in clandestine laboratory enforcement issues. 

The planning team should select a chairperson to coordinate its activities; the
chairmanship may be rotated on a regular basis to allow all the members
equal participation.

----------------------------

Component 2: Interagency Agreements

The development of interagency agreements or memorandums of understanding
(MOUs) should be one of the strategic planning team's primary tasks. MOUs
should be in place before any multidisciplinary, coordinated enforcement effort
is conducted. They should outline the roles and responsibilities of each agency
involved in the enforcement effort and should, at a minimum, address the
following:

o Purpose, goals, objectives, and scope of authority. The MOU should define
the mission of the CLEP, articulate the participating agencies' mutual goals, and
state clearly the program's scope of authority (statewide, regional, countywide,
or other).

o Funding. The MOU should describe how the CLEP is to be funded and the
amount of financial support to be provided by each participating agency.
Support may come from a number of sources, including each agency's
operational funds, grants and contracts, seized assets, or special tax levies.

o Pay and benefits. Agencies have considerably different pay rates, overtime
policies, liability and insurance coverage, and worker compensation benefits. A
comprehensive MOU should take these differences into account. Some
programs elect to allow participating personnel to operate under pay and
insurance plans funded by their specific agencies. While this can result in
occasional inequities, it is a very workable solution if agreed upon in the MOU.

o Personnel. The MOU should set formal personnel selection criteria and clear
rotation policies, address the length of time for program assignment, and stress
the need for participants' adherence to parent agency regulations. Since
interagency agreements are seldom all-inclusive, it is necessary for personnel to
understand that parent agencies retain authority and control over their
employees assigned to the program. 

The MOU should set specific criteria for selection and tenure of top program
leaders. Formal procedures addressing these issues in advance will help to
ensure consistency in the type of top leadership; thus, personnel changes at this
level will not pose a threat to the strategic planning team's continued effective
operation. 

o Media relations. The MOU should specify who will be responsible for
handling media relations and issuing press releases. Ideally, this responsibility
should be vested in a single person, who may be the CLEP coordinator or a
designated representative.

o Sharing forfeited assets. The MOU should specify how any forfeited assets
will be distributed and used. For example, some CLEPs may wish to distribute
the funds to participating agencies using a formula based on the number of
agencies; or the decision may be made to use the assets to augment the
program's operating budget.

In Pennsylvania, the Office of the Attorney General (OAG) and the
Pennsylvania State Police (PSP) have developed the following interagency
agreement that specifically details the goals and objectives of the clandestine
laboratory program:

----------------------------

The clandestine laboratory program is intended to be an interagency
cooperative effort between PSP and the OAG. Each agency shall participate as
fully as possible in program goals and objectives: (1) equipping and training of
the clandestine laboratory investigative unit; (2) expansion of precursor and
glassware monitoring program; (3) intelligence and operational interface
between State, local, and Federal authorities; (4) public awareness and
publicity to aid investigations; (5) location of laboratories, arrest and detention
of operators at all levels; (6) full legal support and prosecution at all levels; (7)
agreements with the Drug Enforcement Administration, the Department of
Environmental Resources, the Environmental Protection Agency, and private
waste disposal hauler contractors for disposal of harmful substances; and (8)
training for State and local officers.

Office of the Attorney General and the Pennsylvania State Police                       
Commonwealth of Pennsylvania               

----------------------------

When Washington State expanded its existing clandestine laboratory
enforcement program to include a cleanup component, the following MOU was
developed among the Washington State Department of Health, Department of
Ecology, and State Patrol to delineate each agency's roles and responsibilities.

----------------------------

It is agreed the Department of Ecology, Washington State Patrol, and the
Department of Health shall participate in the (cleanup program) as technical
advisors, proposal reviewers, panel members for contract selection, and report
reviewers. Specifically, their responsibilities during this project will be as
follows:

1. Washington Department of Health will serve as the lead agency for this
project under the Revised Code of Washington 69.50, RCW 43.27 and RCW
70.54: Public Health and Safety Act. They will provide project management,
project coordination, hire contractors, and write the final report submitted to
the Drug Enforcement Administration.

2. Washington State Patrol will serve as law enforcement experts and follow
the Federal and State Guidelines as they relate to preraid planning, initial entry,
risk assessment, and processing phase. They will operate under the provisions
of RCW 69.50: Controlled Substances Act.

3. Washington Department of Ecology will serve as environmental protection
experts and follow their mandated role of removing, transporting, and disposing
of hazardous materials under the provisions of RCW 69.50. Also, Ecology will
conduct an environmental risk assessment outside of the building as mandated
by RCW 70.105D: Model Toxins Act.

----------------------------

Component 3: Personnel and Training

Selection and training of personnel are critical to the CLEP's effectiveness. This
section should discuss the various personnel needed for an effective program
and the type of training they should receive. This section should also emphasize
the importance of all appropriate team members meeting prior to each
enforcement action to delineate their respective roles and responsibilities. 

Personnel

The CLEP should include the following personnel:

o Program coordinator. He or she should be responsible for overall CLEP 
administration and clandestine laboratory investigations. The coordinator
may also be responsible for developing and informing employees of procedures
regarding safety, industrial hygiene, and training requirements; coordinating
hazardous waste contracts (this may also be the Department of Environment's
responsibility); providing technical advice and training in laboratory
investigations and safety; reviewing and approving the selection of health and
safety equipment; coordinating the medical surveillance program; and serving on
a regional, State, and/or countywide clandestine laboratory strategic planning
team.

o Law enforcement personnel. These should include an onsite supervisor or
incident commander, an entry team, a site safety officer, a site safety appraisal
team, a forensic chemist, criminal investigators, latent print analysts, and a
photographer. 

The roles and responsibilities of the Bureau of Narcotic Enforcement, California
Department of Justice, personnel are presented as a sample in appendix B. It is
important to note that departments differ with regard to specific responsibilities.
For example, while California's procedures require two scientific personnel to
respond for all active or cooking laboratories, the Washington State Patrol's
policy allows detectives who have a good knowledge of chemicals to take
samples when there are only three or four substances involved. This allows the
detectives to process these substances onsite without having to send for a
chemist. The detectives understand that, where they may have doubts, they are
to call a chemist. The California procedures also require the presence of an
experienced criminalist when latent print analysts process a laboratory scene.

The Washington State Patrol, however, stresses the importance of a detective's
presence during latent print processing, since the detective has a working
knowledge of the case and can intercede on the analyst's behalf if other law
enforcement personnel should ask the analyst to perform an unsafe activity. 

o Financial investigator. He or she may be an employee of the law enforcement
agency or the prosecutor's office, and should be responsible for all aspects of
the financial investigation (when appropriate) of clandestine laboratory
operators.

o Prosecutor. The prosecutor plays a critical role in the program's overall
effectiveness, providing essential oversight of all aspects of the investigative
process, ensuring that the criminal and civil (when appropriate) cases are
properly developed and prepared and that financial investigations are properly
conducted, assisting with search warrant and case preparation, preparing
affidavits for destruction of all hazardous material, providing ongoing
training on legal matters to other CLEP members, and serving as a
member of the strategic planning team. 

It is important for the prosecutor to be aware of the broad range of laws and
strategies that are available for litigating cases related to clandestine laboratory
enforcement. Knowledge and application of civil, health/safety, environmental,
and child neglect/endangerment codes can, in some cases, result in enhanced
sentences and facilitate recovery of cleanup costs. For example, a Los Angeles
County prosecutor used the California Health and Safety Code 11470.2(b) to
bill the laboratory operators for recovery of the costs of "seizing, eradicating,
destroying or taking remedial action with respect to the manufacture or
cultivation of a controlled substance." Since prosecutors on both State and local
levels can marshal all the necessary legal and law enforcement resources to
conduct comprehensive investigations, they may, in some jurisdictions, serve as
the CLEP's general coordinator. Regardless of the role played in the CLEP, it
is important that the prosecutor be cross-designated as a special U.S. Attorney
for cases that may warrant Federal prosecution. 

o Fire department/HAZMAT teams. These teams provide onsite support
services to the law enforcement, health, and environmental personnel. They also
may be valuable resources for ongoing training and technical assistance to all
CLEP members.

o Health department personnel. These officials are responsible for assisting law
enforcement and fire department/HAZMAT teams onsite in accordance with
their departments' guidelines and procedures. Health department officials may
be principally responsible for posting contaminated properties, notifying
residents of health and safety risks, and developing and implementing guidelines
for the cleanup of residual contaminants. They may also provide technical
advice to law enforcement agencies regarding compliance with OSHA and
other State safety and health regulations, the selection and maintenance of
safety equipment, and the development of employee medical
monitoring/surveillance programs.

o Department of environment/ecology personnel. These officials may be
responsible for acquiring the disposal contractor, monitoring the removal of
hazardous chemicals and contaminated equipment, and monitoring the cleanup
of the laboratory's exterior environment.

Training

Since CLEP training requirements may be subject to Federal and State
regulations, policymakers should be familiar with standards set by DEA,
OSHA, and their respective State criminal justice and occupational safety and
health agencies.

All personnel who may be exposed to hazardous materials should be required
to complete specialized clandestine laboratory training. Training curriculums
should comply with Federal and State OSHA requirements and should also
meet all standards for clandestine laboratory training established by the State
criminal justice/law enforcement training agency. If possible, every law
enforcement officer should receive supervised on-the-job training in critical
areas (safety, raid techniques, handling hazardous material, using proper safety
equipment, etc.). Training should also address the specific risks to both male
and female officers who may be exposed to hazardous materials. The following
are examples of the training requirements from the California Bureau of
Narcotic Enforcement and the Washington State Patrol:

----------------------------

Personnel shall have successfully completed all applicable training requirements
as specified by the training matrix before responding to a clandestine laboratory
scene. Training requirements will meet those specified in 29 CFR 1910.120,
Hazardous Waste Operations and Emergency Response.

Law enforcement officers, onsite, and scientific support personnel shall
complete the following training: (1) a minimum of 40 hours of (California)
DOJ-approved offsite training; (2) a minimum of 3 days of actual field
experience under the direct supervision of a trained, experienced onsite
supervisor; (3) 8 hours of (California) DOJ-approved annual refresher training;
(4) a minimum of 8 hours of additional training specific to their responsibilities
and the Department's health and safety program.

California Department of Justice
Division of Law Enforcement 
Bureau of Narcotic Enforcement              
Sacramento, California

----------------------------

All clandestine drug laboratory team members shall complete training mandated
by WAC 296-62-3040.

Required training shall include: (1) A 40-hour Basic Clandestine Laboratory
Safety School, (2) 24 hours of field experience under the direct supervision of a
qualified clandestine laboratory team member, and (3) 8 hours of refresher
training annually.

In addition to the above training, supervisors shall have 3 days of supervised
onsite field experience and at least 8 hours of training covering such topics as
the employers' health and safety program, personal protective equipment
(PPE), spill contamination, and health hazard monitoring.

Sampling and training shall consist of at least 4 hours of classroom and practical
instruction by a forensic scientist who is a member of the clandestine laboratory
team.

Washington State Patrol                                         
Olympia, Washington

----------------------------

In addition to the special, investigative training required for law enforcement
officers, it is beneficial for the prosecutor to acquire an understanding of the
broad range of issues involved in the CLEP, including the roles and
responsibilities of other program participants, laboratory investigation and safety
procedures, the chemicals and processes by which illegal drugs are
manufactured, and the various violations related to laboratory operations. 

----------------------------

Component 4: Equipment 

Perhaps the most important (and sometimes controversial) decision that CLEP
policymakers must make involves the selection of and requirement for staff use
of personal protective equipment (PPE). The diversity of known and potential
health hazards at the clandestine laboratory scene requires that all responding
personnel be protected to the fullest extent possible. Federal agencies, including
EPA, OSHA, and DEA, have issued guidelines addressing the protection of
employees from hazardous materials. Policymakers should review these, as well
as State statutes and regulations addressing hazardous materials response and
occupational health and safety, prior to designing this component of the CLEP. 

Three principal elements go into the CLEP's equipment component: (1) PPE,
(2) respiratory protection, and (3) air monitoring equipment.

Personal Protective Equipment

The type and degree of protection required for clandestine laboratory response
is dependent on the type and degree of hazards to be encountered, type and
duration of work to be performed, and clothing and equipment use limitations.
The PPE component should delineate specific levels of protective equipment to
be worn for the varying hazardous chemical and physical environments
associated with clandestine laboratory responses. For example, the Washington
State Patrol policy mandates the use of self-contained breathing equipment
when dealing with certain hazardous labs, such as an LSD or fentanyl site.
(Several Federal agencies have recommended minimum levels of PPE for
varying hazardous environmental levels.[3]) This component should also identify
the specific equipment to be worn by each clandestine laboratory team, as
illustrated by the following excerpt from the Washington State Patrol
policy:

----------------------------
          
Entry Team

1. Two-piece Nomex [TM] utility suit with hood and gloves.
2. Full-face respirator.
3. Level IV ballistic vest.
4. Nylon gun belt, holster, and cuff case.
5. Leather boots.
6. Goggles (for use if respirator not required).
7. Latex over-boots.

Site Safety Appraisal Team

1.Saranex [TM] suit with hood. 
2. Two-piece Nomex [TM] utility suit with hood and gloves.
3. Self-contained breathing apparatus (SCBA).
4. Steel-toed PVC boot.
5. Vinyl glove liners.
6. Nitrile-latex gloves.
7. Latex over-boots (for use if PVC boots not used).

Processing Team

1. Saranex [TM]  suit with hood.
2. Two-piece Nomex [TM] utility suit with hood and gloves.
3. Full-face respirator.
4. Goggles (for use if respirator not required).
5. Vinyl glove liners.
6. Nitrile-latex gloves.
7. Latex over-boots (for use if PVC boots not used).

Washington State Patrol
Olympia, Washington

----------------------------

To select the appropriate level of PPE, policymakers should assess
working conditions, including airborne concentrations of contaminants and other
environmental factors. Selection criteria for PPE fall into three general areas: (1)
hazard assessment, (2) performance requirements, and (3) chemical resistance.

Hazard Assessment. Examples of hazard information that should be assessed
include:

o Chemical hazards (each chemical's physical and toxicological properties).

o Physical hazards (hot temperatures).

o Degree of hazard (grade, strength, quantity of chemicals present).o Work
function, duration, and probability of exposure.

Performance Requirements. Protective clothing and equipment should be
selected with specific use requirements in mind. Products may be manufactured
from a variety of materials that provide varying levels of protection and
performance. The following are several factors to consider in assessing PPE
performance requirements: 

o Strength (degree to which it withstands tears, abrasions, and punctures).

o Flexibility (degree to which it allows freedom of movement).

o Temperature resistance (degree of protection in extreme temperatures).

o Cleanability (whether it can be washed and decontaminated routinely).

o Durability (degree to which it resists aging and maintains protective capacity
over time).

Chemical Resistance. The PPE's chemical resistance (the degree of protection
against specific chemical hazards) requires special consideration since no single
material will provide proper protection against all chemical hazards. All
materials used in protective clothing and equipment are susceptible to attack by
various chemicals; therefore, it is important to know which material will protect
against which chemicals. 

Of the wide variety of natural and synthetic materials used to manufacture PPE,
some of the most effective are known as elastomers. Elastomers are materials
that return to their original shape after being stretched; they provide the best
protection against chemical attack (solid, liquid, or gas). Used in boots, gloves,
coveralls, and fully encapsulating suits, elastomers are sometimes combined
with other materials to enhance durability and protection. 

