DRUG CONTROL

State Approaches 

Taken to Control 

Access to Key 

Methamphetamine 

Ingredient Show 

Varied Impact on 

Domestic Drug Labs

Report to Congressional Requesters

January 2013 

GAO-13-204 

United States Government Accountability Office

GAO 
United States Government Accountability Office

Highlights of GAO-13-204, a report to 

congressional requesters

January 2013

DRUG CONTROL

State Approaches Taken to Control Access to Key 

Methamphetamine Ingredient Show Varied Impact 

on Domestic Drug Labs

Why GAO Did This Study

Meth can be made by anyone using 

easily obtainable household goods and 

consumer products in labs, posing

significant public safety and health 

risks and financial burdens to local 

communities and states where the labs

are found. Meth cooks have 

discovered new, easier ways to make 

more potent meth that require the use 

of precursor chemicals such as PSE. 

Some states have implemented 

electronic tracking systems that can be 

used to track PSE sales and determine 

if individuals comply with legal PSE 

purchase limits. Two states, along with 

select localities in another state, have 

made products containing PSE 

available to consumers by prescription 

only. GAO was asked to review issues 

related to meth. Thus, GAO examined, 

among other things, (1) the trends in 

domestic meth lab incidents over the 

last decade; (2) the impact of 

electronic tracking systems on meth 

lab incidents and limitations of this 

approach, if any; and (3) the impact of 

prescription-only laws on meth lab 

incidents and any implications of 

adopting this approach for consumers 

and the health care system. GAO 

analyzed data such as data on meth 

lab incidents and PSE product sales

and prescriptions. GAO also reviewed 

studies and drug threat assessments 

and interviewed state and local officials 

from six states that had implemented

these approaches. These states were 

selected on the basis of the type of 

approach chosen, length of time the 

approach had been in use, and the 

number of meth lab incidents. The 

observations from these states are not 

generalizable, but provided insights on

how the approaches worked in 

practice. 

What GAO Found

Methamphetamine (meth) lab incidents—seizures of labs, dumpsites, chemicals,

and glassware—declined following state and federal sales restrictions on 

pseudoephedrine (PSE), an ingredient commonly found in over-the-counter cold 

and allergy medications, but they rose again after changes to methods in 

acquiring PSE and in the methods to produce meth. According to Drug 

Enforcement Administration (DEA) data, the number of lab incidents nationwide 

declined through 2007 after the implementation of state and federal regulations 

on PSE product sales, which started in 2004. The number of meth lab incidents 

reported nationally increased after 2007, a trend primarily attributed to (1) the 

emergence of a new technique for smaller-scale production and (2) a new 

method called smurfing--a technique used to obtain large quantities of PSE by 

recruiting groups of individuals to purchase the legally allowable amount of PSE 

products at multiple stores that are then aggregated for meth production.

Meth Lab Incidents Nationwide, 2002 through 2010

Electronic tracking systems help enforce PSE sales limits, but they have not 

reduced meth lab incidents and have limitations related to smurfing. By 

electronically automating and linking log-book information on PSE sales, these

systems can block individuals from purchasing more than allowed by law. In 

addition, electronic tracking systems can help law enforcement investigate 

potential PSE diversion, find meth labs, and prosecute individuals. However, 

meth cooks have been able to limit the effectiveness of such systems as a 

means to reduce diversion through the practice of smurfing. 

The prescription-only approach for PSE appears to have contributed to 

reductions in lab incidents with unclear impacts on consumers and limited 

impacts on the health care system. The implementation of prescription-only laws 

by Oregon and Mississippi was followed by declines in lab incidents. Law 

enforcement officials in Oregon and Mississippi attribute this reduction in large 

part to the prescription-only approach. Prescription-only status appears to have 

reduced overall demand for PSE products, but overall welfare impacts on 

consumers are unclear because of the lack of data, such as the cost of obtaining 

prescriptions. On the basis of the limited information available from health care 

providers in Oregon and Mississippi, there has not been a substantial increase in 

workload demands to provide and dispense prescriptions for PSE products. 

View GAO-13-204. For more information, 

contact Carol Cha at (202) 512-4456 or 

chac@gao.gov.
Page i GAO-13-204 Domestic Meth Labs 

Letter 1 

Background 6

Meth Lab Incidents Rose after a Sharp Decline and Have WideRanging Impacts on Communities 11

Electronic Tracking Systems Help Enforce PSE Sales Limits but 

Have Not Reduced Domestic Meth Lab Incidents 23

Prescription-Only Appears to Help Reduce Lab Incidents; Full 

Impact on Consumers Is Unknown and May Be Limited on 

Health Care System 29

Agency Comments 44

Appendix I Objectives, Scope, and Methodology 45

Appendix II State Level Data on Meth Lab Incidents, 2002 through 2011 52

Appendix III Statistical Model Analysis of the Prescription-Only 

Requirement on Meth-lab Incidents 54

Appendix IV GAO Contact and Staff Acknowledgments 64

Tables

Table 1: PSE Sales and Blocks for NPLEx States, 2011 through 2012 24

Table 2: Number of Lab Incidents for States That Have Used 

Electronic Tracking the Longest, 2002-2011 26

Table 3: Units of PSE Products Sold OTC or Prescribed in 

Mississippi, January 2009-December 2011 37

Table 4: Sales of OTC PE Products in Mississippi, January 2009-

December 2011 39

Table 5: Methamphetamine PSE Restriction Policy Impact on Lab 

Seizure Rates per 100,000 Population Estimated from 

Difference-in- Difference 62

Contents 
Page ii GAO-13-204 Domestic Meth Labs 

Figures

Figure 1: Conversion of PSE to Meth 7

Figure 2: Adoption of Electronic Tracking and Prescription-only 

Approaches, by State 10

Figure 3: Meth Lab Incidents Nationwide, 2002 through 2010 12

Figure 4: Regional distribution of Meth Lab Incidents, January 2002 

through 2010 14

Figure 5: Meth Lab Incidents, 2002 through 2011 15

Figure 6: DEA Funds Spent on the Lab Cleanup Program, Calendar 

Years 2002 through 2010 21

Figure 7: Reported Meth Lab Incidents in Oregon and Mississippi, 

2002 through 2011 30
Page iii GAO-13-204 Domestic Meth Labs 

Abbreviations

CHPA Consumer Healthcare Products Association

CMEA Combat Methamphetamine Epidemic Act of 2005

DD Difference-in-Differences

DEA Drug Enforcement Administration

DOJ Department of Justice

EPIC El Paso Intelligence Center 

ETS electronic tracking system

FDA Food and Drug Administration

GEE generalized estimating equation

HIDTA High Intensity Drug Trafficking Area

ID identification

LEOKA Law Enforcement Officers Killed in Action

MDMA Ecstasy (drug)

NDIC National Drug Intelligence Center

NMPI National Methamphetamine & Pharmaceuticals Initiative

NPLEx National Precursor Log Exchange

N-SSATS National Survey of Substance Abuse Treatment Services

NSS National Seizure System

ONDCP Office of National Drug Control Policy

OTC over-the-counter

PDMP prescription drug monitoring program

PE phenylephrine

PSE pseudoephedrine

QIC quasi-likelihood indicator criteria

TEDS Treatment Episode Data Set

UCR Uniform Crime Report

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-204 Domestic Meth Labs 

United States Government Accountability Office

Washington, DC 20548

January 31, 2013

The Honorable Dianne Feinstein 

Chairman

The Honorable Charles Grassley

Co-Chairman

Caucus on International Narcotics Control 

United States Senate

Methamphetamine (meth) is a powerful, highly addictive stimulant drug 

that has limited medical uses.1 Today, meth can be made by anyone 

using easily obtainable household goods and consumer products. 