Since vendors may advertise a broad array of products as meeting the needs of
the clandestine laboratory enforcement team, program coordinators should
develop product specifications carefully and precisely to ensure the purchase of
equipment that will, in fact, provide the most effective protection available. A
sample from the Washington State Patrol "Product Specifications" (PPE
specifications) appears in appendix C.

Respiratory Protection

A specific, written policy addressing the selection, use, and maintenance of
respirators is an essential element of the equipment component and should
apply to all field and laboratory personnel. This policy should clearly delineate
the employer's responsibility to select and provide appropriate respirators and
to develop and provide training on their use. The policy should also describe
proper respirator use, fit testing and maintenance, medical limitations for
respirator wearers (such as restrictions on persons with respiratory problems
such as asthma, emphysema, or allergies), and program evaluation. Appendix D
contains an example of the respiratory protection program developed by the
California Bureau of Narcotic Enforcement.

Air Monitoring Equipment

Specialized air monitoring equipment is needed to evaluate chemical hazards by
testing for explosive atmosphere and oxygen deficient atmosphere at
clandestine laboratory sites prior to collecting evidence and dismantling the
laboratory. This section of the equipment component should describe the types,
uses, advantages, and limitations of various air monitoring equipment. For
example, the following is an excerpt from the California Bureau of Narcotic
Enforcement policy addressing combustible gas indicators:

----------------------------

Combustible gas indicators are used to measure the concentration of flammable
vapors or gases in the air. The results are expressed in percentage of the lower
explosive limit (LEL) of the vapor or gas.

The advantage of using this type of instrument are: (1) immediate reading; (2)
simple to operate; (3) portable; and (4) built-in audible alarms.

The limitations of using this type of instrument are: (1) combustible gas
indicators are intended for use only in normal oxygen atmospheres; (2) oxygen
deficient or enriched atmospheres can produce false readings; and (3) certain
substances (i.e., leaded gas vapors) can affect the meter's ability to respond
correctly.

California Department of Justice
Division of Law Enforcement 
Bureau of Narcotic Enforcement
Sacramento, California 

----------------------------

Additional Equipment. This section of the component should describe other
equipment and procedures necessary to ensure that the clandestine laboratory
site is processed in a safe, thorough, and timely manner. Thus, this section may
address such issues as evidence collection and inventory, chemical sampling,
prisoner handling, decontamination of site personnel, and the use of a
clandestine laboratory response van.

----------------------------

Component 5: Personnel Medical Screening and Surveillance, and Data
Collection

Although the long-term health effects of exposure to all the chemicals typically
found in clandestine laboratories have yet to be studied, many acute and
chronic effects have been documented. Most common of these include upper
respiratory ailments, kidney and liver dysfunction, and in some instances,
reproductive dysfunction. There is also evidence that PCP and its precursors
have caused chemical and neurological disorders in children born to women
who were exposed to or used PCP before the children were conceived, as well
as cases involving high levels of mercury and lead in children who were living in
houses where laboratories were operating.

The purpose of this component is to delineate procedures for monitoring the
health status of employees involved in clandestine laboratory enforcement
activities. Regular medical monitoring ensures that: (1) work-related illnesses
are detected early, making medical intervention more successful; (2) illnesses
that may be aggravated by exposure to toxins are identified; (3) injuries
resulting from exposure to toxins are immediately treated; and (4) baseline and
followup medical data are available to monitor changes in the health status of
employees who are exposed to hazardous substances.

Personnel assigned to clandestine laboratory teams should receive a baseline
medical screening, including an occupational/medical history, a complete
physical examination, a blood chemistry screen, pulmonary function and
spirometry testing, and a stress-treadmill test prior to assignment. Medical
screening should also evaluate a person's ability to wear required PPE
under specific conditions--high temperatures, for example--that may be
expected at a clandestine laboratory site. Only medically approved employees
should be assigned to the CLEP.

As illustrated by the excerpts that follow from the medical screening and
surveillance protocols of the Washington State Patrol and the Office of the
Attorney General, Commonwealth of Pennsylvania, medical examinations
should be repeated at 12-month intervals, after injury or exposure to hazardous
chemicals, and at the termination of the assignment. Annual examinations may
also be provided for employees who have left the CLEP but were exposed to
chemicals during their assignments. 

----------------------------

All members of the clandestine laboratory team shall participate in a medical
surveillance program. The medical surveillance program shall comply with
WAC 296-62-3050 and include the following: (1) a baseline physical
examination shall be obtained prior to assignment to the clandestine laboratory
team; (2) an annual physical exam obtained by each active member of the
clandestine laboratory team; (3) an examination obtained by any team member
who is injured or develops any signs or symptoms indicating possible
overexposure; (4) a physical examination at the termination of the employee's
assignment to the clandestine laboratory team.

The employer shall bear all costs associated with the medical surveillance
program.

Medical examinations shall include a medical and work history (or updated
history) with special emphasis on symptoms related to the handling of
hazardous substances and health hazards associated with clandestine
laboratories and to fitness for duty, including the ability to wear required PPE
under conditions which may be expected in clandestine laboratories.

All medical examinations shall be performed by, or under the supervision of, a
licensed physician.

Washington State Patrol               
Olympia, Washington

----------------------------

A. Medical surveillance shall be provided by the employer and all team
members according to the following guidelines:

1. Prior to assignment to the laboratory team.

2. At least once each 12 months after initial assessment.

3. At termination of employment or removal from the laboratory team if the
team member has not had an examination within the last 6 months.

4. As soon as possible upon notification by a team member that the team
member has developed signs or symptoms indicating possible overexposure to
hazardous substances or health hazards, or that the employee has been
exposed above the established exposure levels in an emergency situation.

5. At more frequent times, if examining physician determines that an increased
frequency of examination is medically necessary.

B. Medical examinations shall include a medical and work history (or updated
history if one is in the team member's file), with special emphasis on symptoms
related to the handling of hazardous substances and health hazards associated
with clandestine laboratories and to fitness for duty, including the ability to wear
required PPE under conditions (e.g., temperature extremes) that may be
expected in laboratories.

C. All medical examinations shall be performed by, or under the supervision of,
a licensed physician; and shall be provided at no cost to the team member.

D. The employer shall provide the following to the physician:

1. Copy of laboratory policy.

2. Description of team member's duties.

3. Team member's anticipated exposure levels. 

4. Description of PPE used or to be used.

5. Information from previous medical examinations.

Office of the Attorney General
Commonwealth of Pennsylvania

----------------------------

Two data collection instruments are currently used to monitor personnel whose
work includes exposure to or handling of hazardous chemicals: (1) the
Hazardous Assessment and Recognition Plan (HARP) and (2) the Clandestine
Laboratory Exposure Report (CLER).

The HARP (illustrated in appendix E) provides a chronological record of
hazardous and chemical information as it is developed during the course of an
enforcement action. It is completed onsite by the site safety officer and includes
information on potential hazards (chemical, flammable, explosive, and
radioactive) at the site. It also documents each employee's onsite work duties
and includes the specific types of chemicals present, as well as types of
protective equipment used by personnel. 

The HARP, developed by the California Department of Justice, Bureau of
Narcotic Enforcement, includes Drager tubes on its list of recommended
equipment; however, the Washington State Patrol has not found toxicity
assessment of the laboratory environment to be of value, and personnel
cautioned that the use of these tubes at a complex laboratory site could add
several hours to the processing time and provide only minimal benefit. 

A CLER (illustrated in appendix F) should be completed for each person at the
clandestine laboratory scene. The report should include such information as (1)
laboratory type, (2) length of exposure by type of activity, (3) any physical
reaction/symptom, (4) any medical diagnosis, (5) special equipment and
decontamination activities, and (6) other personnel present.

----------------------------

Component 6: Precursor Chemical Monitoring 

Developing and implementing a system to monitor the sale and distribution of
precursor chemicals is an essential element to a comprehensive approach to
clandestine laboratory enforcement. The principal Federal statute to control the
diversion of precursor and essential chemicals is the Chemical Diversion and
Trafficking Act of 1988.

In addition to Federal legislation, States have enacted precursor
chemical/glassware monitoring statutes. For example, in the States of
Washington, New Jersey, Pennsylvania, and Oklahoma, precursor chemical
statutes have been effective in reducing the number of "mom and pop"
laboratories and have placed serious burdens on even large, organized
operators/profiteers.

State statutes vary with regard to the types and quantities of chemicals they
control, licensing and reporting requirements, and sanctions, as well as the State
agency charged with monitoring the movement of these chemicals. In some
States, the monitoring agency is a law enforcement agency (department of
public safety, bureau of narcotics and drugs, the office of the attorney general,
or department of justice); while in other States, the responsibility falls on any
one of a number of agencies (the board of pharmacy, the department of health,
or the department of commerce).

Wide variations in State laws have made monitoring the sale and distribution of
these chemicals across State lines very difficult for State and local law
enforcement officials. Consequently, these officials have recommended that the
Federal Government encourage uniformity among the States and take the
initiative to develop a model State chemical control statute. This effort is
currently being undertaken by the American Prosecutors' Research Institute of
the National District Attorneys Association (APRI/NDAA).

In a draft report, Highlights of the Model State Chemical Control Act, APRI
has recommended provisions that should be contained in State chemical control
acts (see appendix G)

----------------------------

Component 7: Clandestine Laboratory Cleanup

Clandestine laboratories present significant environmental and public health
challenges; therefore, a comprehensive program invariably includes policies and
procedures for the safe disposal of the hazardous materials found, as well as for
site cleanup. 

Perhaps no component of a CLEP requires more interagency cooperation and
coordination than that of cleanup. While active labs pose a greater risk of
chemical exposure than do sites where drugs were formerly produced, both
environments should be considered hazardous waste sites and should be
treated as such by law enforcement, environmental, and health agencies.
Clearly, the cleanup component is not merely the responsibility of one agency
but is shared by all agencies represented in the program. Ultimately, the benefits
of an effective cleanup strategy are shared by all of the participating
agencies.

Chapter 2 noted that when a law enforcement agency seizes a clandestine
laboratory, the agency may become a hazardous waste generator as defined by
Federal law--the Resource Conservation and Recovery Act--and may need to
comply with applicable regulations.

As policymakers design their clandestine laboratory enforcement programs,
they should be thoroughly familiar with the rules, regulations, and issues
involved in disposal of gross contaminants. Health and environmental agencies,
as well as forensic chemists who are members of the CLEP strategic planning
team, can be instrumental in clarifying applicable Federal and State statutes and
regulations and in assisting law enforcement agencies in developing specific
policies and procedures addressing clandestine laboratory cleanup and
disposal.

Disposal of Contaminated Materials

Once all necessary evidence samples are collected at the clandestine laboratory
site, remaining chemicals, laboratory glassware, and equipment should be
considered contaminated and disposed of properly. States vary in how
hazardous chemicals may be destroyed. For example, the California Health and
Safety Code allows, with specific requirements, for the destruction of chemicals
used in the manufacture of controlled substances. The State of Washington
allows a "destruct order" (see appendix H) to be issued in conjunction with the
search warrant for the laboratory site, enabling law enforcement officers to
"destroy or arrange for the destruction of any item suspected of being
dangerous or hazardous, such as chemicals, residue, contaminated lab
equipment, containers for such items, or other suspected hazardous substance." 

Although law enforcement personnel should be present to provide security for
the disposal operation, the actual procedures should be performed by a
qualified disposal contractor. The contractor should remove, transport, store,
and dispose of all chemicals and associated glassware, equipment, and
contaminated materials from the site, and prepare manifests. In so doing, the
contractor should be familiar with and comply with applicable DOT, EPA, and
State regulations: 

o EPA and required State identification numbers.

o Controlled substances registration (if State mandated).

o Appropriate vehicles, material, and personnel available.

o Reasonable response time.

o Use of an RCRA-permitted treatment, storage, and disposal (TSD) facility.

o Knowledge and experience necessary to manage and dispose of hazardous
materials properly.

Selection of the disposal contractor may be a joint effort of the CLEP strategic
planning team, as health and environmental officials can assist law enforcement
officials in reviewing contractor qualifications in light of State and local needs.
Jurisdictions vary in how they select and use disposal contractors. For example,
in California, both the Bureau of Narcotic Enforcement and DEA have disposal
contractors; decisions about which contractor to call are most often predicated
on which is the "lead" investigative agency. In Washington State and New
Jersey, the disposal contractor is hired by the State department of ecology or
environmental protection, as illustrated by the following policy excerpts:

----------------------------

The incident commander shall notify the appropriate Department of Ecology
Spill Response Region of the possibility of a clandestine laboratory operation.

The Department of Ecology is responsible for acquiring a contractor to dispose
of chemicals and contaminated equipment found at the lab site.

Washington State Patrol
Olympia, Washington

----------------------------

All activities undertaken will comply with procedures adopted in concert with
the State Department of Environmental Protection (DEP) regarding the safe
disposal of toxic or hazardous substances seized in clandestine lab interdictions.

The DEP will, as required by law, provide assistance as necessary for the
neutralization, removal, and destruction of any toxic or hazardous materials that
are found at and seized from any clandestine lab sites.

New Jersey State Police                      
Operation ALERT Policies and Procedures

----------------------------

Securing of the Site

Once the disposal contractor has finished, law enforcement personnel should
secure the site and the appropriate State or local agency, usually the health
department, should post the site. (Law enforcement personnel should not leave
the site until it is posted; in some instances, law enforcement agencies take
responsibility for the posting.) The posting should indicate that a clandestine
laboratory was seized at that location on a specific date. Additionally, all
appropriate State and local health and environmental agencies should be
notified of an enforcement action involving the transfer, storage, or disposal of
hazardous waste.

If the laboratory site is on private property, the property owner should be
notified; if the site is on public land, the appropriate State or local agency
should be notified. (Samples of notification letters are presented in appendix I.)
In formulating procedures addressing notification, policymakers need to consult
their State and local statutes and regulations addressing hazardous waste sites
and the applicability of these laws to the specific waste generated at the site.

Cleanup of Residual Contamination

Cleanup of residual contamination--the final step in the cleanup process--is
usually the property owner's responsibility. Clandestine laboratory sites will
require cleanup if the site is to be used again as residential or commercial
property. The cleanup process consists of three steps: (1) site evaluation, (2)
residual cleanup and decontamination activities, and (3) post-cleanup sampling.

Component 8: Community Education and Awareness

As with other criminal problems, law enforcement agencies need help from the
public in preventing and detecting clandestine laboratories. Community
education and awareness should be an important part of any overall CLEP
strategy. Education and awareness programs should be designed to acquaint
the general public with warning signs of clandestine laboratory operations, such
as the smell of chemicals not normally associated with residential housing; the
presence of chemical drums, equipment, and glassware; or high levels of water
and electricity usage. In addition, public awareness programs should stress the
possibly toxic, flammable, and explosive nature of chemicals found at
laboratory sites.

Special segments of the business community should be targeted for education
and awareness programs, with particular emphasis on providing training to
residential landlords and property managers. This training should include such
topics as:

o Applicant screening.

o Rental agreements.

o Property inspections.

o Warning signs of drug activity.

o Actions to take upon discovering a clandestine laboratory.

o Eviction.

o Role of law enforcement and other agencies.

o Appropriate Federal and State laws and local ordinances.

The Portland (Oregon) Police and Fire Bureaus and the Neighborhood Crime
Prevention Program, Office of Neighborhood Associations, have developed
The Landlord Training Program: Keeping Illegal Activity Out of Rental
Property: A Practical Guide for Landlords and Property Managers (see
Sources for Further Information, Training Programs), as part of their community
policing initiative. More than 4,000 city landlords and property managers have
attended this program to date. In addition, the booklet Clandestine Drug
Labs--What Every Hotel and Motel Operator Should Know (see Sources for
Further Information, Training Programs) also was developed, describing
clandestine laboratory operations and procedures for hotel and motel managers
reporting suspicious activities.

Notes

1. RCW 69.50.500 Powers of enforcement personnel. (a) It is hereby made
the duty of the State Board of Pharmacy, the department, and their officers,
agents, inspectors and representatives, and all law enforcement officers within
the state, and of all prosecuting attorneys, to enforce all provisions of this
chapter, except those specifically delegated, and to cooperate with all agencies
charged with the enforcement of the laws of the United States, of this state, and
all other states, relating to controlled substances as defined in this chapter. (b)
Employees of the department of health, who are so designated by the board as
enforcement officers, are declared vested to be peace officers and shall be
vested with police powers to enforce the drug laws of this state.

2. Washington State Interagency Steering Committee on Illegal
Methamphetamine Drug Labs, Model Local Health Department Response to
Illegal Methamphetamine Drug Labs, Olympia, Washington: Department of
Social and Health Services, Toxic Substances Section, March 1989.

3. These Federal agencies and their respective codes are OSHA--29 CFR
1910.120 (Hazardous Waste Operations and Emergency Response); EPA--40
CFR 260 et seq. (Hazardous Waste Regulations); Department of
Transportation--40 CFR 172, 173, 178, and 179 (Transportation requirements
for hazardous materials).

----------------------------

Chapter 4

----------------------------

The Clandestine Laboratory Enforcement Program: Planning a Strategy

In recent years, many organizations have begun to heed the words "He who
fails to plan, plans to fail." As a result, organizations have become involved in
some type of long-range or strategic planning. Although opinions differ as to
how strategic planning should be defined and interpreted or designed and
executed, a general consensus exists that there is a need for some kind of
strategic planning in organizations of all sizes and cultures.[1] 

This chapter highlights the importance of strategic planning and describes the
principles of the strategic planning process as they apply to CLEPs. These
principles are translated into practical steps for program implementation in
chapter 5.

----------------------------

Strategic Planning Defined

Strategic planning, broad-based and conceptual in nature, deals with the future
in terms of long-term objectives and integrated programs for accomplishing
these objectives.[2] The strategic plan also addresses the critical issues facing
the organization in the future and is often seen as planning in the face of
obstacles or competition.[3] Strategic planning requires the setting of clear
goals and objectives and reaching these objectives within a specified
timeframe.[4] 

For CLEPs, the strategic planning process is designed to enhance the ability of
a planning team to identify and achieve specific, designed results by integrating
information about the program's external environment, its internal capabilities,
and its overall purpose and direction. The emphasis of this planning approach is
on the process itself, which is characterized by self-examination, setting
direction and priorities, making difficult choices, implementing, monitoring, and
evaluating.

----------------------------

Need for Strategic Planning

The need for a strategic planning approach is particularly important for CLEPs
because of the program's multidisciplinary nature. A CLEP's strategy
recognizes that agencies working together can often be more effective and
productive than the same agencies working separately, and the strategic plan is
the vehicle that ensures interagency cooperation, coordination, and
communication.

Strategic planning can help law enforcement, prosecution, and health and
environment personnel, as well as emergency responders, establish a common
mission and common priorities and minimize parochial perspectives in favor of
broader goals. This approach can also help highlight the need for, and ways to
obtain, funding; educate oversight bodies; deal with leadership changes;
establish policies and procedures; and make timely responses to legal and
political mandates.

----------------------------

Gaining Commitment for Strategic Planning

The first and most critical aspect in instituting a strategic planning approach for a
CLEP is commitment from the heads of the agencies involved, and this
commitment must be communicated to program participants early and clearly. It
is vital to the program's success that all participating principal organizations are
identified and their commitment to the program and the strategic planning
process obtained. 

Top Management Responsibility in Strategic Planning

The primary responsibility for development and implementation of the plan rests
with the involved agency heads. These top managers should see the planning
process as crucial to the program's overall success and be willing to invest time
and effort in a way that is visible to all participants. The creation of a CLEP--
deciding its purpose and its future course--is the task of the various agencies'
top management and should not be delegated.[5]

Identification of the Strategic Planning Team. Once commitment from
participating agency heads is obtained, the strategic planning team members
should be identified. This team should represent all participating agencies,
including Federal, State, and local law enforcement; prosecutors; fire,
health, environmental, and occupational health and safety officials; and forensic
chemists. The multidisciplinary strategic planning team is a critical CLEP
component, facilitating involvement and open dialog among all principal
participants, which, in turn, will engender program "ownership" by all the
agencies, rather than just the lead agency. It is important to remember that the
strategic planning team is not the same as the operational task force. The
planning team develops the plan, while the operational task force implements it.

Each agency head should identify and appoint individuals who can represent
that organization's various functional aspects on the planning team. The team
should be directly accountable to the agency heads who are creating the CLEP
and should be required to submit periodic progress reports to the agency heads
throughout the planning process, keeping them involved on a continuous basis
for making key choices and decisions, and providing direction. Only in this way
can the agency heads guide the planning process so as to ensure the creation of
a CLEP that meets their needs.

----------------------------

Environmental Analysis

Prior to and throughout the entire planning process, the team should be alert to
any changes and developments that may affect the CLEP. For example, a
combination of factors, including passage of the "kingpin" statute in New Jersey
and a precursor chemical statute in Pennsylvania, resulted in clandestine
laboratory operators buying their chemicals in New Jersey, but making and
distributing their products in Pennsylvania. These "environmental" factors
created the need to develop an interstate approach to clandestine laboratory
enforcement efforts.

The goal of environmental analysis is to identify trends that are most significant
for the organization and describe their likely implications. Through ongoing data
gathering and analysis of relevant trends, the team should examine a broad
range of issues: economic trends; social, technological, and political factors;
demographics; statutes and regulations; research and development; citizen
complaints; and the individual and collective strengths and weaknesses of the
participating organizations. It is important to note that environmental analysis is
not in itself a stage or phase of the strategic planning process; rather, it is a
continuous function of the planning team that provides critical information during
all strategic planning stages.[6]

----------------------------

The Strategic Planning Approach

The strategic planning approach consists of the following five elements or
stages:

o Stage 1: Mission formulation.

o Stage 2: Organizational assessment.

o Stage 3: Developing objectives.

o Stage 4: Developing action plans.

o Stage 5: Implementation.

Each of these stages is essential to the CLEP's successful development and
implementation. 

Stage 1: Mission Formulation

The program mission statement is the starting point for the plan. The mission
statement forms the foundation from which all the other strategic elements
emanate.[7] The mission statement should describe the values or beliefs that will
shape the program and the program's purpose. While developing the mission
statement may be a difficult and time-consuming task, it is critical since it will
chart the CLEP's future direction and establish a basis for decisionmaking.[8] 

Values: Beliefs That Shape the CLEP. Values are the beliefs that shape the
program and the behavior of the individuals involved.[9] Typically, an
organization's values are organized and codified into a philosophy of operations,
which explains how the organization approaches its work, how it is managed
internally, and how it relates to its external environment. Organizational values
determine what both individuals and organizations consider to be appropriate
and inappropriate behavior. Thus, values play an important role by influencing
administrative decisions as well as employee actions.

The Washington State Patrol has articulated its values as follows:

----------------------------

The Washington State Patrol has been entrusted with duties and responsibilities
to assist, preserve, protect, and defend people and their property and to
maintain social order. This public trust mandates that all members exemplify the
highest standard of conduct while on and off duty. 

Departmental members shall adhere to and uphold all laws and serve the public
in an ethical, courteous, impartial, and professional manner while respecting the
rights and dignity of all persons.

Washington State Patrol 
Olympia, Washington

----------------------------

Strategic planning team members should define and articulate those
values that they want to guide the CLEP. The multidisciplinary nature of a
CLEP necessitates clarification of the program's values: what is appropriate
behavior, how participating agencies approach their work, how they manage
internally, and how they relate to the community. In addition to examining their
own values, strategic planning team members should assess the values of their
respective organizations and their stakeholders (funding agencies, employees,
members of the community, etc.), as these will often influence what the team
identifies as the CLEP's values. 

Purpose of the CLEP. A clear mission statement:

o Defines the purpose and intent of the CLEP.

o Allows all the participating agencies to see themselves as part of a worthwhile
enterprise.

o Enables participants to see how they can improve the community through
their participation in the program.

Defining the purpose of the CLEP in the mission statement is a crucial aspect of
the strategic planning process. For example, the Washington State Patrol's
Mission Statement reads: 

----------------------------

The Washington State Patrol shall serve the public by providing assistance,
coordination, and the delivery of law enforcement and support services for the
safety and protection of people and property.

Washington State Patrol 
Olympia, Washington

----------------------------

This mission may be readily transferable to a CLEP, as exemplified by the
mission statement developed by the Commonwealth of Pennsylvania Office of
the Attorney General:

----------------------------

The Commonwealth of Pennsylvania Office of the Attorney General conducts
aggressive, comprehensive, and coordinated law enforcement activities to
detect, identify, assess, and counter or neutralize clandestine drug manufacturing
laboratories operating within the Commonwealth of Pennsylvania. In doing so,
departmental personnel shall ensure the safest possible environment by avoiding
or reducing chemical exposure.

Commonwealth of Pennsylvania 
Office of the Attorney General

----------------------------

The New Jersey State Police's Operation ALERT (Active Laboratory
Emergency Response Team) program defines its purpose as follows: 

----------------------------

To establish and make operational a team of chemists, investigators, and
attorneys who have the expertise necessary to investigate and prosecute
clandestine laboratory operators and to train and equip personnel toward this
end. 

New Jersey State Police 
West Trenton, New Jersey

----------------------------

The success of the CLEP will to a large extent depend on the clarity of the
program's purpose and whether it has incorporated all the reasons for its
existence, including not only the reduction or elimination of clandestine
laboratory activity but also the purposes related to prosecution, health, and the
environment.

Stage 2: Organizational Assessment

An important question facing the strategic planning team is whether the CLEP
has the ability to accomplish its mission effectively. Therefore, in the
organizational assessment stage of the strategic planning approach, special
attention should be paid to collecting the following data that will influence the
program's capabilities: 

Critical Issues. The organizational assessment should include information about
critical issues inside and outside the program that might impact the strategic
plan. A critical issue is defined as a difficulty that has significant influence on the
way an organization functions or on its ability to achieve a desired future for
which there is no agreed-upon response.[10] A critical issue can be almost
anything--funding, current Federal/State statutes and regulations, participating
agencies' policies and procedures, new technologies, politics, or community
acceptance. The strategic planning team needs to develop an issue agenda and
prioritize the issues that they believe will have the most impact on the program
in the next 3 to 5 years.

Strengths, Weaknesses, Opportunities, and Threats. The planning team should
identify and rank the program's strengths and weaknesses, as well as its future
opportunities and threats. The purpose of examining strengths and weaknesses
is to identify strengths that can be utilized in accomplishing the program's
mission and weaknesses that need to be managed or avoided as the strategic
plan is formulated. Future opportunities and threats should be examined since
policymakers probably will find that much of the program's future may be
dictated by forces outside its own structure. Therefore, no plans should be
developed without studying these external forces.

Stage 3: Developing Objectives

At this stage, the strategic planning team should ask the questions, What do we
want the CLEP to accomplish, and how do we measure our success or failure? 

When developing objectives, the planning team should examine what is
expected from the program by all the participating agencies. Since the CLEP is
a multidisciplinary program, there probably will be many different expectations;
however, it is essential that all participants share a common vision for the
program.

In the context of the CLEP, objectives may focus on such issues as the
elimination of clandestine laboratories, increased numbers of prosecutions
resulting in convictions, decreased levels of exposure-related injuries or illnesses
in law enforcement and other personnel, and improved environmental factors
related to the cleanup of contaminated property.

The planning team should then compare its objectives with the information
gathered about the critical issues and the program's strengths, weaknesses,
opportunities, and threats. The team should attempt to develop concrete actions
to manage the critical issues by building upon strengths, overcoming
weaknesses, exploiting opportunities, and blocking or blunting threats.[11] 

If there is a substantial discrepancy between the program's objectives and the
capacity to achieve them, the planning team should reevaluate its objectives and
rework the plan, until the gap between the objectives and the capacity to
achieve them is minimized. For example, a strategic plan that includes the
elimination of all clandestine laboratories and the prosecution of all operators in
a given region within a 6-month period would generally be unreasonable and
impossible to achieve. This strategic plan should be reworked to include
examining the program's strengths, weaknesses, opportunities, and threats and
setting a more realistic objective of reducing the number of clandestine
laboratories by a certain percentage within a given timeframe.

Stage 4: Developing Action Plans

After the objectives have been established, the planning team should identify the
proposed ways in which each objective might be met. This effort should include
analyzing the cost/benefit of each and selecting the particular strategies that are
most likely to achieve the objective.

The action planning phase should be delegated to the various participating
agencies, each of which should be expected to develop detailed action plans
with a budget and a timetable for completion. All participating agencies should
submit action plans to achieve the program's objectives.

Each agency's plan should then be checked against the program mission
statement to determine whether the proposed actions and directions are
consistent with the CLEP's mission. Each agency's plan should be agreed upon
by each of the other agencies and should become a part of an interagency
agreement. 

The team should then identify any gaps in the combined plans, determine how
they can be closed, and determine what impact, if any, the gaps might have on
the plan's implementation.

Stage 5: Implementation

In this phase, the plan is handed to the various agency heads to implement to
achieve the required results. The true test of the action plan's implementation
and effectiveness is whether the organizational managers use it in everyday
decisionmaking.

By this time, the planning team has worked closely with the various agency
heads in the strategic plan development. It is important now that the agency
heads become involved in the implementation phase in a highly visible manner,
publicly voicing their commitment to the program and its strategic plan, and
demonstrating this commitment by dedicating the resources necessary to make
it successful.

During implementation, the planning team should make periodic reports to the
agency heads and staff about the program's progress. The implementation
phase also requires the team to conduct evaluations of the strategic plans and
make any changes necessary to ensure the objectives are being met and the
program's mission accomplished.

Strategic planning is the process by which the guiding members of an
organization envision the organization's future and develop the necessary
procedures and operations to achieve the vision. The multidisciplinary nature of
a CLEP compounds the need for a strategic planning approach. 

Strategic planning is a continuous process, and it is important to realize that the
plan and the guidance it provides are required throughout the life of the CLEP.
Often, participants in the strategic planning process become bogged down with
the complexities of the plan and lose sight of its real purpose. Keeping the
planning model simple, with reasonable expectations, will help to ensure its
success. Special emphasis should be placed on reminding all participants in the
planning process that the real purpose of the strategic plan is to serve as a
framework for action in creating the future direction of the CLEP.

Notes

1. Hines, Gary, "Strategic Planning Made Easy," Training and Development,
April 1991.

2. Below, Patrick J., George L. Morrissey, and Betty L. Acomb, The
Executive Guide to Strategic Planning, San Francisco: Jossey-Bass, 1987.

3. Kaufman, Roger, Strategic Planning Plus: An Organizational Guide,
Glenview, Illinois: Scott Foresman, 1992. 

4. Goodstein, Leonard D., Timothy M. Nolan, and J. William Pfeiffer, Applied
Strategic Planning--A Comprehensive Guide, San Diego, California: Pfeiffer
and Co., 1992.