According to the Drug Enforcement Administration (DEA) and the Office 

of National Drug Control Policy (ONDCP), illicit meth used in the United 

States today is manufactured by Mexican drug-trafficking organizations in 

“super labs” located in Mexico and California, as well as by cooks in 

“small toxic labs” predominately located in the central United States, from 

the Gulf of Mexico to the Great Lakes and from the plains to the 

Appalachian Mountains.2

In the wake of an increased law enforcement focus on illicit meth labs in 

the 1980s, meth manufacturing methods changed. Meth cooks 

These labs pose significant public safety and 

health risks and financial burdens to local communities and states where 

they are found. The toxic chemicals and solvents involved in meth 

manufacturing can result in fiery explosions and expose property and 

people, including children, to contaminates that are dangerous and costly 

to remove.

 

1

Medical and psychological effects of meth abuse can include aggression, memory loss, 

heart damage, hyperthermia, and psychotic behavior. While legitimately manufactured 

meth can be used to treat such medical conditions as narcolepsy, attention deficit 

disorder, obesity, and depression, alternative drugs are more frequently used for 

treatment of these conditions.

2

Illicit meth can be manufactured in various forms and can be smoked, snorted, injected, 

and taken orally. Super labs are capable of producing over 10 pounds of meth in a 24-

hour period. According to estimates by DEA’s Office of Diversion Control, meth produced 

by Mexican drug-trafficking organizations makes up approximately 80 percent of the illicit 

meth consumed in the United States. Small toxic labs produce less than 2 ounces (56 

grams) of finished product. Most labs found in the United States are small toxic labs.

 
 

Page 2 GAO-13-204 Domestic Meth Labs 

discovered new, easier ways to make more potent meth that required the 

use of precursor chemicals such as pseudoephedrine (PSE), a nasal 

decongestant commonly found in over-the-counter (OTC) cold and allergy 

medications. PSE is the primary essential ingredient used to make meth 

in the United States today.3 Initial federal efforts to address a growing 

meth problem primarily focused on increased meth-trafficking penalties 

and regulating the bulk importation, exportation, and distribution of meth 

precursor chemicals such as PSE. However, by 2004, the annual number 

of meth lab incidents reported by law enforcement had reached an alltime high of over 24,000.4 In response, many states began taking steps to 

further regulate PSE at the point of sale, such as requiring customers to 

present photo identification (ID) when purchasing PSE products and 

pharmacists to keep PSE products behind the counter and maintain a log 

of all sales. In 2006, the Combat Methamphetamine Epidemic Act of 2005 

(CMEA) was passed to, among other things, regulate the retail sale of 

OTC PSE products by setting daily and monthly sales limits for customer 

purchases and requiring sellers to keep these products behind the 

counter and maintain a written or electronic sales logbook.5

Recognizing the serious public safety and health risks and financial 

burdens of these labs, state and local governments and Congress have 

since taken or considered taking further action to help prevent PSE 

diversion to make illicit meth. For example, some states have 

implemented electronic tracking systems that can be used to track PSE 

sales and determine if individuals comply with legal PSE purchase limits. 

Two states, along with select localities in another state, have made 

products containing PSE available to consumers by prescription only.6

 

3

Ephedrine can be used as a substitute for PSE when making methamphetamine.

In 

addition, since 2010, at least 69 bills have been introduced in 18 states 

that would require consumers to obtain a prescription to purchase PSE 

4

Meth lab incidents include seizures of labs, dump sites, chemicals, and glassware. Law 

enforcement agencies report meth lab incidents to the National Seizure System (NSS) 

maintained by DEA’s El Paso Intelligence Center (EPIC). EPIC monitors and tracks all 

meth-related information nationally and internationally that is reported to the NSS. 

5

Pub. L. No. 109-177, 120 Stat. 256 (2006). The CMEA also placed restrictions on the 

precursor chemicals ephedrine and phenylpropanolamine. At the time, the industry had 

removed these drugs from the market for safety reasons.

6

Oregon, Mississippi, and select Missouri cities and counties have passed laws or 

ordinances requiring individuals to obtain a prescription from a health care provider in

order to purchase PSE products.
 

Page 3 GAO-13-204 Domestic Meth Labs 

products. In this context, you requested that we provide information on 

domestic meth lab incident trends and the impacts these two approaches 

have had on the domestic meth lab problem. Accordingly, this report 

addresses

• the trends in domestic meth lab incidents over the last decade and the 

impact of domestic meth labs on the communities affected by them;

• the impact of electronic tracking systems on domestic meth lab 

incidents and the limitations, if any, of using these systems; and

• the impact of prescription-only laws on domestic meth lab incidents 

and any implications of this approach for consumers and the health 

care system.

To identify trends in domestic meth lab incidents over the last decade, we 

analyzed data for all states from DEA’s National Seizure System on lab 

seizure incidents that occurred during the last 10 complete calendar 

years, 2002 through 2011.7 Using these data, we analyzed the number of 

incidents nationally, by region, and by type of lab and lab capacity. To 

assess the reliability of these data, we discussed the data with agency 

officials and compared them with other data and documentation, where 

available, from states we selected as case studies for this review. We 

selected this non-probability sample of states to reflect a mix of 

characteristics, such as the type of approach chosen for controlling the 

sale of PSE products (electronic tracking or prescription-only), length of 

time the approach has been in use, and the number of meth labs seized 

relative to the state’s population size.8

 

7

According to DEA officials, records of incidents can be updated within the NSS or new 

records added as new data and information becomes available or is submitted. 

Consequently, the number of total number of incidents may vary over time. The data 

analyzed for this review were pulled from the NSS on October 1, 2012. 

We worked with DEA to resolve 

any data discrepancies and determined that the data were sufficiently 

reliable for the purposes of this report. We also interviewed federal 

officials, as well as state and local officials in the 6 case study states 

about meth lab trends. While we cannot generalize any findings or results 

8

The states we selected as case study states included the electronic tracking states of 

Iowa, Kentucky, Missouri, and Tennessee, and the prescription-only states of Mississippi

and Oregon. Select Missouri cities and counties have passed laws or ordinances requiring 

individuals to obtain a prescription from a health care provider in order to purchase PSE 

products. 
 

Page 4 GAO-13-204 Domestic Meth Labs 

to the national level from this sample, this information provided 

perspectives on the factors affecting meth lab trends. We also reviewed 

drug threat assessments and reports by the National Drug Intelligence 

Center (NDIC) and information from DEA and ONDCP officials. We 

reviewed the methodology of the assessments and reports and found 

them sufficiently reliable for our purposes. To determine the impact of 

domestic meth lab incidents on the communities affected by them, we 

reviewed documentation from the Department of Justice (DOJ), data and 

documentation from DEA, a report from the DOJ Inspector General on 

DEA’s meth lab cleanup program, reports from the RAND Corporation, 

and information from various state and local officials from our case study 

states.

To determine the impact of electronic tracking systems on domestic meth 

lab incidents, we analyzed DEA data from 2002 through 2011 on the 

number of meth lab incidents that were reported in the 3 states that have 

implemented electronic tracking the longest—Kentucky, Oklahoma, and 

Tennessee. We also reviewed PSE purchase activity data for 2011 and 

2012 from Appriss, the firm that developed and manages the software 

program MethCheck, which is used as the operational platform for the 

National Precursor Log Exchange (NPLEx), the interstate electronic 

tracking system paid for by manufacturers of PSE products. We chose 

this time period because 2011 and 2012 were the most recent years for

which data from multiple states were available. In addition, we obtained 

information from officials with Appriss as well as officials with state and 

local law enforcement in the 4 electronic tracking case study states. 

Although the perspectives of these state and local officials cannot be 

generalized across the broader population of state and local law 

enforcement agencies in electronic tracking states, their perspectives 

provided insights into and information on the use and impact of the 

approach in practice and its limitations.

To determine the impact of prescription-only laws on domestic meth lab 

incidents and any implications of adopting this approach for consumers 

and the health care system, we analyzed DEA data on meth lab incidents 

from Mississippi and Oregon and their border states from 2002 through 

2011.9

 

9

These border states included Alabama, Arkansas, California, Idaho, Louisiana, Nevada, 

Tennessee, and Washington. 

We also conducted a statistical modeling analysis of Oregon lab 
 

Page 5 GAO-13-204 Domestic Meth Labs 

incident data but could not conduct a similar analysis for Mississippi 

because sufficient data were not yet available. We interviewed state and 

local officials in prescription-only states about the impact of these laws on 

lab incidents, and although their perspectives cannot be generalized 

across states, they provided insight for this report. We also reviewed PSE 

purchase data from neighboring states. For Mississippi specifically, we 

obtained data from IMS Health Inc. through DEA on the volume of PSE 

and phenylephrine sales for the period when the prescription-only 

approach was in effect for part of the year to the 2009 period, when it was 

not.10 We also obtained and reviewed data provided by the Mississippi 

Board of Pharmacy’s Prescription Drug Monitoring Program (PDMP) to 

assess the impact on consumers. We also reviewed a report prepared for 

the Consumer Healthcare Products Association (CHPA) and interviewed 

the state boards of pharmacy and state associations representing 

pharmacists in Mississippi and Oregon and the National Consumers 

League and the Asthma and Allergy Foundation of America.11

We conducted this performance audit from February 2012 to January 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

We 

selected these organizations because they have previously surveyed 

consumers about access to PSE products. In addition, we interviewed 

state associations representing physicians practicing in Oregon and 

Mississippi and Medicaid program officials in Mississippi and Oregon. 

While their perspectives cannot be generalized to the larger population of 

physicians in these states, they provided insights into the impact of the 

approach on their members’ practices. We assessed the reliability of data 

received from the NPLEx system, IMSHealth Inc., and the Mississippi 

PDMP by interviewing knowledgeable officials and reviewing relevant 

documentation, and we determined that these data were sufficiently 

reliable for the purposes of this report.

 

10IMSHealth Inc. is a provider of consulting and analytical information and services for the 

health care industry.

11CHPA is a trade association that represents U.S. manufacturers of nonprescription 

medications.
 

Page 6 GAO-13-204 Domestic Meth Labs 

Additional details on our scope and methodology are contained in 

appendix I.

Meth is relatively easy and cheap to make today by individuals with little 

knowledge of chemistry or laboratory skills or equipment. PSE, an 

ingredient used in OTC and prescription cold and allergy medications, is 

the key substance needed to make the dextrorotatory methamphetamine 

(d-meth) illicitly produced in most domestic meth labs today. The 

difference between a PSE molecule and a d-meth molecule is a single 

oxygen atom. Meth cooks make d-meth by using common household 

products to remove this oxygen atom to produce meth as shown in 

figure 1.

Background 

PSE—an Essential 

Ingredient for Making 

Meth
 

Page 7 GAO-13-204 Domestic Meth Labs 

Figure 1: Conversion of PSE to Meth

Meth cooks have used two primary processes known as the Nazi/Birch 

and Red P methods to make d-meth.12

 

12The Birch reduction method-also known as the Nazi method-uses ephedrine or 

pseudoephedrine, anhydrous ammonia, and sodium or lithium metal and requires less 

than 1 hour to produce methamphetamine that is about 95 percent pure. The Red 

Phosphorus method-also known as the Red P method- uses ephedrine or 

pseudoephedrine, iodine or hydriodic acid, and red phosphorus and takes over 3 hours to 

produce methamphetamine that is approximately 90 percent pure.

In recent years, meth cooks have 

developed a variation of the Nazi/Birch method known as the One Pot or 

Shake and Bake method that produces meth in one step where 

ingredients are mixed together in a container such as a 2-liter plastic 

bottle. Another process for making meth is known as the P-2-P method, 

which produces a less potent form of meth known as racemic or dl-
 

Page 8 GAO-13-204 Domestic Meth Labs 

meth.13 It does not require PSE as a precursor chemical and is typically 

half as potent as the d-meth made with PSE.

Initial federal efforts to address a growing meth lab and abuse problem 

primarily focused on increasing meth-trafficking penalties and regulating 

the bulk importation, exportation, and distribution of meth precursor 

chemicals such as PSE. In 2004, Oklahoma was the first state to pass a 

law to control the retail sale of PSE products by requiring customers to 

present photo IDs and pharmacists to keep the product behind the 

counter and log all sales. By November 2005, over 30 other states had 

passed laws related to the control of the retail sale of PSE products. In 

2006, the CMEA was enacted, which included measures designed to 

control the availability of meth precursor chemicals such as PSE by 

regulating the retail sale of OTC products containing these chemicals.14

The CMEA placed restrictions on the sale of these products, including (1) 

requiring these products to be kept behind the counter or in a locked 

cabinet where customers do not have direct access; (2) setting a daily 

sales limit of 3.6 grams and a monthly purchase limit of 9 grams per 

customer regardless of the number of transactions; and (3) requiring 

sellers to maintain a logbook, written or electronic, to record sales of 

these products and verify the identity of purchasers.15 The CMEA does 

not prohibit states from taking actions to establish stricter sales limits or 

further regulate the sale of PSE products.16

 

13This method involves the synthesis of methylamine and phenylacetone also known as 1-

phenyl-2- propanone or P-2-P. Motorcycle gangs used this method to manufacture meth 

in the 1960s and 1970s.