5. Goodstein, Nolan, and Pfeiffer.

6. Pfeiffer, J. William, Leonard D. Goodstein, and Timothy M. Nolan,
Understanding Applied Strategic Planning: A Manager's Guide, San Diego,
California: University Associates, Inc., 1985; Witham, Donald C., "Strategic
Planning for Law Enforcement," The Police Chief, January 1990.

7. Below, Morrissey, and Acomb.

8. Goodstein, Nolan, and Pfeiffer.

9. Wassermann, Robert, and Mark H. Moore, Values in Policing (Perspectives
on Policing No.8), Washington, D.C.: National Institute of Justice, 1988. 

10. Nutt, Paul C., and Robert W. Backoff, Strategic Management of Public
and Third Sector Organizations, San Francisco: Jossey-Bass, 1992.

11. Nutt and Backoff..c. Establishing the Clandestine Laboratory

----------------------------

Chapter 5

----------------------------

Establishing the Clandestine Laboratory Enforcement Program: Practical Steps
to Implementation

The process of building a comprehensive clandestine laboratory enforcement
program requires an organization's long-term commitment and should include
the principles of strategic planning. This chapter describes specific steps to
establishing a CLEP based on the experiences of the demonstration sites, as
well as on the principles of strategic planning discussed in the previous chapter.
Worksheets are provided as an aid to the strategic planning team in designing
the programs.

----------------------------

Practical Steps to Implementation

Practical steps to implementing a CLEP include the following:

Step 1: Develop the Program Mission Statement 

As discussed in chapter 4, the strategic planning approach to establishing an
effective CLEP begins with formulating the program's mission statement. A
precise, carefully developed mission statement, describing the program's
purpose and values or beliefs, will facilitate efficient, productive decisionmaking
during program implementation. 

Worksheet 5.1 provides a sample format for developing the CLEP's values and
mission statement.

Step 2: Select a Program Coordinator or Manager

The CLEP needs an advocate and leader. The program coordinator or
manager should be an experienced administrator with expertise in all aspects of
clandestine laboratory enforcement and with the authority to influence and
implement agencywide policies and procedures. To be successful in this role,
the coordinator should be:

o An individual in a position of authority who commands the respect of both
staff and managers and who can make the necessary operational changes to
ensure the program's success.

o An individual who can identify and evaluate existing and emerging resources
that may be of value to the program.

o A risk taker who is willing to take a leadership role in addressing
controversial issues.

o A problem solver who can identify barriers to the program and the means to
overcome them.

o A coalition builder who can work and negotiate effectively among
participating agencies' conflicting interests, bringing them together toward a
common goal.

o A strong communicator who can articulate orally and in writing the program's
incentives, goals, objectives, and mission and who can deliver briefings to all
principal program participants, other policymakers and legislators, and the
community.

Each agency participating in the CLEP may identify a program coordinator who
will be responsible for carrying out the responsibilities of his or her respective
agency. 

Step 3: Develop the Strategic Plan

As chapter 4 suggested, development of a strategic plan for the program is
crucial to its success. This process should delineate the following:

o Environmental developments and trends that will impact the program over
the next 3 to 5 years, including economic, social, legal, technological, and
political issues.

o Critical issues inside and outside the organization that may have an impact on
the program's success.

o Organizational weaknesses that need to be managed or avoided and
organizational strengths that can be utilized in accomplishing the program's
objectives.

o Program results that may indicate success or failure of the program. 

o Positive expectations of the principal participants who will support the CLEP
and negative expectations of those who will not support it.

o Action plans for each program objective. 

Use Worksheets 5.2 through 5.7 to begin the process of developing the CLEP
strategic plan.

Step 4: Identify Funding Sources and Options

Identifying sources of funding is a critical step in establishing the CLEP.
Throughout the strategic planning process, agency heads and other
policymakers should attempt to identify potential long-term funding options and
resources beyond any initial developmental funds that may be available. Agency
heads should be alert to the possibility of any State or Federal grants that may
be available. However, the life of the program should not be dependent on such
funds; these sources should be considered only as potential pieces of the total
funding. For example, it may be possible to obtain grants to fund specific
segments of the operation, such as training, equipment, etc.

In other types of drug investigations, asset forfeiture funds are often seen as a
logical source of revenue. This is not the case in most clandestine laboratory
investigations for the following reasons. First, the laboratory site may be so
contaminated that it may be virtually unusable and, therefore, worthless.
Second, the cleanup cost of the site may exceed the value of the property.
Third, even if the site is cleaned and remediated, the seizing agency may incur
civil liability due to the possibility of long-term health risks. Thus, most
clandestine laboratory sites are not seized for asset forfeiture purposes but are
returned to the property owner after the evidence and gross contaminants have
been removed. 

Some policymakers have suggested that CLEPs should be allocated a share of
the forfeitures from all drug cases. For example, the New Jersey State Police's
Operation ALERT policy states:

----------------------------

The seizure and/or forfeiture of currency and real or personal property will be
equitably shared among the agencies participating in the case based on man
hours and resources devoted by the agencies.

New Jersey State Police
West Trenton, New Jersey

----------------------------

Additional options for identifying potential funding resources beyond the initial
developmental ones include, but are not limited to the following:

o A cost-sharing consortium model. This model is based on the concept that
several jurisdictions within a State, or several agencies within a jurisdiction,
can use the services of the CLEP and, therefore, should contribute to its
funding. In this model, which may be applied to the entire program or to
any part of the program (such as disposal of hazardous materials, cleanup),
participating jurisdictions or agencies develop a "formula" for payment into a
central fund for program use. An example of this model is the San Diego
County Hazardous Materials Incident Response Team (HIRT) program,
which funds a 24-hour, emergency response capability to any hazardous
materials site, including clandestine laboratories. (See appendix J for a
description of the HIRT program and its funding formula.)

o Agency operational funds model. In this model the CLEP components are
financed by the participating agencies' operating budgets. For example, the
prosecutors' salaries are incorporated into the county prosecutor's or attorney
general's budget, the costs associated with investigation are borne by the law
enforcement agency, and the costs for disposal and cleanup are the department
of environment's responsibility. 

o Recovery legislation. State legislation may be enacted that would empower
State officials to serve an individual owner or operator of a clandestine
laboratory with a petition for the recovery of all expenses incurred in "seizing,
eradicating, destroying or taking remedial action with respect to the
manufacture or cultivation of a controlled substance."

o Other options. Policymakers have suggested other funding options, including
tax levies on chemical companies that manufacture precursor and essential
chemicals, fines on chemical companies found to be illegally selling precursor
chemicals, and Federal and State contracts/grants. Identifying
viable, long-term funding is essential prior to the development and
implementation of the CLEP. 

Use Worksheet 5.8, "Identifying Funding Resources and Options," to begin the
process of identifying CLEP funding sources. 

Step 5: Establish Components and Write Policies and Procedures

The program components are the foundation of the CLEP. Policies and
procedures should be written for each of the program components. The
CLEP can then be introduced through an internal and external communication
strategy (see step 7).

Use Worksheet 5.9, "Component Policies and Procedures," to write policies
and procedures for each component. 

Step 6: Select Staff and Develop Roles and Responsibilities

Each of the agencies participating in the CLEP should identify the appropriate
staff and delineate their respective roles and responsibilities in the program.
Refer to chapter 3 and appendix B for a discussion of personnel and their roles
and responsibilities.

Step 7: Implement an Internal and External Communication Strategy

A well-designed and executed communication strategy, targeted at both the
participating agencies and, sometimes, the community at large, can help ensure
the program's success. Communication should be viewed as a proactive part of
the program, rather than as a series of reactive responses. As with all aspects of
the CLEP, the communication strategy must have the principal participants'
support. Further, it should: 

o Involve representatives from all agencies represented in the program.

o Identify the target audiences (among them legislators, judges, law
enforcement officials, the community at large, and the media) and priorities for
each. 

o Develop a plan, including messages, content, and timing, for implementing
the communication strategy. 

o Identify appropriate individuals to implement the communication strategy.

Use Worksheet 5.10, "Communication Strategy," to devise the nature of the
communication, the message(s) to be disseminated, the intended audience(s),
and the methods.

Step 8: Prepare a Training Plan

The training plan is a part of the internal communication strategy and should
include a series of training sessions for all personnel involved in the investigation,
prosecution, and cleanup of clandestine laboratories, as discussed under
component 3. The training plan should describe the audience, goals, content,
method of delivery, and resources that will be needed. 

Use Worksheet 5.11, "Training Plan," to prepare a training plan for the CLEP.

Step 9: Develop a Health and Safety Plan

A health and safety plan should be developed to include procedures for medical
screening of employees prior to their participation in clandestine laboratory
investigations and seizures, and ongoing health monitoring of employees who
are involved in such operations. As discussed in chapter 2, screening and
monitoring of employees by agencies involved with clandestine laboratory
operations is mandated by OSHA regulations.

Step 10: Develop an Evaluation Plan

The decision to establish a CLEP involves substantial commitment and
resources. Program planners have a right to know how well the program is
working and a need to know how to improve it. Therefore, the evaluation step
should not be overlooked by program planners. An outside evaluation by
professionals is preferable as it provides an objective, third-party, expert
opinion. If the cost of an outside evaluator is prohibitive, much can be gained
from self-evaluation by officials within the program.

Even a very simple evaluation strategy can help to ensure that the program
continues to meet the agencies' and community's needs and that it is responsive
to changes in the types of clandestine laboratory cases encountered. The
evaluation strategy involves systematically examining the CLEP to document its
impact, and identifying and solving impediments to its overall functioning.
Evaluation should be ongoing throughout the implementation of the program,
since results can serve as valuable guidance for modifying the CLEP as
necessary.

The evaluation strategy should include five major components: 

o Defining the program's goals and objectives. This process consists of
examining written program documentation and discussing program goals and
objectives with the principal participants.

o Detailing the program's history. This information, which reveals the program's
scope and limitations, can often be obtained from those strategic planning team
members who were principally responsible for the program's design. Issues
to address include origins of the program, changes in the program since its
inception, and recommendations for the program's future.

o Defining the program's content. The evaluation should determine whether
each of the essential program components has been used and, if not, document
the reasons for omission.

o Describing program processes and outcomes. This step involves delineating
the components of the implementation processes and the results or outcomes.
For example, the organizational, political, legislative, and management strategies
are the processes used to implement a program. Outcomes of a program may
include an increase in the number of clandestine laboratories seized, an increase
in the number of hazardous sites remediated, and a change in the knowledge
and attitudes of the principal participants about respective roles and
responsibilities.

o Summarizing the program and providing recommendations for change. A
report should be written describing the evaluation activities and findings.
Abbreviated versions of the report may be prepared for different audiences
inside and outside the organization, including heads of participating agencies, the
news media, the public, and funding sources, where applicable. If the evaluation
developed recommendations to improve the CLEP, these recommendations
should be included in this report.

Successful implementation of a comprehensive CLEP requires the commitment
of the heads of all participating agencies, the development of a strategic plan,
and the execution of that plan in a systematic manner. The program
implementation process begins with the establishment of a strategic planning
team and ends with a program evaluation. The final step, evaluation, will serve
to identify successful program approaches, as well as approaches that may
need to be modified to ensure that all objectives are met.

----------------------------

Worksheets 5.1 to 5.11 are not included in this ASCII plain-text file. To view
this document in its entirety, download the Adobe Acrobat graphic file available
from this Web site or order a print copy from BJA at 800-688-4252.

----------------------------

Glossary 

----------------------------

Absorption- The movement of material through the skin. 

Acute- Lasting through a single event or for a short period of time.

Air purifying respirator (APR)- A device designed to protect the wearer from
the inhalation of harmful atmospheres by removing the contaminants through a
filtering media.

Carcinogen- A substance that induces cancer from either acute or chronic
exposure.

Caustic- Capable of strongly irritating, corroding, burning, or destroying living
tissue.

Chronic- Over a long period of time.

Clandestine laboratory- An illicit operation consisting of a sufficient combination
of apparatus and chemicals that either have been or could be used in the
manufacture of controlled substances.

Combustible gas indicator- An instrument used to detect and measure
flammable/explosive atmospheres.

Decontamination- The process of removing or neutralizing contaminants from
individuals and equipment.

Exposure- Any situation arising from work operations where any employee
may ingest, inhale, absorb through the skin or eyes, or otherwise come into
contact with a hazardous substance.

Exposure limit- A limit set to minimize employee exposure to a hazardous
material.

Hazardous- Capable of posing an unreasonable risk to health and safety.

Hazardous waste- A waste or combination of waste that has been identified by
Federal or State regulation as posing a risk to public health or the environment.

Incompatible- A term used to describe materials that will or can cause
dangerous reactions from direct contact with one another.

Irritant- A material that will cause an inflammatory response or reaction of the
eyes, skin, or respiratory system.

Laboratory safety certified- This term describes an employee who has current
certification meeting the medical surveillance and training matrix requirements.

Permissible exposure limit (PEL)- A maximum allowable exposure level under
OSHA regulations.

Precursor- A raw material that is essential to the production of a controlled
substance and that becomes a part of the finished product.

Route of exposure- The manner in which a chemical contaminant enters the
body (i.e., ingestion, inhalation, or absorption).

Self-contained breathing apparatus (SCBA)- A respirator designed to protect
the wearer from the inhalation of harmful atmospheres by providing a clean air
source carried by the wearer.

Site safety plan- Written, site-specific safety criteria that establish requirements
for protecting the health and safety of respondents during all activities.

Solvent- A substance, usually a liquid, into which another substance is
dissolved.

Synthesis- The formation of a complex compound by the combining of two or
more chemicals.

Toxicity- The capacity of a material to produce adverse health effects resulting
from exposure to that material.

----------------------------

Appendix A

----------------------------

Tables of Chemical Toxicity and Routes of Exposure (Washington State
Department of Health) 

These tables are not included in this ASCII plain-text file. To view this
document in its entirety, download the Adobe Acrobat graphic file available
from this Web site or order a print copy from BJA at 800-688-4252.

----------------------------

Appendix A1

Types of Inhaled Toxicants and Their Effects

o Asphyxiants- gases, such as nitrogen, that deprive the body tissues of oxygen.

o Irritants- chemicals, such as hydrogen gas and ammonia compounds, that
irritate the air passages, causing constriction of the airways and possibly edema,
or liquid in the lungs, and infection.

o Necroses- chemicals, such as nitrogen dioxide, that result in cell death and
edema.

o Fibroses- chemicals, such as silicates, that produce fibrotic tissue, which may
block airways and decrease lung capacity.

o Allergens- chemicals, such as isocyanates, that induce an allergic response
characterized by bronchial constriction and pulmonary disease.

o Carcinogens- chemicals, such as arsenic, that are associated with lung cancer.

Source: Lazarus, Bruce, Gus Ballis, Gerri Silva, and Ken Beutler. Field
Hazards and Protection Training Guide. U.S. Drug Enforcement
Administration, Clandestine Laboratory Certification Program. June 1987.