14The CMEA was enacted in the USA PATRIOT Improvement and Reauthorization Act of 

2005, Pub. L. No. 109-177, 120 Stat. 192 (March 9, 2006). The CMEA also set limits on 

imports of meth precursor chemicals, increased penalties for meth production and 

trafficking, and required the Department of State to work with Mexico to help prevent the 

smuggling of illicit meth across the U.S.-Mexico border. 

15Sellers must enter the name of the product and quantity sold into the logbook. 

Customers must write or enter into the logbook their name, address, date, and time of sale

and also sign the logbook. Sellers must verify that the customer’s name matches the 

name written in the logbook by that individual and that the date and time of sale are 

correct. 

16For example, Alaska, Iowa, Indiana, Minnesota, and Wisconsin have implemented lower 

monthly sales limits than the 9-gram limit established by the CMEA.

Federal and State PSE 

Sales Restrictions
 

Page 9 GAO-13-204 Domestic Meth Labs 

Since the passage of the CMEA, some states have implemented 

electronic systems to track sales of products containing PSE. Through 

these systems, retailers report sales of PSE products to a centralized 

database that can be used to determine whether individuals are 

exceeding the purchase limitations of the CMEA or state laws. Reported 

information typically includes the date and grams purchased, as well as 

the name, address, and other identifying information of the purchaser. 

Most tracking systems are stop sale systems that would query the 

database, notify the retailer whether the pending sale would violate 

federal or state purchase limitations, and deny sales where limits have 

already been reached.17 As of December 2012, 19 states were using stop 

sale tracking systems. Seventeen of these states were using a system 

called the NPLEx that is endorsed and funded by PSE manufacturers 

through CHPA.18

Some states and localities have taken additional steps to regulate PSE 

sales. Oregon, Mississippi, and 63 Missouri cities or counties have 

passed laws or ordinances requiring individuals to obtain a prescription 

from a health care provider in order to purchase PSE products. While a 

prescription is required, an in-person encounter with a health care 

provider may not be necessary to obtain the prescription. There is no set 

limit to how much PSE can be prescribed. Both Oregon and Mississippi 

require that prescriptions for PSE products be entered into the states’ 

prescription drug monitoring program, a program that allows for 

pharmacists and prescribers to electronically look up how much PSE 

product has been prescribed to a patient. Figure 2 shows the states with 

prescription-only laws and ordinances and electronic tracking systems, 

including the dates these systems were implemented.

Two states were using systems developed in-house or 

by another vendor.

 

17These systems generally allow retailers to override a stop sale alert if certain conditions 

are met (i.e., under a threat of violence). Such sales are known as exceedances.

18The National Association of Drug Diversion Investigators distributes the NPLEx system 

to participating states that pass a law requiring that all sales of PSE be tracked 

electronically in real time and illegal transactions be denied. 

Electronic Meth Precursor 

Tracking Systems and 

Prescription-Only Laws 

and Ordinances
 

Page 10 GAO-13-204 Domestic Meth Labs 

Figure 2: Adoption of Electronic Tracking and Prescription-only Approaches, by State

Note: Analysis as of December 2012. An additional 7 states were scheduled to begin using NPLEx on

01/01/13.
 

Page 11 GAO-13-204 Domestic Meth Labs 

According to DEA data on meth lab incidents, after peaking in 2004, the 

number of lab incidents nationwide declined through 2007 after the 

implementation of state and federal regulations on PSE product sales. As 

shown in figure 3, the number of lab incidents peaked in 2004, with states 

reporting over 24,000 lab incidents nationally. However, beginning in 

2005, the number of incidents began to decline sharply and reached a 

low of about 7,000 incidents in 2007. While there may be multiple factors 

at work that resulted in this decline such as region-specific factors, 

federal, state, and local law enforcement officials attribute the primary 

cause of the decline to the restrictions on purchases of PSE products 

imposed at both the federal and state levels from 2004 through 2006. The 

impact of these restrictions was to reduce the accessibility of PSE for use 

in illicit meth labs, which in turn resulted in fewer labs during this period.

Meth Lab Incidents 

Rose after a Sharp 

Decline and Have 

Wide-Ranging Impacts 

on Communities

Meth Lab Incidents 

Declined Sharply 

Following Implementation 

of State and Federal PSE 

Sales Restrictions
 

Page 12 GAO-13-204 Domestic Meth Labs 

Figure 3: Meth Lab Incidents Nationwide, 2002 through 2010

Note: In 2011, law enforcement reported 13,530 lab incidents to DEA’s National Seizure System 

(NSS). Law enforcement officials are required only to report incidents to the NSS in cases where DEA 

funds are used for cleanup. From February 2011, to September 2011, there were no DEA funds 

available for cleanup. Consequently, it is likely that the number of 2011 lab incidents was 

underreported.

After reaching a low in 2007, the number of meth lab incidents reported 

nationally increased over the next few years. National trends show that 

meth lab incidents have increased since 2007, reaching more than 

15,000 at the end of 2010 –more than double the number of reported 

incidents for 2007. Federal, state, and local law enforcement officials 

attribute this rising trend primarily to two factors:

• The emergence of a new technique for smaller-scale production.

A production method popularly called the One Pot method, which 

simplified the entire meth production process down to a single 2 liter 

plastic bottle and enhanced the ability of individuals to make their own 

meth, began to emerge in 2007. With this method, meth addicts are 

capable of manufacturing their own meth quicker and with less PSE, 

chemicals, and equipment than required by traditional methmanufacturing methods, although this method also produces less 

Meth Lab Incidents Rose 

Following the Emergence 

of the One Pot Production 

Method and Smurfing
 

Page 13 GAO-13-204 Domestic Meth Labs 

meth than the traditional manufacturing methods. According to DEA 

data, more than 87 percent (43,726) of the labs seized with a capacity 

reported from 2008 through 2011 have been smaller capacity (less 

than 2 ounce) labs and about 74 percent (39,049) used the Nazi/Birch 

manufacturing process, of which the One Pot method is a variation. 

Less than 0.5 percent (219) of the labs seized during this period were 

super labs (labs producing 10 pounds or more of meth per batch), 

less than 13 percent (6,473) used the Red P method, and only 0.05 

percent (26) of the labs seized during this period used the P-2-P 

method, which does not require PSE as a precursor chemical.19

• Use of a method for meth producers to circumvent PSE sales 

restrictions. Another key factor federal, state, and local officials 

attribute to the increase in meth labs in recent years is the use of a 

method known as smurfing to work around PSE sales restrictions. 

Smurfing—which is discussed in greater detail later in this report—

essentially involves the coordinated effort by individuals or groups of 

individuals to purchase the maximum per person legal allowable 

amount of PSE products and then aggregate their purchases for the 

use in meth production or for sale to a meth producer. Federal, state, 

and local officials stated that consequently, using this technique, meth 

producers have been able to obtain the PSE product they need to 

make meth despite the federal and state sales restrictions. This, in 

turn, has led to the proliferation of more labs.

Further examination of data trends at the regional level reveals that the 

number of meth lab incidents varies greatly among regions of the country. 

Specifically, while the number of meth lab incidents continues to be low in 

the Northeast and declines in the number of meth labs incidents have 

been maintained in the West since PSE sales restrictions went into place, 

the South and Midwest regions have experienced significant increases 

overall in the number of incidents since 2007. Further, the South and 

Midwest have also had more lab incidents than the West and Northeast 

since 2003 (see fig.4). In general, these trends are consistent across all 

categories of lab types and capacities, except for incidents involving the 

P-2-P labs and labs of larger capacities (10 pounds or greater), for which 

the West tended to report higher numbers of incidents overall. 

 

19This analysis excluded incident reports that did not include information on lab capacity 

or type. 

South and Midwest 

Regions Have Significantly 

Increased Meth Lab 

Incidents Overall as 

Compared with Other 

Regions 
 

Page 14 GAO-13-204 Domestic Meth Labs 

Figure 4: Regional distribution of Meth Lab Incidents, January 2002 through 2010

Notes:

Data was accessed on October 1, 2012.

Figure 5 shows lab incidents by state for the last decade (see app. II for 

this information by state).
Page 15 GAO-13-204 Domestic Meth Labs

Source: GAO analysis of meth lab incident data from DEA’s National Seizure System, data accessed on October 1, 2012; 

Map Resources (map).

Fla.

La.

Miss. Ala. Ga.

S.C. Ark.

Tex.

N.C.

Tenn.

N.Mex.

Ariz. Okla.

Ky.

Va.

Md.

Del.

Kans. Mo.

W.Va. Colo.

N.J.

Ind. Ohio Nev.

Utah

Calif.

R.I.

Conn. Pa.

Ill.

Mass.

Nebr.

Iowa

Wyo.

N.Y.

Vt.

N.H.

Mich.

S.Dak.

Ore.

Wis.

Maine N.Dak.

Idaho

Mont.

Wash.

Minn.

D.C.

Hawaii

Alaska

Interactive graphic Figure 5: Meth Lab Incidents by State, 2002 through 2011

Move mouse over state names for meth lab incidents.
 

Page 16 GAO-13-204 Domestic Meth Labs 

Meth labs can have a significant impact on a community’s health care 

system when labs catch on fire or explode, causing serious injuries and 

burns to meth cooks and other individuals that require costly medical 

treatment. Mixing chemicals in meth labs creates substantial risks of 

explosions, fires, chemical burns, and toxic fume inhalation. These burns 

and related injuries resulting from these events can be more serious than 

burns and injuries sustained through non-meth-lab-related causes. For 

example, a 2008 study conducted of meth and non-meth burn patients 

that received treatment in one hospital burn unit in Kalamazoo, Michigan, 

from 2001 through 2005, found that meth lab patients tended to have 

more frequent inhalation injuries, needed greater initial fluid resuscitation 

volume, required intubation more frequently, and were more likely to have 

complications than non-meth patients.20

The treatment for meth lab-related burns and injuries can be very 

expensive. According to one provider, treatment costs for two meth lab 

The small size of the relatively 

new One Pot or Shake and Bake method can be even more dangerous 

than larger meth labs, as drugmakers typically hold the One Pot container 

up close, increasing the risk for severe burns from the waist to the face. 

According to the director of the Vanderbilt University Regional Burn 

Center in Tennessee, meth lab injuries can also be more severe than 

burns resulting from just fires alone because patients often suffer thermal 

burns from the explosion, as well as chemical burns from exposure to 

caustic chemicals. He also noted that meth lab burn patients tend to be 

more difficult to treat because their addiction and overall poor physical 

health make it difficult for them to facilitate their own recovery as well as 

the fact that most attempt to hide the cause of their injury, which can 

hinder the administration of proper care.

 

20Paul A. Blostein; Brian R. Plaisier, MD; Sheldon R. Maltz, MD; Scott B. Davidson, MD; 

Eric W. Wideman, DO; Eric C. Feucht, MD; and Sheri L. VandenBerg, RN. 

“Methamphetamine Production is Hazardous to Your Health,” Journal of Trauma, Injury, 

Infection, and Critical Care, vol. 66, no.6, (2009).

Domestic Meth Labs 

Impact Communities in 

Matters Related to Health 

Care, Child Welfare, Law 

Enforcement Resources, 

and the Environment

Impacts on Health Care 
 

Page 17 GAO-13-204 Domestic Meth Labs 

burn patients exceeded $2 million per patient. Although accurate 

estimates of the proportion of burn victims that received their burns from a 

meth lab are difficult21

Children who live at or visit locations or residences with meth labs or are 

present during drug production face acute risks to their health and safety. 

According to data from DEA’s National Seizure System, over 21,000 

children were reported affected by meth labs from 2002 through 2011.

, one estimate placed the percentage of meth lab 

burn patients at 25 to 35 percent of total burn patients. Of those patients 

that are identified as receiving their injuries from meth labs, many are 

found either not to have health insurance or have publicly funded 

insurance such as Medicaid. For example, the 2008 Kalamazoo study 

also found that significantly fewer meth burn patients had private 

insurance, while more were on Medicaid or had no insurance as 

compared with non-meth burn patients.

22

 

21According to the director of the Vanderbilt University Regional Burn Center, on the basis 

of his experience, meth lab-related burn victims generally try to conceal the cause of their 

injuries and health providers are hesitant to determine whether the injuries were due to 

illicit meth production because many insurers will not pay for such care under those 

circumstances.

Physically, the age-related behaviors of young children (such as frequent 

hand-to-mouth contact and physical contact with their environment) 

increase the likelihood that they will inhale, absorb, or ingest toxic 

chemicals, drugs, or contaminated food that may be within their reach or 

in their environment. For example, in 2009 a 20-month-old boy in 

Kentucky died from chemical burns to his trachea and bronchial system 

and toxic ingestion after accidentally drinking some liquid drain cleaner 

left over by adults who made meth in the trailer he was living in. A child 

living at a home with a meth lab may also inhale toxic substances or the 

secondhand smoke of adults who are using meth, receive an accidental 

skin prick from discarded needles or other drug paraphernalia, or absorb 

methamphetamine and other toxic substances through the skin following 

contact with contaminated surfaces, clothing, or food. The physiological 

characteristics of children, such as higher metabolic and respiratory rates 

and a developing central nervous system, also leave them vulnerable to 

the other effects of toxic chemical exposures, which can cause cancer; 

22As part of reporting a lab seizure to the DEA’s NSS, law enforcement is required to 

report on the number of children affected by the lab, such as those living at the site as well 

as those that might have visited the site. 