----------------------------

Appendix A2

Factors Influencing Toxicity

A number of factors influence the normal dose response. These include the
following:

o Route of exposure- the route by which a toxic material enters the body
determines how much is absorbed and which organs are exposed to the highest
concentration; e.g., the amount of chemical that is toxic orally may not be as
toxic when in contact with the skin.

o General health- some materials may be more toxic to one person than to
another, based on each person's nutrition, immunologic status, hormonal status,
and coexisting diseases.

o Gender- some materials are more toxic to one gender than another, because
of differences in body fat, metabolism, and reproductive systems. For example,
women have a larger percentage of body fat than men; this body fat tends to
retain the effects of toxic chemicals. Further, toxic chemicals cause
reproductive risks for women of childbearing years. 

o Synergism, Antagonism, and Potentiation- some combinations of chemicals
produce effects different from those attributed to each individually. Synergists
are chemicals that, when combined, cause a greater than additive effect;
antagonists are chemicals that, when combined, lessen the predicted effect.
Potentiation is a type of synergism in which the potentiator is not usually toxic in
and of itself, but has the ability to increase the toxicity of other chemicals.

o Age- children and the elderly are more susceptible to the effects of certain
chemicals than are average adults. Children have higher respiration rates and
different metabolism rates, excretory patterns, and susceptibilities than adults;
for example, children are less sensitive to central nervous system stimulants but
are more sensitive to depressants than average adults. Infants are especially
vulnerable to toxic substances since their immature livers lack the detoxification
mechanisms found in adults. The elderly are more susceptible to the effects of
certain chemicals because aging has affected their blood and hepatic systems,
musculature, metabolism, and excretory patterns. 

o Genetics- genetic differences can affect susceptibility; some people lack
genes which produce enzymes that can alter the toxicity of some chemicals. 

o Environmental factors- increased and decreased environmental temperature,
increased or decreased barometric pressure, or radiation may influence a toxic
response.

Each of these factors needs to be considered in order to accurately determine
the relative risks of any clandestine laboratory. 

Source: Lazarus, Bruce, Gus Ballis, Gerri Silva, and Ken Beutler. Field
Hazards and Protection Training Guide. U.S. Drug Enforcement
Administration, Clandestine Laboratory Certification Program. June 1987.

----------------------------

Appendix B

----------------------------

Sample Roles and Responsibilities of CLEP Law Enforcement Personnel
California Bureau of Narcotic Enforcement

Roles and Responsibilities

The roles and responsibilities section has been divided into two categories. The
first category consists of law enforcement personnel, including an onsite
supervisor, case agent, site safety officer, Bureau of Narcotic Enforcement
(BNE) narcotic task force commanders, and the clandestine laboratory
coordinator. The second category consists of scientific support personnel,
including criminalists, laboratory technicians, latent print analysts, and members
of the Hazard Response and Evaluation (HRE) Program. Finally, safety
guidelines have been included for all personnel responding to the clandestine
laboratory site.

Law Enforcement Personnel

Onsite Supervisor

o Shall be a laboratory safety certified law enforcement officer who has also
completed the 8-hour Health and Safety Supervisor training course.

o Ensures that the provisions of this manual are adhered to by all personnel.

o Has ultimate authority at the scene.

o Is responsible for reporting unusual occurrences to their immediate supervisor
and the clandestine laboratory coordinator.

o Ensures the completion of all appropriate reports/forms in a timely manner.

o Directs all phases if case agent is not laboratory safety certified.

o Should consult with the scientific support personnel on safety-related issues.

Case Agent

o Directs all phases (if laboratory safety certified).

o Assigns and directs site safety officer during all phases of the investigation.

o Ensures procedures as outlined in this manual are followed by all personnel.

o Works with the criminalists and latent print analysts in determining what items
of evidence are sampled.

o Completes all appropriate reports in a timely manner.

o Ensures that the evidence will be transported from the analyzing laboratory to
the storage location.

o Ensures proper notification of the county health department and the property
owner as required by Health and Safety Code, Division 10, Section
11642(c)(2).

o Ensures that all personnel are briefed on safety issues related to the
investigation.

o Is responsible for notifying hazardous waste hauler.

Site Safety Officer (SSO)

o The case agent shall appoint one laboratory safety certified law enforcement
officer to act as the site safety officer.

o Is responsible for health and safety at the site.

o Ensures that the HARP form is completed and submitted to the DOJ
clandestine laboratory coordinator within 10 days of the incident.

o Ensures that one laboratory safety certified individual is designated to be
available in the immediate area to enter with an SCBA and/or any other
necessary equipment in case of an emergency.

o Ensures that emergency first-aid equipment is available for immediate use at
the site (i.e., first-aid kit, eye wash, shower).

o Ensures the proper selection and use of personal protective equipment and
that replacement equipment is available.

o Notifies personnel of onsite changes that could affect safety (i.e., weather).

o Ensures that all contaminated disposable equipment is removed by the waste
hauler.

o Ensures that nondisposable equipment is decontaminated or packaged for
transfer to another site for decontamination.

o Establishes work zones and ensures that they are respected based upon
information obtained through a combination of direct reading instruments and
his/her observation.

o Ensures that there is adequate lighting to perform all required tasks safely.

o Ensures chemical spill material is available.

BNE Narcotic Task Force Commanders

o Task force commanders should request a clandestine laboratory team for
assistance at the initiation of a clandestine laboratory investigation to ensure the
availability of a laboratory team for seizure and dismantling. Notification should
be made prior to any briefing so that laboratory team members can attend. 

o Task force commanders shall ensure that officers under their command are
briefed on and understand the policies and procedures in this manual.

Clandestine Laboratory Coordinator

The coordinator supervises and directs BNE's statewide clandestine laboratory
enforcement efforts. The responsibilities of this office include:

o Developing and informing employees of procedures regarding safety,
industrial hygiene, and training requirements.

o Coordinating statewide hazardous waste contracts.

o Providing technical advice and training in lab investigation and safety.

o Reviewing and approving the selection of health and safety equipment.

o Coordinating medical monitoring of employees.

o Managing the county reimbursement program.

o Chairing the Department of Justice's statewide Clandestine Laboratory Safety
Committee.

o Preparing legislation and bill analyses.

Scientific Support Personnel

Criminalists

o Two scientific support personnel, one of whom is a criminalist versed in
chemical procedures used in illicit drug manufacturing, should respond to a
clandestine laboratory location. However, for all active or cooking laboratories,
two scientific personnel shall respond.

o Criminalists shall work with the case agent to determine what items of
evidence shall be sampled.

o Criminalists should collect l ounce of sample per inner container (40 CFR
173.4).

o Criminalists are responsible for ensuring that all sampling materials are
brought to the scene.

o Only criminalists shall sample evidence unless otherwise authorized by their
bureau chief.

o Upon arrival at the scene, the criminalists shall provide consultation to the site
safety officer to determine the level of personal protective equipment to be used
during the processing and assessment phase.

o The criminalists shall package and transport the samples to the laboratory
in accordance with procedures outlined in this manual.

Laboratory Technicians

o Laboratory technicians responding to a clandestine laboratory scene shall
meet all of the requirements for laboratory safety certification. 

o Will assist the criminalist in the sampling, packaging, and transporting of
the evidence.

Latent Print Analysts 

o Laboratory safety certified latent print analysts shall be responsible for the
processing of the clandestine laboratory scene for latent prints.

o Latent print analysts shall not process a clandestine laboratory scene unless a
clandestine laboratory experienced criminalist is present.

o Latent print lift cards shall be photographed along with the processed item.

o Latent print lift cards shall be sealed in an evidence pouch and transported by
the latent print analyst.

Hazard Response and Evaluation Program (HRE Program)

The Hazard Response and Evaluation Program was established to develop a
series of safety programs to meet the needs of the Department of Justice's
Division of Law Enforcement. The responsibilities of the HRE Program include:

o Compliance with State and Federal safety laws.

o Technical support to the Clandestine Laboratory Enforcement Program.

o Development and implementation of a chemical hygiene plan for all Bureau of
Forensic Science (BFS) laboratory facilities.

o Compliance with hazardous waste laws.

o Assistance to other law enforcement agencies in development of their safety
plans.

o Consultation to BNE for safety-related matters at the request of the chief of
narcotic enforcement.

o Development and implementation of a hazardous communication plan for the
Division of Law Enforcement.

o Provision of safety-related training to clandestine laboratory personnel. 

Safety Guidelines--All Personnel

o All personnel working at a clandestine laboratory site shall use the level of
protection established by the site safety officer.

o Prior to eating, drinking, or smoking, all personnel shall follow
decontamination procedures established in this manual.

o All personnel shall report any observed safety hazards immediately to the site
safety officer.

o All personnel shall follow decontamination procedures prior to leaving the
scene.

o All clandestine laboratory personnel shall participate in a medical surveillance
program provided by their employer.

o All personnel shall complete the minimum required training as outlined in this
manual prior to participating in clandestine laboratory preassessment,
assessment, or processing phases of the investigation.

o All personnel using personal protective equipment are required to ensure their
equipment is in safe working condition..

----------------------------

Appendix C

----------------------------

Sample Product Specifications Personal Protective Equipment (PPE)

Product Specifications

Product: Pressure demand self-contained breathing apparatus (SCBA) with
composite cylinder (30-minute service life) and NIOSH-approved, intrinsically
safe, in-mask, noise-canceling microphone.
SCBA (with case): 7 units
Composite cylinders: 10 units
Spectacle kit: 3 units
Nose cup (large): 16 units
Microphones: 7 units

I. Purpose

To establish the minimum safety standards for personal protective equipment.

II. Type 

A. The SCBA type covered by this specification shall use compressed air and
shall be approved jointly by the National Institute for Occupational Safety and
Health (NIOSH) and the Mining Enforcement and Safety Administration
(MESA) under Subpart H, 30 CFR, Part 11, for a 30-minute service life.

III. Component Parts

A. The SCBA shall consist of the following parts: 

1. Single-lens facepiece.

2. Breathing tube and coupling nut assembly.

3. Pressure-demand regulator complete with pressure gauge, mainline valve,
and integral bypass valve.

4. High-pressure hose connecting the pressure demand regulator and the
audible warning device.

5. Audible warning device.

6. Cylinder of compressed air complete with valve containing guarded pressure
gauge and with handwheel at right angle to center line of cylinder. 

7. Frame with clamp and draw bolt to retain cylinder.

8. Fire- and heat-resistant harness with stainless steel reinforcement to support
frame on wearer.

9. Speaking diaphragm with NIOSH-approved, pass-through, inmask
noise-canceling microphone.

10. Instructions for use and maintenance.

11. Carrying case.

IV. Facepiece

A. The facepiece shall be constructed as follows:

1. The number of facepieces shall be six medium and one large.

2. The single lens shall be shatterproof, available in polycarbonate or glass,
and located to provide a satisfactory field of vision for persons of widely
varying facial shapes and sizes.

3. Air shall enter the facepiece in a manner that will reduce the possibility of
accumulation of moisture on the lenses. An air deflection baffle molded in the
facepiece shall divert exhalation away from the lens.

4. Adjustable five-band rubber headband assembly shall be held in place by
roller buckles.

5. An exhalation valve opening at a pressure of approximately 1.5 inches of
water. 

6. A speaking diaphragm suitably protected.

7. A couple nut at inlet.

8. All parts shall be replaceable in the field without special tools.

9. Nose cup shall be provided as an option for each unit.

V. Breathing Tube Assembly

A. The breathing tube assembly shall consist of the following parts:

1. A corrugated breathing tube.

2. A male insert to match coupling nut on facepiece.

3. A couple nut assembly consisting of a coupling nut threaded to attach to the
regulator, an insert to the coupling nut to guide the coupling nut in connection
to the regulator, and a gasket.

4. Items 2 and 3 shall be fastened securely to the breathing tube with a suitable
clamp.

VI. Pressure-Demand Waist-Mounted Regulator

A. The pressure-demand regulator shall deliver a flow of air when the wearer
exhales and shall terminate when the wearer inhales. The static outlet pressure
shall be approximately 1.0 inches of water when tested by means of a
flowmeter to indicate the flow. The regulator shall have the following
characteristics (either air- or water-pumped nitrogen shall be acceptable for
testing and the gas pressure used for the testing shall be between 1,000 and
2,000 pounds per square inch.)

1. A flow of at least 200 liters per minute shall be delivered before there is a
negative pressure in the facepiece.

B. The pressure-demand regulator shall contain the following parts:

1. A pressure gauge to indicate the pressure in the cylinder.

2. A shutoff valve to stop airflow into the regulator from the cylinder.

3. A bypass valve to permit airflow, at controlled pressure from the cylinder,
through the regulator, independent of the shutoff valve, should malfunctioning of
the automatic elements of the regulator require such a flow. The entire flow
passage shall be integral to the regulator, with no externally mounted tube to
deliver the air from the bypass value to the regulator.

4. A pressure-reducing value to reduce the high pressure from the cylinder to a
range suitable to meet the performance requirements specified above. Such
a value shall have a centered metal filter on the inlet to retain particles 25
microns or greater, shall be in open position against the high-pressure air
inlet, and shall seat in the direction of this airflow. It shall be adjustable by
means of a screw on the regulator's exterior.

5. An admission value to deliver the airflow to the user from the reducing air
chamber during exhalation. This value shall be open in a chamber separate from
that housing the diaphragm.

6. A diaphragm responsive to respiration and used to open the admission value
by actuating twin levers for flow during inhalation. This diaphragm shall be
constructed of a material resistant to the permeation of petroleum vapors and
shall be replaceable as a unit without any retention components.

7. A spring to produce a pressure of approximately 1.0 inches of water at the
outlet of the regulator.

8. A pressure-relief valve to release pressures in excess of the normal operating
pressures of the reducing valve. The pressure at which the valve releases shall
be at least 10 pounds per square inch above the normal operating pressure of
the reducing valve and not more than 30 pounds above such pressure. It shall
be mounted external to the regulator and shall vent to the air.

9. A pressure-relief valve to release any excessive pressure that may develop
on the low-pressure side of the regulator because of blockage of the regulator
outlet. This relief valve shall vent at a nominal 35 psi pressure and shall be
mounted externally with the inlet in the diaphragm chamber. (Note:
Face-mounted regulator is unacceptable due to downward vision impairment
when working in a confined hazardous materials environment.)

VII. High-Pressure Hose

A. A high-pressure hose connecting the demand regulator and the audible
warning device shall be provided. It shall have a minimum working pressure of
2,500 psi and a minimum burst of 8,800 psi.

VIII. Audible Alarm

A. The audible alarm shall be an air-actuated, self-cocking, continuously
ringing, audible warning device, automatically operating when air pressure in
supply cylinder reaches approximately 560 psi.

IX. Cylinder

A. The cylinder shall be a nominal 514 cubic inch volume which, when filled to
2,216 psi pressure, shall contain approximately 45 cubic feet of free gas, and
shall bear DOT exemption 7277.

B. The cylinder shall contain a closing valve, which shall incorporate a pressure
gauge to indicate the pressure in the cylinder at all times. The handwheel shall
be at a 90-degree angle from the longitudinal plane of the cylinder.

C. The cylinder shall be constructed of aluminum and fiberglass composite
material (fully wound).

X. Harness

A. The harness assembly shall consist of harness straps and a metal plate fitted
with a clamp to hold the cylinder. The cylinder clamping device shall be
adjustable for various sized cylinders, hinged at one end, and equipped with a
quick opening device at the other end. The harness straps shall be attached to
the frame by replaceable nuts and bolts with leather wear pads. The harness
material shall be heat, wear, and chemical resistant, and be padded at the
shoulders for maximum comfort. The frame should contain stainless steel
reinforcement to protect against chemical or flame degradation. The entire
suspension shall be readily adjustable for various physical sizes.

XI. Carrying Case

A. A carrying case shall be provided to retain the complete apparatus and the
instruction card or booklet for each unit.

XII. Communication

A. Speaking diaphragm shall contain a NIOSH-approved, intrinsically safe
in-mask, noise-canceling microphone. Microphone cable shall be capable of
being connected to a Y-cable for interface with an amplifier and a two-way
radio.

XIII. Instruction Card or Booklet

A. An instruction card or booklet shall be provided with each apparatus. Such
instructions shall contain complete operating instructions and maintenance
procedures.

XIV. Spectacle Kits

XV. Training 

A. The vendor shall provide training to the user at no charge to the agency.

Source: Washington State Patrol

----------------------------

Appendix D

----------------------------

Sample Respiratory Protection Program
California Bureau of Narcotic Enforcement 

Clandestine Laboratory Safety Written Respiratory Protection Program Manual
May 1991

Written Respiratory Protection Program

Respiratory Protection Program--Standard Operating Procedure

1. Introduction

1.1 Scope- This standard sets forth accepted practices for respirator users, and
provides information and guidance on proper selection, use, and maintenance of
respirators.

1.2 Purpose- The purpose of this standard is to ensure that the California
Department of Justice's respiratory protection program provides guidance to all
employees using respiratory protection. This program applies to all job-related
respiratory hazards encountered both in the field or in the laboratory.

1.3 Permissible Practice- In the control of those occupational diseases caused
by breathing air contaminated with harmful dusts, fumes, sprays, mists, fogs,
smokes, vapors, or gases, the primary objective shall be to prevent
atmospheric contamination. This shall be accomplished as far as feasible by
accepted engineering control measures (e.g., enclosure or confinement of the
operation, general and local ventilation, and substitution of less toxic materials)
and/or administrative control measures (e.g., limiting exposure by adjusting
work schedule). When effective engineering and administrative controls are not
feasible or while they are being instituted or evaluated, appropriate respirators
shall be used.

1.4 Employer Responsibility

1.4.1 Approved respirators shall be provided by the employer when such
equipment is necessary to control harmful exposures.

1.4.2 The employer shall properly select the correct respirator for the job
application.

1.4.3 The employer shall be responsible for the establishment and maintenance
of a respiratory protection program.

1.4.4 The employer shall educate and train employees on proper respirator
use.

1.5 Employee Responsibility

1.5.1 The employee shall use the provided respiratory protection in accordance
with the instruction and training received.

1.5.2 The employee shall properly maintain the respirator.

1.5.3 The employee shall report any malfunction of the respirator to the
appropriate manager or supervisor.

1.6 Program Administration- Responsibility and authority for administration of
this program shall be with the HRE Program.

1.7 Safety Officer- Individual designated by the special agent supervisor or
laboratory manager who is responsible for maintenance, monthly inspection,
cartridge and accessor supply stock, etc. of respirators.

1.8 Site Safety Officer- Responsible for implementing the site safety plan,
information gathering, evaluation, and coordinated communications. 

2. Definitions

Aerosol- A system consisting of particles, solid or liquid, suspended in air.

Approved- Respirators that have been tested and listed as satisfactory, meeting
standards set by the National Institute for Occupational Safety and Health
(NIOSH), or jointly by the Mine Safety and Health Administration (MSHA)
and NIOSH.

Breathing Tube- A tube through which air or oxygen flows to the facepiece.

Cartridge- A small canister containing a filter solvent, or catalyst, or any
combination thereof, which removes specific contaminants from the air drawn
through it.

Confined Space- An enclosure--such as a storage tank, process vessel, boiler,
silo, tank car, pipeline, tube, duct, sewer, underground utility vault, tunnel, or
pit--having limited means of egress and poor natural ventilation and that may
contain hazardous contaminants or be oxygen deficient.

Contaminant- A harmful, irritating, or nuisance material that is foreign to the
natural atmosphere.

Dust- A solid, mechanically produced particle with size varying from
submicroscopic to visible.

Emergency Respirator Use- Wearing a respirator when a hazardous
atmosphere suddenly occurs that requires the immediate use of a respirator
either for escape from or entry into the hazardous atmosphere.

Facepiece- That portion of the respirator that covers the wearer's nose and
mouth (quarter mask and half mask) or that covers the nose, mouth, and eyes
(full facepiece). It is designed to make a gas-tight or particle-tight fit with the
face and includes the headbands, exhalation valve(s), and connectors for an
air-purifying device or repairable gas source, or both.

Filter- A media component used in respirators to remove solid or liquid
particles from the inspired air.

Fume- A solid condensation particle of extremely small size, generally less than
1 micrometer in diameter.

Gas- An aeriform fluid that is in the gaseous state at ordinary temperature and
pressure.

High-Efficiency Filter (HEPA)- A filter that removes from air 99.97 percent or
more of monodisperse dioctyl phthalate (DOP) particles having a mean particle
diameter of 0.3 micrometer.

Immediately Dangerous to Life and Health (IDLH)- Any atmosphere that poses
an immediate hazard to life and produces immediate irreversible debilitating
effects on health.

Inhalation Valve- A device that allows respirable air to enter a respirator and
prevent exhaled air from leaving the respirator through the valve.

Maximum Use Limit- The maximum concentration of a contaminant for which
an air-purifying filter, cartridge, or canister is approved for use.

Mist- A liquid condensation particle with sizes ranging from submicroscopic to
visible.

MSHA- Mine Safety and Health Administration, U.S. Department of Labor.

Negative Pressure Respirator- A respirator in which the air pressure inside the
respiratory-inlet covering is positive during exhalation and negative during
inhalation in relation to the air pressure of the outside atmosphere.

NIOSH- National Institute for Occupational Safety and Health, U.S.
Department of Health, Education, and Welfare.

Not Immediately Dangerous to Life or Health- Any hazardous atmosphere that
may produce physical discomfort immediately, chronic poisoning after repeated
exposure, or acute adverse physiological symptoms after prolonged exposure.

Odor Threshold Limit- The lowest concentration of a contaminant in air that
can be detected by the olfactory sense.

OSHA- Occupational Safety and Health Administration, U.S. Department of
Labor.

Permissible Exposure Limit (PEL)- The legally established time-weighted
average (TWA) concentration or ceiling concentration of a contaminant that
shall not be exceeded.

Positive-Pressure Respirator- A respirator in which the air pressure inside the
respiratory-inlet covering is positive in relation to the air pressure of the outside
atmosphere during exhalation and inhalation. 

Protection Factor- The ratio or ambient concentration of an airborne substance
to the concentration of the substance inside the respirator at the breathing zone
of the wearer. The protection factor is a measure of the degree of protection
provided by a respirator to the wearer.

Respirator- A device designed to protect the wearer from the inhalation of
harmful atmospheres.

Sanitization- The removal of dirt and the inhibiting of the action of agents that
cause infection or disease.

Service Life- The period of time that a respirator provides adequate protection
to the wearer.

Smoke- The products of combustion, pyrolysis, or chemical reaction of
substances in the form of visible and invisible solid and liquid particles and
gaseous products in the air.

Spray- A liquid, mechanically produced particle with sizes varying from
submicroscopic to visible.

Vapor- The gaseous state of a substance that is solid or liquid at ordinary
temperature and pressure.

3. Classification, Description, and Limitations of Respirators

3.1 Atmosphere-Supplying Respirators

3.1.1 Self-contained breathing apparatus (SCBAs) are respirators in which the
wearer carries his/her own breathing atmosphere. Chief limitations of SCBAs
are their weight and/or bulk, limited service life, and the training required for
maintenance and safe use. Only SCBAs providing 30 minutes of breathing air at
2215 psi and operated in the positive pressure mode will be used to enter
atmospheres requiring the use of an SCBA.

3.1.2 Emergency escape respirators used in a hazardous atmosphere for
immediate escape. This respirator is to be used only for escape. The respirator
provides 5 minutes of breathing air.

3.1.3 Air line respirators are those in which the breathing atmosphere is
supplied from a source away from the wearer.

3.2 Air Purifying- Air-purifying respirators are those employing a filter,
cartridge, or canister device to remove contaminants from the atmosphere.
These respirators do not protect against IDLH, oxygen-deficient atmospheres,
atmospheres with poor warning properties, or atmospheres not removed by
air-purifying cartridges and are limited by the type, efficiency, and capacity of
the filter, cartridge, or canister employed.

4. Selection of Respirators

4.1 Approved Respirators- Only MSHA/NIOSH-approved respirators shall
be selected. Surgical masks or unapproved dust filters shall not be substituted
for approved respirators.

4.2 General Considerations- The selection of a respirator for any given situation
shall require consideration of the following factors:

4.2.1 The nature of the hazard.

4.2.2 The characteristics of the hazardous operation or process.

4.2.3 The location of the hazardous area with respect to a safe area having
respirable air.

4.2.4 The period of time for which respiratory protection may be provided.

4.2.5 The activity of the workers in the hazardous area.

4.2.6 The physical characteristics, functional capabilities, and limitations of
various types of respirators. 

4.2.7 The respirator-protection factors and respirator fit.

4.3 Selection Criteria

4.3.1 Respiratory protective equipment shall be selected based on hazard
assessment findings and type of work being performed.

4.3.2 Selection of appropriate respirators shall be obtained with the guidance of
Respirator Selection Criteria

5. Use of Respirators 

5.1 Training- The supervisor and the respirator wearer shall be given adequate
training by a qualified person(s) to ensure proper use of respirators. Written
records shall be maintained by the clandestine laboratory coordinator for BNE
personnel and the HRE manager for BFS personnel of those persons trained
and the dates the training occurred.

5.1.1 Training of Supervisors- Supervisors who supervise respirator wearers
shall be given adequate training to ensure proper use of respirators. This training
shall include the following elements:

o The basic respiratory protection practices.

o The nature and extent of respiratory hazards to which persons under his/her
supervision may be exposed.

o The principles and criteria of selecting respirators.

o The training of respirator wearers.

o The issuance of respirators.

o The inspection of respirators.

o The use of respirators, including monitoring of use.

o The maintenance and storage of respirators.

o The regulations concerning respirator use.

5.1.2 Training of Respirator Wearers- To ensure the proper and safe use of a
respirator, the training of each respiratory wearer shall include the following
elements: 

o The reasons for respiratory protection.

o The nature, extent, and effects of respiratory hazards to which a person may
be exposed. 

o An explanation of why engineering controls are not being applied or are not
adequate and of what effort is being made to reduce or eliminate the need for
respirators.

o An explanation of why a particular type of respirator has been selected for a
specific respiratory hazard.

o An explanation of the operation, and the capabilities and limitations, of a
respirator selected.

o Instruction in selecting, donning, checking the fit, and wearing the respirator.

o An opportunity for each respirator wearer to handle the respirator, learn how
to don and wear it properly, check its seals, wear it in a safe atmosphere, and
wear it in a test atmosphere.

o An explanation of how maintenance and storage of the respirator is carried
out.

o Instruction in how to recognize and cope with emergency situations.

o Instruction for special respirator use.

o Regulations concerning respirator use.

5.1.3 Retraining- Each respirator wearer shall be retrained annually.

5.2 Respirator Fit Tests

5.2.1 A qualitative respirator fit test shall be used to determine the ability of
each individual respirator wearer to obtain a satisfactory fit with a negative
pressure respirator.

5.2.2 A person shall be allowed to use only the specific make(s) and model(s)
for which the person obtained a satisfactory fit. Under no circumstances shall a
person be allowed to use any respirator if the results of the qualitative respirator
fit test indicates that the person is unable to obtain a satisfactory fit.

5.2.3 A respirator fit test shall be carried out for each wearer of a negative
pressure respirator prior to initial respirator use and at least annually.

5.2.4 In qualitative fit tests, a respirator wearer is exposed to an irritant smoke,
an odorous vapor, or other suitable test agent. An air-purifying respirator must
be equipped with an air-purifying element(s) that effectively removes the test
agent from the inspired air. If the respirator wearer is unable to detect
penetration of the test agent into the respirator, the respirator wearer has
achieved a satisfactory fit with the respirator.

5.2.5 Respirator fit tests shall not be required for positive pressure respirators.

5.3 Respirator Fit Test Records- Records of respirator fit tests shall be kept.
These records shall include the following information:

5.3.1 A person who has hair (stubble, mustache, sideburns, beard, low hairline,
bangs) that passes between the face and the sealing surface of the facepiece of
the respirator shall not be permitted to wear such a respirator.

5.3.2 A person who has hair (mustache, beard) that interferes with the function
of a respirator valve(s) shall not be permitted to wear the respirator.

5.3.3 Spectacles that have temple bars or straps that pass between the sealing
surface of the respirator facepiece and the wearer's face shall not be used.

5.3.4 A head covering that passes between the sealing surface of the respirator
facepiece and the wearer's face shall not be used.

5.3.5 The wearing of spectacles, goggles, a face shield, helmet, or other eye
and face protective device that interferes with the seal of a respirator to the
wearer shall not be allowed.

5.3.6 If scars, hollow temples, excessively protruding cheekbones, deep
creases in facial skin, the absence of teeth or dentures, or unusual facial
configurations prevent the seal of a respirator facepiece to a wearer's face, the
person shall not be permitted to wear the respirator.

5.4 Respirator Inspection Prior to Use- Each person issued a respirator for
routine, nonroutine, emergency, or rescue use shall inspect the respirator prior
to its use to ensure that it is in good operating condition.

5.4.1 Air-purifying respirator inspection shall include facepiece, face shield,
straps, buckles, valves, cartridges/canisters, and sealing caskets. 

5.4.2 SCBA inspection shall include facepiece, face shield, straps, buckles,
valves, breathing tubes, fittings, compressed air cylinder, air hoses, regulator,
and low-pressure warning device.

5.5 Leaving a Hazardous Area- A respirator wearer shall be permitted to leave
the hazardous area for any respirator-related cause. Reasons that require a
respirator wearer to leave a hazardous area include but are not limited to the
following:

o Failure of the respirator to provide adequate protection.

o Malfunction of the respirator.

o Detection of leakage of an air contaminant into the respirator.

o Increase in resistance of respirator to breathing.

o Severe discomfort in wearing the respirator.

o Illness of respirator wearer.

6. Maintenance of Respirators

6.1 Cleaning and Sanitizing- Each respirator shall be cleaned and sanitized to
ensure that the respirator wearer is provided with a clean and sanitized
respirator at all times. Respirators shall be cleaned and sanitized after each
use following the manufacturer's recommendations.

6.2 Inspection

6.2.1 Each respirator shall be inspected before and after use. A respirator shall
be inspected by the user immediately prior to each use to ensure that it is in
proper working condition.

6.2.2 Respirators used/maintained for emergency shall be inspected at least
monthly by a designated individual.

6.2.3 A record of inspection dates, findings, remedial actions, and the name of
the individual performing the inspection shall be kept with each respirator.

6.3 Part Replacement and Repair

6.3.1 Replacement of parts or repairs shall be done only by persons trained in
proper respirator assembly and correction of possible respirator malfunctions
or defects.

6.3.2 Replacement parts shall be only those designed for the specific respirator
being repaired.

6.4 Storage- Respirators shall be stored in a manner that will protect them
against dust, sunlight, heat, extreme cold, excessive moisture, or damaging
chemicals. Respirators shall be stored to prevent distortion of rubber or other
elastomeric parts.

7. Special Problems

7.1 Vision

7.1.1 Employees who wear corrective lenses shall be provided spectacle kits
designed to hold corrective lenses inside the respirator mask

7.1.2 The wearing of contact lenses is prohibited in any atmosphere where a
respirator is required.

7.2 Use of Respirators for Entry Into Atmosphere Immediately Dangerous to
Life or Health- When respirators are required for entry into IDLH
atmospheres, at least one standby person shall have the proper equipment
available to assist the respirator wearers in case of emergency. Communications
(visual, voice, or other suitable means) shall be maintained between the standby
person and the respirator wearers.