Impacts on Children
 

Page 18 GAO-13-204 Domestic Meth Labs 

damage the brain, liver, kidney, spleen, and immunologic system; and 

result in birth defects.

In addition to the physical dangers, children in environments where meth 

is being made are also reported to be at risk to suffer abuse or neglect by 

their parents or other adults. Parents and caregivers who are meth 

dependent can become careless and often lose their capacity to take care 

of their children such as ensuring their children’s safety and providing 

essential food, dental and medical care, and appropriate sleeping 

conditions. Children living in households where meth labs are operated 

are also at increased risk for being physically and sexually abused by 

members of their own family or other individuals at the site.

To protect the children discovered at meth lab sites from further harm and 

neglect, social service agencies remove the children from their homes 

and place them in foster care. Foster care is a social welfare service that 

serves the needs of abused and neglected children. Child welfare 

workers can remove a child if it is determined that remaining with the 

parents will jeopardize a child’s welfare. Children are placed either with a 

surrogate foster family or in a residential treatment facility called a group 

home with the intent to provide temporary housing in a safe and stable 

environment until reunification with the child’s birth parents or legal 

guardians is possible. Reunification happens once the state is convinced 

that the harmful factors that triggered removal no longer exist. Several 

states and jurisdictions have created special protocols and programs to 

address the needs of children exposed to clandestine meth labs. These 

protocols and programs typically involve medical screening of the children 

for toxicity and malnourishment, emergency and long-term foster care, 

and psychological treatment. Social service agencies may also seek to 

enroll meth-involved parents and their children in a family-based 

treatment program, where both the parents and children receive services. 

Family-based treatment programs offer treatment for adults with 

substance use disorders and support services for their dependent

children in a supervised, safe environment that allows the family to 

remain together and prevents exposure to further harm. The costs to 

state department of human service agencies to provide services to these 

children can be significant depending on the number, age, and specific 

needs of the child. For example, from January 2006, through December 

2011, the Missouri Department of Social Services substantiated 702 

reports of children exposed to meth labs, involving a total of 1,279 

children. Of those 1,279 children, 653 required placement in departmental 

custody. The total cost of providing custodial care to children exposed to 

meth labs in Missouri since August 2005, was approximately $3.4 million 
 

Page 19 GAO-13-204 Domestic Meth Labs 

according to the department.23 In one Missouri county, so many children

were being removed from meth lab homes and placed in state custody 

that there are now no longer any foster families available to care for 

them.24 Similarly, according to the Tennessee Department of Children’s 

Services, 1,625 children were removed from meth lab homes from 

January 2007 through December 2011 and placed in foster care at a cost 

of approximately $70.1 million.25

The raw materials and waste of the meth labs pose environmental 

dangers because they are often disposed of indiscriminately by lab 

operators to avoid detection, and can also cause residual contamination 

of exposed surfaces of buildings and vehicles where the meth was being 

made. According to DEA, for every pound of meth produced, 5 to 6 

pounds of toxic waste are produced. Common practices by meth lab 

operators include dumping this waste into bathtubs, sinks, or toilets, or 

outside on surrounding grounds or along roads and creeks. Some may 

place the waste in household or commercial trash or store it on the 

property. In addition to dumped waste, toxic vapors from the chemicals 

used and the meth-making process can permeate walls and ceilings of a 

home or building or the interior of a vehicle, potentially exposing 

unsuspecting occupants. As a result, the labs potentially end up 

contaminating the interiors of dwellings and vehicles as well as water 

sources and soil around the lab site for years if not treated.

Because of the dangerous chemicals used in making meth, cleaning up 

clandestine methamphetamine labs is a complex and costly undertaking. 

According to regulations promulgated for the Resource Conservation and 

Recovery Act by the Environmental Protection Agency, the generator of 

hazardous waste is the person who produced or first caused the waste to 

be subject to regulation.26

 

23 According to information provided by Missouri officials, the average child remains in 

state care for 369 days at a cost of $18.35 per day. 

The act of seizing a meth lab causes any 

chemicals to be subject to regulation and thus makes law enforcement 

the “generator” of the waste when seizing a lab. Accordingly, seizing a lab 

24According to Division of Family Services officials, they now try to locate family members 

that are clean of addiction and crime who can care for these children. 

25Tennessee officials report that a child spends an average of 399.5 days in foster care, 

with an overall average cost of $108 dollars per day to the state. 

26Resource Conservation and Recovery Act of 1976, Pub. L. No. 94-580, 90 Stat. 2795. 

Impacts on the Environment
 

Page 20 GAO-13-204 Domestic Meth Labs 

makes a law enforcement agency responsible for cleaning up the 

hazardous materials and the costs associated with the cleanup. The 

materials seized at a clandestine drug laboratory site become waste 

when law enforcement officials make the determination of what to keep 

as evidence. Those items not required as evidence are considered 

hazardous waste and must be disposed of safely and appropriately. The 

task of removal and disposal of the hazardous waste is usually left to 

contractors who have specialized training and equipment to remove the 

waste from the lab site and transport it to an EPA-regulated disposal 

facility. Depending on the size of the lab, the cost for such a service to 

respond to an average lab incident can range from $2,500 to $10,000, or 

up to as much as $150,000 to clean up super labs, according to DOJ.

To help state and local agencies with the expense of lab cleanup, DEA 

established a lab cleanup program where DEA contracts with vendors 

and pays them to conduct the cleanup on behalf of the law enforcement 

agency seizing the lab.27 In fiscal year 1998, DEA began funding 

cleanups of clandestine drug labs that were seized by state and local law 

enforcement agencies, focusing on the removal and disposal of the 

chemicals, contaminated apparatus, and other equipment.28

 

27Some states, such as South Carolina, California, and Missouri, have established their 

own independent state-run cleanup programs. 

State and 

local law enforcement agencies seeking to utilize this service contact the 

DEA to coordinate the cleanup effort. According to DEA program officials, 

DEA has spent over $142 million on these cleanups nationwide since 

calendar year 2002. See figure 6.

28In 2004, 98 percent of the laboratories seized were producing meth. While most 

clandestine labs produce meth, some labs produce other substances such as Ecstasy 

(MDMA). The number of substances that are manufactured is constantly growing as new 

controlled substance analogs are developed to circumvent controlled substance laws. 
 