7.3 Respirator Use in Confined Spaces- All confined spaces shall be
considered to be immediately dangerous to life or health unless proven
otherwise. Before a person is allowed to enter a confined space, tests shall be
carried out to determine the concentration of any known or expected flammable
or toxic contaminant present and to determine the concentration of oxygen. A
person shall not be permitted to enter a confined space without wearing the
proper type of respirator.

8. Evaluation of Program Effectiveness

8.1 Wearer Acceptance- Respirator wearers shall be consulted periodically
about their acceptance of respirators. Factors affecting the wearer acceptance
of respirators include comfort, resistance to breathing, fatigue, interference with
vision, interference with communication, restriction of movement, and
confidence in the effectiveness of the respirator to provide adequate protection.

8.2 Appraisal of Protection Afforded- Medical surveillance of respirator
wearers shall be conducted annually to determine if respirator wearers are
being provided with adequate respiratory protection.

8.3 Industrial hygiene evaluation of workplace conditions requiring use of
respirators shall be periodically conducted.

9. Medical Limitations for Respirator Wearers

9.1 No employee shall be assigned work requiring the use of a respirator,
including standby mode, unless it has been determined by a physician that the
person is physically able to perform the work while using a respirator.

9.2 The physician's determination that an employee is certified to wear/use a
respirator shall be based on medically indicated tests and findings, including:

o Medical history.

o Pulmonary function tests (spirometry).

o Treadmill test (when indicated).

o Chest x-ray (when indicated).

9.3 The physician's determination shall be made at the time of preemployment
medical examination and updated annually.

9.4 The physician's determination shall be documented on the "Physician's
Certification of Employee Respirator Use" letter or similar document, signed by
the examining physician and placed into the employee's confidential medical
record.

----------------------------

Appendix E

----------------------------

Sample Hazardous Assessment and Recognition Plan (HARP) Instrument
California Bureau of Narcotic Enforcement is not included in this ASCII
plain-text file. To view this document in its entirety, download the Adobe
Acrobat graphic file available from this Web site or order a print copy from
BJA at 800-688-4252.

----------------------------

Appendix F

----------------------------

Sample Clandestine Laboratory Exposure Report (CLER) Instrument
California Bureau of Narcotic Enforcement is not included in this ASCII
plain-text file. To view this document in its entirety, download the Adobe
Acrobat graphic file available from this Web site or order a print copy from
BJA at 800-688-4252.

----------------------------

Appendix G

---------------------------

Highlights of the Model State Chemical Control Act
American Prosecutors Research Institute
National District Attorneys Association

Preventing Illegal Diversion

o Regulates transactions involving chemicals frequently used in the illicit
production of controlled substances.

o Authorizes emergency regulation of chemicals on a temporary basis to avoid
imminent hazards to public safety.

Controlling Access to Chemicals

o Requires annual registration of persons who manufacture, provide, sell,
furnish, transfer, or deliver regulated chemicals.

o Terminates registration upon registrant's death, cessation of legal existence,
discontinuation of business or professional practice, or change in ownership.

o Precludes assignment or transfer of registration without written consent from
an appropriate State official.

o Requires a permit for each time a person seeks to possess a regulated
chemical.

o Requires a permit applicant to submit detailed identification information,
including notarized fingerprint cards (except in specified circumstances) and
criminal history. Business applicants must provide information for each owner,
manager, agent, or representative.

Protecting Lawful Use and Facilitating Implementation

o Excludes from regulation agents, common carriers, law enforcement officers,
medical practitioners, and pharmacists who handle regulated chemicals in
the lawful course of practice, business, or employment.

o Allows, upon application by a drug manufacturer, the exemption of a specific
drug product from regulation (e.g. Bronkaid, Tedral, Primatine).

o Exempts owners, partners, and corporate officers of publicly held
corporations of 35 shareholders or more from permit application requirements
to submit criminal history, fingerprint cards, and other identification information.

o Allows submission of retrospective monthly reports in lieu of a permit if the
possessor is eligible to apply for a permit and either maintains a regular supply
and purchase relationship with a distributor or has a record of lawful use.

o Provides permit applicants the right to appeal if official fails to act on an
application within 21 days after receipt of a completed application.

o Provides a show cause hearing for denial, suspension, or revocation of a
registration or permit, or suspension or revocation of a monthly report, with
right to appeal.

o Allows distributors and possessors to submit copies of reports submitted
under Federal law for transactions involving threshold amounts.

o Allows appropriate State officials to charge nonrefundable application fees to
cover processing and other administrative costs.

Tracking the Flow of Chemicals

o Requires regulated distributor to obtain identification of purchaser and any
vehicle used in the transaction.

o Requires regulated distributor and possessor to prepare annual physical
inventory and maintain readily accessible records for 4 years after the date of
the transaction.

o Requires regulated distributor and possessor to report theft or loss of
chemicals, breakage of containers, and suspicious transactions (e.g., method of
payment or delivery not in the usual course of business, potential violations of
Act or EPA laws).

Deterring Unauthorized Action and Protecting the Environment

o Imposes civil fines on corporations in addition to criminal penalties.

o Establishes civil assessments for cleanup of hazardous illegal
laboratory sites and enforcement of the Act.

o Authorizes forfeiture of chemicals and property pursuant to controlled
substances acts.

Determining Compliance With the Act

o Provides State official investigatory powers to subpoena witnesses, compel
testimony, and require production of documents.

o Requires confidentiality of information obtained through administrative
investigation.

o Authorizes administrative inspection of premises where chemicals and records
are required to be or in fact kept.

Source: American Prosecutors Research Institute, National District Attorneys
Association. Alexandria, VA. 1992. (Produced under grants from the Bureau
of Justice Assistance and the National Institute of Justice.) 

----------------------------

Appendix H

----------------------------

Sample Destruct Order Washington State Patrol is not included in this ASCII
plain-text file. To view this document in its entirety, download the Adobe
Acrobat graphic file available from this Web site or order a print copy from
BJA at 800-688-4252. 

----------------------------

Appendix I

----------------------------

Sample Notification of Hazardous/Toxic Chemical Contamination Letters
(California Office of the Attorney General and Washoe County, Nevada
District Health Department) is not included in this ASCII plain-text file.
To view this document in its entirety, download the Adobe Acrobat graphic file
available from this Web site or order a print copy from BJA at 800-688-4252.

----------------------------

Appendix J

----------------------------

Sample Hazardous Materials Incident Response Team (HIRT) Program
Executive Summary
San Diego, California

Section I Executive Summary

On October 1, 1986, a regional hazardous materials emergency response
program was implemented in San Diego County. The program was designated
the Hazardous Materials Incident Response Team or HIRT. The program was
developed by, and is a program of, the San Diego County Unified Disaster
Council. The Disaster Council is the governing body of the Unified San Diego
County Emergency Services Organization. This Emergency Services
Organization was established under an Agreement of Joint Powers signed by
the County of San Diego and all incorporated cities within the county.

The program calls for hazardous materials emergency response to be provided
countywide through the joint efforts of the San Diego Fire Department (SDFD)
HAZMAT Response Team and the San Diego County Department of Health
Services' Hazardous Materials Management Division (HMMD). Both of these
agencies have highly trained teams with many years of experience in responding
to hazardous materials emergencies. The cities and the county are the primary
funding source for HIRT.

Under this program, a combined response is provided. The SDFD HAZMAT
Response Team is responsible for isolating and containing the incident, stopping
the release, effecting rescues, and other related tasks. The HMMD, on the
other hand, is responsible for assessing the risk to public health and safety and
the environment, taking the necessary steps to mitigate these hazards, ensuring
adequate cleanup of the area, and conducting necessary enforcement activities.
The combined team is referred to as the Hazardous Materials Incident
Response Team, or HIRT.

HIRT will respond to the request of first responders at a hazardous materials
incident. HIRT provides advice and technical support to the first responder but
does not assume scene management responsibility. The first responder, or
appropriate agency designated by law, maintains full control and authority over
the incident and retains responsibility for any release of public information
concerning the incident.

HIRT is normally activated through the City of San Diego's Fire Department
Communication Center. HIRT can also be contacted directly by telephone or
established radio channels. Communication and consultation between local
agencies and HIRT can be maintained while in route through the use of mobile
telephones.

This program has a number of benefits, some of which include the following:

1. Makes available, throughout San Diego County, a team of highly trained
hazardous materials response professionals.

2. Reduces potential liability to individual jurisdictions by having a specialized
response capability available.

3. Makes available to member jurisdictions an expert resource for a
wide variety of hazardous materials questions, problems, and issues.

4. Eliminates unnecessary duplication of effort by having one program providing
a coordinated and standardized response making the best use of available
resources.

5. Provides a formal process for cost recovery that takes advantage
of the most recent enabling legislation.

6. Makes grant monies and equipment more accessible by consolidating into a
single request the needs and requirements of the entire area (4,255 square
miles) and total population (exceeding 2,500,000) of San Diego County.

7. Allows for user control of a regional program by using, as the administrative
authority, an existing regional organization of which the user jurisdictions are
members.

The HIRT program is considered to be a successful, effective, and desirable
program. User jurisdictions have expressed a high level of satisfaction. While
the number of incidents has increased, the team's experience and efficiency
have improved and kept pace.

The HIRT program, with its regional approvals, control, and response, is
unique in the country. Interest from other areas is high. Inquiries have been
received from throughout California and from other states, such as Arizona,
Florida, Massachusetts, Ohio, and Oklahoma. The program is viewed
nationally as a successful model program.

----------------------------

References 

----------------------------

Amdur, Mary, John Doull, and Curtis Claussen. Casarett and Doull's
Toxicology: The Basic Science of Poisons. 4th Edition. New York: Pergamon
Press. 1991. 

Below, Patrick J., George L. Morrissey, and Betty L. Acomb. The Executive
Guide to Strategic Planning. San Francisco: Jossey-Bass. 1987.

Boseman, Barry, and Jeffrey D. Straussman. Public Management Strategies:
Guidelines for Managerial Effectiveness. San Francisco: Jossey-Bass. 1990.

Bryson, John M., and Robert C. Einsweiler. Strategic Planning: Threats and
Opportunities for Planners. Chicago: Planners Press, American Planning
Association. 1988.

California Department of Justice, Division of Law Enforcement, Bureau
of Narcotic Enforcement. Clandestine Laboratory Manual of Instruction and
Procedure. Sacramento: California Department of Justice. March
1992.

Camillus, John C. Strategic Planning and Management Control: Systems
for Survival and Success. Lexington, Massachusetts: Lexington Books.
1986.

Cantrell, T.S., John Boban, Leroy Johnson, and A.C. Allen. "A Study of
Impurities Found in Methamphetamine Synthesized From Ephedrine." Forensic
Science International. 39(39-53). 1988.

Checkoway, Barry. Strategic Perspectives on Planning Practice. Lexington,
Massachusetts: Lexington Books. 1986.

Coates, Joseph F. Issues Management: How You Can Plan, Organize, and
Manage for the Future. Mount Airy, Maryland: Lomond Press.
1986. 

Cope, Robert. High Involvement Strategic Planning: When People and
Their Ideas Really Matter. Oxford, Ohio: The Planning Forum. 1991.

Drug Enforcement Administration, Health Services Unit. Potential Health
Hazards at Clandestine Laboratory Sites. October 1985.

Drug Enforcement Administration, U.S. Environmental Protection Agency, and
the U.S. Coast Guard. Guidelines for the Cleanup of Clandestine Drug
Laboratories. March 1990.

Executive Office of the President. Methamphetamine Facts and Figures.
Washington, D.C.: Office of National Drug Control Strategy. January
1997.

Executive Office of the President. National Methamphetamine Strategy
Update. Washington, D.C.: Office of National Drug Control Policy. May
1997.

Goodstein, Leonard D., Timothy M. Nolan, and J. William Pfeiffer. Applied
Strategic Planning-A Comprehensive Guide. San Diego, California: Pfeiffer and
Company. 1992.

Hamermesh, Richard C. Making Strategy Work: How Senior Managers
Produce Results. New York: Wiley. 1986.

Hellebust, Karsten G., and Joseph C. Krallinger. Strategic Planning
Workbook. Oxford, Ohio: The Planning Forum. 1989.

Hines, Gary. "Strategic Planning Made Easy." Training and Development. April
1991.Johnson, Gerry. Strategic Change and the Management Process. New
York: Blackwell. 1987. 

Karger, Delmar W. Strategic Planning and Management: The Key to
Corporate Success. New York: Dekker. 1991.

Kaufman, Roger. Strategic Planning Plus: An Organizational Guide. Glenview,
Illinois: Scott Foresman. 1992.

Kittle, Lew J. Interim Guidelines for Contamination Reduction and Sampling at
Illegal Drug Manufacturing Sites. Washington Department of Health, Office of
Toxic Substances. 1992.

Knox, Dahk. Organizational Effectiveness: The Strategic Planning Process. Ican
Press. 1992.

Lazarus, Bruce, Gus Ballis, Gerri Silva, and Ken Beutler. Clandestine
Laboratory Certification Program: Field Hazards and Protection Training
Guide. Washington, D.C.: U.S. Drug Enforcement Administration.1987.

Makridakis, Spyros G. Forecasting, Planning, and Strategy for the 21st
Century. New York: Free Press. 1990.

Manzini, Andrew O., and John D. Gridley. Integrating Human Resources and
Strategic Planning. New York: AMACOM. 1986.

McCoy, Bowen H. "The Parable of the Sadhu." Harvard Business Review 83,
No. 5. September-October 1983.

Melcher, Bonita H., and Harold Kerzner. Strategic Planning: Development and
Implementation. Blue Ridge Summit, Pennsylvania: TAB Professional and
Reference Books. 1988.

Migliore, R. Henry. Strategic Planning and Management. Pontiac, Michigan:
GP Publishing. 1990.

Moore, Mark Harrison, and Darrel W. Stephens. Beyond Command and
Control: The Strategic Management of Police Departments. Washington, D.C.:
Police Executive Research Forum. 1991.

Morrison, James L., and William L. Renfro. Futures Research and the Strategic
Planning Process: Implications for Higher Education. Washington, D.C.: ERIC
Clearinghouse on Higher Education. 1984.

Nanus, Burt. Visionary Leadership. San Francisco: Jossey-Bass. 1992.

Nutt, Paul C., and Robert W. Backoff. Strategic Management of Public
and Third Sector Organizations. San Francisco: Jossey-Bass. 1992.

Owens, Tom. Strategic Planning. Los Altos, California: Crisp Publications.
1992.

Pfeiffer, J. William, Leonard D. Goodstein, and Timothy M. Nolan.
Understanding Applied Strategic Planning: A Manager's Guide. San Diego,
California: University Associates, Inc. 1985.

Pfeiffer, J. William, Leonard D. Goodstein, and Timothy M. Nolan. Shaping
Strategic Planning: Frogs, Dragons, Bees, and Turkey Tails. San Diego,
California: Pfeiffer and Company. 1989.

Radford, K.J. Strategic Planning: An Analytical Approach. Reston,
Virginia: Reston Publishing Co. 1980.

Sax, Irving N. Dangerous Properties of Industrial Materials. 6th Edition. New
York: Van Nostrand Reinhold. 1984.

Sibson, Robert E. Strategic Planning for Human Resources Management.
New York: AMACOM. 1992.