Page 21 GAO-13-204 Domestic Meth Labs 

Figure 6: DEA Funds Spent on the Lab Cleanup Program, Calendar Years 2002 

through 2011 

Note: By February 2011, DEA had exhausted all of the $8.3 million in appropriated fiscal year 2011 

funds for lab cleanups. The program did not restart operations until October 2011, when fiscal year 

2012 began and additional funds became available.

Given that labs can be placed in a wide range of locations, such as 

apartments, motel rooms, homes, or even cars, there is also the potential 

need for further remediation of these areas beyond the initial cleanup of 

hazardous waste if they are to be safely used or occupied again.

Whereas cleanup involves the removal of large-scale contaminants, such 

as equipment and large quantities of chemicals for the purpose of 

securing evidence for criminal investigations and reducing imminent 

hazards such as explosions or fires, remediation involves removing 

residual contaminants in carpeting or walls, for example, to eliminate the 

long-term hazards posed by residual chemicals. Procedures for 

remediation of a property or structure usually involve activities such as 

the removal of contaminated items that cannot be cleaned, such as 

carpeting, and wallboard; ventilation; chemical neutralization of residues; 

washing with appropriate cleaning agents; and encapsulation or sealing 

of contaminants, among other activities. Depending on the extent of the 
 

Page 22 GAO-13-204 Domestic Meth Labs 

contamination, the cost to remediate a property can be substantial.29

Because of their toxic nature, meth labs pose a serious physical danger 

to law enforcement officers who come across or respond to them, and 

therefore must be handled using special protective equipment and 

training that are costly to law enforcement agencies. The process of 

cooking meth, which can result in eye and respiratory irritations, 

explosions and fires, toxic waste products, and contaminated 

surroundings, can be dangerous not only to the meth cook but also to 

persons who respond to or come across a lab, such as law enforcement 

officers. Because of the physical dangers posed by the labs, the 

Occupational Safety and Health Administration has established 

requirements for persons, including law enforcement, entering a 

clandestine lab.

Extremely contaminated structures may require demolition. However, 

unlike the funding that is available for initial lab cleanup from DEA, there 

are no federal funds available for remediation, leaving the owner of a 

contaminated property responsible for the costs of any remediation to be 

done.

30

Because of the complexity involved in handling meth labs, seizing even a 

small lab can demand significant time and resources of law enforcement 

agencies. The processing of a lab can take hours and require the 

involvement of several officers to address the hazards left behind, collect 

and document evidence, and guard the scene of the lab while it is being 

processed. For example, according to one law enforcement official in 

Tennessee, responding to a meth lab requires at least two protectively 

suited-up officers inside the lab to gather evidence, two additional officers 

These requirements include initial and annual training 

on hazardous waste operations, annual physical exams to monitor the 

ongoing medical condition of individuals involved in handling meth lab 

sites, and guidelines for protective equipment to be used when working in 

a lab. Consequently, whether the lab is raided by investigators or 

encountered by accident during the course of an investigation, first 

responders and police agencies are required to provide their personnel 

specialized training and equipment, such as hermetically sealed hazmat 

suits, to safely process a lab.

 

29For example, decontamination of an average-sized site has been estimated to cost 

around $50,000.

3029 C.F.R. § 1910.120

Impacts on Law Enforcement
 

Page 23 GAO-13-204 Domestic Meth Labs 

suited up outside the lab as a backup team in case something happens 

with the lab and they need to respond, and at least one other officer onsite to provide security while the lab is being processed for evidence and 

cleanup. According to one estimate provided by a law enforcement 

agency in Indiana, the cost to the agency of the officers’ time as well as 

the protective equipment and processing supplies required to respond to 

a lab can exceed $2,000 per lab. Given these costs, law enforcement 

officials from all case study states agreed that responding to meth labs 

can be a significant financial burden on their agencies. For example, in 

fiscal year 2010, the Tennessee Meth Task Force spent $3.1 million 

providing equipment and training to law enforcement personnel and 

responding to meth lab incidents. Further, unlike large multinational drugtrafficking organizations, meth lab operators are usually lower income and 

producing meth for personal use; thus operators usually have little in the 

way of valuable assets or cash that law enforcement agencies can seize 

as a way of recouping the lab seizure response costs.

Electronic tracking systems can help prevent individuals from purchasing 

more PSE product than allowed by law. By electronically automating and 

linking logbook information on PSE sales and monitoring sales in real 

time, stop sale electronic tracking systems can block individuals 

attempting to purchase more than the daily or monthly PSE limits allowed 

by federal or state laws. All sales in states using the NPLEx system are 

linked; thus the system can also be used to block individuals who attempt 

to purchase more than the allowable amount of PSE in any state using 

the NPLEx system. According to data provided by the vendor that 

provides the NPLEx software platform, in 2011, the system was used to 

block the sale of more than 480,000 boxes and 1,142,000 grams of PSE 

products in 11 states. Similarly, as of July 31, 2012, the system was used 

to block the sale of more than 576,000 boxes and 1,412,000 grams of 

PSE products in the 17 states using the system in 2012. See table 1. 

Electronic Tracking 

Systems Help Enforce 

PSE Sales Limits but 

Have Not Reduced 

Domestic Meth Lab 

Incidents 

Tracking Systems Can 

Help Enforce Individual 

Sales Limits, Identify 

Potential Diversion, and 

Prosecute Meth Crimes
 

Page 24 GAO-13-204 Domestic Meth Labs 

Table 1: PSE Sales and Blocks for NPLEx States, 2011 through 2012

Number of states

on NPLEx Purchases Blocks

2011

a

11 15,479,147 (15,964,132 boxes; 

31,089,533 grams)

435,406 (484,325 boxes; 1,142,032 

grams; 

January 1, 2012, through 

July 31, 2012

17 18,729,125 (19,230,688 boxes; 

38,741,225 grams)

500,031 (576,840 boxes; 1,412,451 

grams)

Source: Appriss.

Note:

a

By automating the logbook requirement set forth by the CMEA, electronic 

tracking systems can make PSE sales information more accessible to law 

enforcement to help it investigate potential PSE diversion, find meth labs, 

and prosecute individuals for meth-related crimes.

Blocks occur when an individual attempting to purchase PSE product has already purchased the 

maximum amount of PSE product allowed by state or federal law or does not meet other established 

requirements such as being of minimum age or have been previously convicted of manufacturing 

methamphetamine, for example. In such instances, the system notifies the sales clerk to stop or 

“block” the sale from being completed.

31 Law enforcement 

officials we spoke with in all four case study states that use electronic 

tracking systems reported using the systems for one or more of these 

purposes. For example, officers from a Tennessee narcotics task force 

told us how they use the NPLEx system to help identify the diversion of 

PSE for meth production. According to these officers, the NPLEx system 

provides them with both real-time and on-demand access to pharmacy 

logs via a website and includes automated tools that enable them to 

monitor suspicious buying patterns or specific individuals.32

 

31With such systems in place, law enforcement no longer would need to go from retailer to 

retailer to examine or make copies of written logs to look for investigative leads.