Skinner, Harry F. "Methamphetamine Synthesis via Hydriodic Acid/Red
Phosphorus Reduction of Ephedrine," Forensic Science International.
48(123-134). 1990.

Steiner, George A. Strategic Planning: What Every Manager Must Know. New
York: Free Press. 1979.

U.S. Department of Health and Human Services. Proceedings of the
National Consensus Meeting on the Use, Abuse, and Sequelae of Abuse of
Methamphetamine with Implications for Prevention, Treatment and Research.
Substance Abuse and Mental Health Services Administration. 1997.

U.S. Department of Justice. Controlling Chemicals Used To Make Illegal
Drugs: The Chemical Action Task Force and the Domestic Chemical Action
Group. Washington, D.C.: National Institute of Justice. January 1993.

U.S. Department of Justice. Developing a Strategy for a Multiagency Response
to Clandestine Drug Laboratories, Washington, D.C.: Bureau of Justice
Assistance. June 1993.

U.S. Department of Justice. Drug Use Forecasting 1996: Annual Report on
Adult and Juvenile Arrestees. Washington, D.C.: National Institute of Justice.
June 1997.

U.S. Department of Justice. Methamphetamine Precursor Chemical Control in
the 1990's. Washington, D.C.: Drug Enforcement Administration. April
1997.

U.S. Senate Committee on the Judiciary. Drug Production and the
Environment. April 11, 1991.

Washington State Department of Social and Health Services, Toxic Substances
Section. Model Local Health Department Response to Illegal
Methamphetamine Drug Labs. Olympia, Washington: Department of Social and
Health Services. March 1989.

Wasserman, Robert, and Mark H. Moore. Values in Policing. Perspectives on
Policing No. 8. Washington, D.C.: U.S. Department of Justice, National
Institute of Justice. November 1988.

Witham, Donald C. "Strategic Planning for Law Enforcement." The Police
Chief. January 1990.

----------------------------

Sources for Further Information

----------------------------

Expert Sources are not included in this ASCII plain-text file. To view this
document in its entirety, download the Adobe Acrobat graphic file available
from this Web site or order a print copy from BJA at 800-688-4252.

Federal Agencies 

U.S. Drug Enforcement Administration Division Offices

Atlanta Field Division
Richard B. Russell Federal Building
75 Spring Street SW., Room 740
Atlanta, GA 30303
404-331-7347

Boston Field Division
15 New Sudsbury Street, Room E400
Boston, MA 02203
617-557-2100

Chicago Field Division
230 S. Dearborn Street, Suite 1200
Chicago, IL 60604
312-353-7875

Dallas Field Division
1880 Regal Row
Dallas, TX 75235
214-640-0801

Detroit Field Division
431 Howard Street 
Detroit, MI 48226
313-234-4000

Houston Field Division
1433 West Loop South
Houston, TX 77024
713-693-3000

Los Angeles Field Division
255 East Temple Street, 20th Floor
Los Angeles, CA 90012
213-894-2650

Miami Field Division
8400 Northwest 53d Street
Miami, FL 33166
305-590-4870

Newark Field Division
Federal Office Building, Suite 806970 
Broad Street Newark, NJ 07102
201-645-6060

New Orleans Field
Division3838 North Causeway Boulevard, Suite 18003 
Lakeway Center Metairie, LA 70002
504-840-1100

New York Field Division
99 10th Avenue 
New York, NY 10011
212-337-3900

Philadelphia Field Division
600 Arch Street
Philadelphia, PA 19106
215-597-9530

Phoenix Field Division
Suite 301
3010 North 2d Street
Phoenix, AZ 85012
602-664-5600

Rocky Mountain Field Division
115 Inverness Drive East
Englewood, CO 80112
303-705-7311

San Diego Field Division
4560 Viewridge Avenue 
San Diego, CA 91950 
619-616-4100

San Francisco Field Division
450 Golden Gate Avenue 
San Francisco, CA 94102
415-436-7900

Seattle Field Division
Suite 104
220 West Mercer 
Seattle, WA 98119
206-553-5443

St. Louis Field Division
Suite 500 
7911 Forsythe Boulevard
St. Louis, MO 63105
314-425-3241

Washington Field Division
Room 2558
400 Sixth Street
SW. Washington, DC 20024
202-401-7834

National Response Center
1-800-424-8802 

U.S. Environmental Protection Agency Regional Offices
(24-hour response telephone numbers)

EPA Region 1
Emergency Planning and Response 
Branch John F. Kennedy Building
Boston, MA 02203
617-223-7265

EPA Region 2
Response and Prevention Branch 
2890 Woodbridge Avenue
Edison, NJ 08837
732-548-8730

EPA Region 3
Superfund Removal Branch
841 Chestnut Street
Philadelphia, PA 19107
215-566-3255 

EPA Region 4
Emergency Response and Removal Branch
345 Courtland Street NE., 1st floor
Atlanta, GA 30365
404-562-8700

EPA Region 5
Emergency Response Branch
77 West Jackson, 5th Floor HSE-5J
Chicago, IL 60604
312-353-2318

EPA Region 6
Emergency Response Branch
1445 Ross Avenue, 9th Floor
Dallas, TX 75202-2733
214-665-2222

EPA Region 7
Emergency Planning and Response Branch
25 Funston Road, 2d Floor 
Kansas City, KS 66115
913-281-0991

EPA Region 8
Emergency Response Branch
999 18th Street, Suite 500
Denver, CO 80202-2405
303-293-1788
1-800-227-8914

EPA Region 9 
Field Operations Branch
75 Hawthorne Street
San Francisco, CA 94105
415-744-2000

EPA Region 10
Emergency Response
1200 Sixth Avenue 
Seattle, WA 98101
206-553-1263

Publications 

Note: The publications listed below are available from the National Technical
Information Service, U.S. Department of Commerce, Springfield, VA 22161,
703-605-6000. 

An Overview of the Emergency Response Program. Office of Emergency and
Remedial Response, U.S. Environmental Protection Agency. Washington, D.C.
April 1992.

Chemical Handler's Manual: An Informational Outline of the Chemical
Diversion and Trafficking Act of 1988. U.S. Drug Enforcement Administration.
Washington, D.C. 1990.

Guidelines for the Cleanup of Clandestine Drug Laboratories. Joint Federal
Task Force of the U.S. Drug Enforcement Administration, U.S. Environmental
Protection Agency, and U.S. Coast Guard. Washington, D.C. March 1990.

Hazardous Waste Operations and Emergency Response: General Information
and Comparison. Office of Emergency and Remedial Response, U.S.
Environmental Protection Agency. Washington, D.C. April 1991.

Hazardous Waste Operations and Emergency Response: Uncontrolled
Hazardous Waste Sites and RCRA Corrective Actions. Office of Emergency
and Remedial Response, U.S. Environmental Protection Agency. Washington,
D.C. April 1991.

HAZMAT Team Planning Guidance. Office of Emergency and Remedial
Response, U.S. Environmental Protection Agency. Washington, D.C. February
1990.

Protecting Health and Safety at Hazardous Waste Sites: An Overview. U.S.
Environmental Protection Agency. Washington, D.C. September 1985.

Reimbursement to Local Governments for Emergency Response to Hazardous
Substance Releases. Office of Emergency and Remedial Response, U.S.
Environmental Protection Agency. Washington, D.C. November 1989.

Note: The publications listed below are available from the National Criminal
Justice Reference Service, U.S. Department of Justice, Box 6000, Rockville,
MD 20850, 800-851-3420.

Controlling Chemicals Used to Make Illegal Drugs: The Chemical Action Task
Force and the Domestic Chemical Action Group. National Institute of Justice,
U.S. Department of Justice. Washington, D.C. January 1993.

Multijurisdictional Drug Law Enforcement Strategies: Reducing Supply and
Demand. National Institute of Justice, U.S. Department of Justice, Washington,
D.C. December 1990.

Precursors and Essential Chemicals in Illicit Drug Production: Approaches to
Enforcement. National Institute of Justice, U.S. Department of Justice.
Washington, D.C. October 1993.

Note: The following publications are available from the National Drug
Intelligence Center, Johnstown, PA, 814-532-4601.

Effects of D-Methamphetamine, National Drug Intelligence Center, U.S.
Department of Justice, Johnstown, PA. December 1996.

Ephedra: A Potential Precursor for D-Methamphetamine Production, National
Drug Intelligence Center, U.S. Department of Justice. Johnstown, PA. May
1997.

Hazards of D-Methamphetamine Production, National Drug Intelligence
Center, U.S. Department of Justice. Johnstown, PA. June 1995.

Note: The following publications are available from a number of sources,
including government agencies, libraries, and bookstores. They contain
significant information on clandestine drug laboratory chemical processes,
emergency response, scene management, and cleanup and removal operations: 

Allen, A.C. A Review of the Synthesis and Analysis of Fentanyl and Its
Analogs. Clandestine Laboratory Investigative Chemists Association. 1996.

Hugel, J., and A. Holmes An Analyst's Guide to the Investigation of
Clandestine Laboratories. Clandestine Laboratory Chemists Association. 1995.

Kalchick, M.F. A Review of the Synthesis and Analysis of Phencyclidine and
Its Analogs. Clandestine Laboratory Chemists Association. 1995.

Kalchick, M., and R. Ely. A Review of the Synthesis and Analysis of
Phenyl-2-Propanone, Amphetamine, and Methamphetamine, Volumes 1 and 2.
Clandestine Laboratory Investigative Chemists Association. 1993.

Chemical Threats to Police Officers from Clandestine Drug Labs. Royal
Canadian Mounted Police. March 1996 (ISBN 0-662-24268-8).

Clandestine Drug Lab Contaminant Reduction Program. City of Portland,
Oregon. April 1993.

Clandestine Drug Laboratories Cleanup Demonstration Program. California
Environmental Protection Agency, Division of Toxic Substances Control. July
1993.

Clandestine Laboratory Manual of Instruction and Procedure. California
Department of Justice, Bureau of Narcotic Enforcement. March 1992.

Clandestine Laboratory Policy Manual for Law Enforcement Agencies.
Washington State Patrol April 1989.

Health, Heat, and Water Hazards Associated with Illegal Drug Manufacturing
(Amphetamine, Methaqualone, Phencyclidine, and Methamphetamine).
California Health and Welfare Agency, Emergency Services Authority. March
1991.

Guidelines for Contamination Reduction and Sampling at Illegal Drug
Manufacturing Sites. Washington State Department of Health, Office of Toxic
Substances. June 1996.

Model Local Health Department/District Response to Illegal Drug Labs.
Washington State Department of Health, Office of Toxic Substances. July
1996.

Model Local Fire Department and Hazardous Materials Team Response to
Illegal Methamphetamine Drug Labs. Washington State Department of Health.
January 1990.

Training Programs

1. The following training programs were developed with funding support from
the Bureau of Justice Assistance and are available from Circle Solutions, Inc.,
2070 Chain Bridge Road, Suite 450, Vienna, VA 22182. For more
information, contact Michael McCampbell, Clandestine Laboratory Model
Enforcement Program, 703-902-1225.

o Introduction to Comprehensive Clandestine Laboratory Enforcement. This
1-day training program prepares State and local law enforcement agencies to
address specialized problems associated with clandestine drug laboratory
enforcement. Through a series of lectures and case studies, course participants
will learn to recognize the signs of a clandestine laboratory and apply
investigative techniques to successfully apprehend lab operators. Participants
will also learn to plan for the unique hazards of a clandestine laboratory when
executing a raid. Most importantly, participants will be provided with critical
information that may prevent them from being injured at a clandestine
laboratory.

o Managing a Clandestine Laboratory Enforcement Program. This day program
prepares supervisors and managers in State and local law enforcement agencies
to address the specialized problems associated with clandestine laboratory
enforcement. Course participants will learn about the dangers of clandestine
laboratories and associated risks to investigative personnel. From an
understanding of these risks, course participants will become aware of the
importance of a coordinated, multiagency approach to enforcement. In
addition, participants will learn the components necessary for a comprehensive
enforcement program.

o Clandestine Laboratory and Methamphetamine Trafficking Investigations.
This 5-day workshop prepares investigators in State and local law
enforcement agencies to apply the specialized techniques required to conduct
an effective clandestine laboratory investigation. Through a series of lectures
and case studies, course participants will learn how to recognize and react to
hazards, develop cases, conduct a comprehensive investigation, and develop a
complete raid plan.

o Strategic Planning for Clandestine Laboratory Enforcement. This 2-day
course is designed primarily for upper level management and policymaking
personnel from State and local public safety, health, and environmental
agencies. It will assist these personnel to develop a strategic plan for a
multiagency approach for organizing, coordinating, and managing their
clandestine laboratory response programs. In addition, participants will be
provided with detailed information on the components of an effective
enforcement program, including implementation steps and long-term cleanup
requirements. 

2. The following training programs are available from the California Specialized
Training Institute (CSTI), which is a component of the Governor's Office of
Emergency Services. For more information, contact the Registrar, CSTI, P.O.
Box 8123, San Luis Obispo, CA 93403, 805-549-3344.

o Clandestine Drug Laboratory Waste Operations (CLANWOPER).This
5-day course was developed jointly by CSTI and the California Department of
Toxic Substances Control. It provides practical, hands-on health and safety
training for emergency response to, or managing the cleanup of, clandestine
drug laboratory sites and hazardous waste.

o Clandestine Drug Laboratory Chemical Identification. This 4-day course
was developed jointly by CSTI and the California Department of Toxic
Substances Control. It focuses on the field identification of hazardous material
associated with, and hazardous waste generated in, clandestine drug synthesis.
The course is specifically for those persons responding to, or managing the
cleanup of, clandestine drug laboratories and their hazardous wastes.

3. For more information on the Portland, Oregon Police Bureau's Landlord
Training Program and the booklet, Clandestine Drug Labs-What Every Hotel
and Motel Owner Should Know, contact John Campbell, Campbell-Delong
Resources, Inc., Portland, Oregon, 503-221-2005.

BJA Contact

The Bureau of Justice Assistance provides grant support and program planning
assistance in support of State clandestine laboratory enforcement programs.
For additional information, contact the U.S. Department of Justice, Bureau of
Justice Assistance, Law Enforcement Branch, 810 Seventh Street NW.,
Washington, DC 20531, 202-616-3211. 

Bureau of Justice Assistance Information

General Information

Callers may contact the U.S. Department of Justice Response Center for
general information or specific needs, such as assistance in submitting grant
applications and information on training. To contact the Response Center, call
1-800-421-6770 or write to 1100 Vermont Avenue NW., Washington, DC
20005.

Indepth Information

For more indepth information about BJA, its programs, and its funding
opportunities, requesters can call the BJA Clearinghouse. The BJA
Clearinghouse, a component of the National Criminal Justice Reference Service
(NCJRS), shares BJA program information with state and local agencies and
community groups across the country. Information specialists are available to
provide reference and referral services, publication distribution, participation
and support conferences, and other networking and outreach activities. The
Clearinghouse can be reached by

o Mail
P.O. Box 6000
Rockville, MD 20849-6000

o Visit
2277 Research Boulevard
Rockville, MD 20850

o Telephone
1-800-688-4252
Monday through Friday 8:30 a.m. to 7 p.m. eastern time

o Fax
301-519-5212                            

o Fax on Demand
1-800-688-4252

o BJA Home Page
www.ojp.usdoj.gov/BJA

o NCJRS World Wide Web
www.ncjrs.org

o E-mail
askncjrs@ncjrs.org

o JUSTINFO Newsletter
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