In one 

particular case, the taskforce used NPLEx’s monitoring tools to place a 

watch on a specific individual previously identified as being involved in 

illegal meth activity. When the individual subsequently purchased PSE, 

the task force received a notification e-mail of the purchase and upon 

32The system can notify law enforcement when a particular individual purchases or 

attempts to purchase a PSE product. Law enforcement can also run specific reports on 

individuals or pharmacies. For example, a store report provides law enforcement with 

transaction summaries, as well as transaction and compliance details. An activity report 

can provide information on a specific person’s ID, specific pharmacy, and activity type 

(purchase, attempt, block, return, or inquiry).Two of the 17 states using NPLEx 

(Tennessee and Indiana) also use their own tracking systems in addition to NPLEx. 
 

Page 25 GAO-13-204 Domestic Meth Labs 

further investigation was able to determine that the individual had sold the 

PSE to a Mississippi meth cook. Some law enforcement officials in our 

four case study states reported that they do not actively use the electronic 

tracking systems for investigations but rather rely on other sources such 

as informants, meth hotlines, citizen complaints, and routine traffic stops 

to identify potential diversion and meth labs. Nevertheless, these officials 

acknowledged using these systems to obtain evidence needed to 

prosecute meth-related crimes after meth labs have been found. For 

example, a law enforcement official in Iowa noted that after officials have 

identified a suspected lab operator or smurfer, they can use the data in 

NPLEx to help build their case for prosecution or sentencing by using the 

records to estimate the amount of PSE that was potentially diverted for 

meth production. They can also determine for which retailers they need to 

obtain video evidence to confirm their identity of the individual making the 

purchase.

Law enforcement officials in Indiana and Tennessee, two states that 

recently moved from lead-generating systems to the NPLEx stop sale 

system, reported some challenges with NPLEx as a diversion 

investigation tool.33 Prior to the implementation of NPLEx, law 

enforcement was able to use the lead-generating systems in place to 

identify individuals who exceeded purchase limits and then take 

enforcement action or obtain a search warrant based upon the criminal 

offense. However according to these officials, given that NPLEx blocks 

individuals from exceeding purchase limits, individuals involved in 

diversion are no longer as readily identifiable as persons of interest and it 

now takes longer and is more labor intensive to investigate potential PSE 

diversions, as they no longer have arrest warrants as a tool to get into a 

residence suspected of having a meth lab.

 

33Lead-generating systems report sales information to a database that can be accessed 

by law enforcement to identify purchase limit violations or help generate leads on potential 

diversion for meth production.
 

Page 26 GAO-13-204 Domestic Meth Labs 

While electronic tracking systems such as NPLEx are designed to prevent 

individuals from purchasing more PSE than allowed by law, meth cooks 

have been able to limit the effectiveness of such systems as a means to 

reduce diversion through the practice of smurfing.34

Meth lab incidents in states that have implemented electronic tracking 

systems have not declined, in part because of smurfing. For example, 

meth lab incidents in the three states—Oklahoma, Kentucky, and 

Tennessee—that have been using electronic tracking systems for the 

longest period of time are at their highest levels since the implementation 

of state and federal PSE sales restrictions. While these states 

experienced initial declines in meth lab incidents immediately following 

the state and federal PSE sales restrictions put in place from 2004 

through 2006, lab incidents have continued to rise since 2007, likely in 

part because of the emergence of smurfing and the use of the One Pot 

method for production (see table 2).

Smurfing is a 

technique meth cooks use to obtain large quantities of PSE by recruiting 

individuals or groups of individuals to purchase the legal allowable 

amount of PSE products at multiple stores, and then aggregate for meth 

production. By spreading out PSE sales among individuals, smurfing 

circumvents the preventive blocking of stop sale tracking systems.

Table 2: Number of Lab Incidents for States That Have Used Electronic Tracking the Longest, 2002-2011

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Kentucky 388 a 516 622 616 336 310 442 743 1,359 1,758

Oklahoma 1,053 b 1,426 914 329 223 114 194 784 880 1,006

Tennessee 814 c 1,589 2,369 1,751 903 603 834 1,494 2,153 2,326

Source: DEA NSS.

Notes:

The number of lab incidents are in bold type for those years that electronic tracking was in effect for 

the state. Declines in the number of lab incidents that began prior to the states’ use of electronic 

tracking are likely due to legal restrictions on the sale of PSE being put in place through the states 

and the passage of the CMEA.

 

34With regard to the implementation of electronic tracking systems, some law enforcement 

officials have raised concerns specifically about the NPLEx system related to accessing 

sales data, among other issues. In November 2012, Senator Ron Wyden of Oregon and 

Representative Phil Roe of Tennessee requested that DOJ conduct an investigation into 

the NPLEx system and its operation. According to the Deputy Assistant Administrator for 

DEA’s Office of Diversion control, DOJ is reviewing this request.

Meth Producers Use 

Smurfing to Circumvent 

Tracking Systems, and Lab 

Incidents in Tracking 

States Have Not Declined
 

Page 27 GAO-13-204 Domestic Meth Labs 

a

Kentucky began using electronic tracking in June 2008.

b

Oklahoma began using electronic tracking in 2006.

c

Law enforcement officials from every region of the country report that the 

PSE used for meth production in their areas can be sourced to local and 

regional smurfing operations.

Tennessee began using electronic tracking in 2006. 

35 The methods, size, and sophistication of 

these operations can vary considerably—from meth users recruiting 

family members or friends to purchase PSE for their own individual labs 

to larger-scale operations where groups purchase and sell large 

quantities of PSE to brokers for substantial profits, who in turn often sell 

the PSE to Mexican drug-trafficking organizations operating super labs in 

California.36

The use of fake identification by smurfs is an area of growing concern for 

law enforcement. Smurfs can use several different false IDs to purchase 

PSE above the legal limit without being detected or blocked by a tracking 

system. For example, in 2012, through a routine traffic stop, state and 

local law enforcement officials in Tennessee identified a smurfing ring 

where a group of at least eight individuals had used more than 70 false 

IDs over a 9-month period to obtain over 664 grams of PSE. All of the IDs 

had been used to purchase the maximum amount of PSE allowed, with 

only one transaction (2.4 grams of PSE) blocked by the electronic 

tracking system. Law enforcement officials from the four electronic 

tracking case study states emphasized that investigating smurfing rings 

can be very time and resource intensive because of the large number of 

persons involved and the potential use of fraudulent identifications. The 

use of fake IDs for smurfing can also affect the use of electronic tracking 

systems as tools to assist in the prosecution of meth-related crimes. 

According to the National Methamphetamine & Pharmaceuticals Initiative 

(NMPI) advisory board, smurfers are increasingly utilizing fake 

identification and “corrupting” electronic tracking databases to the point 

where prosecutors prefer eyewitness accounts and investigation (law 

enforcement surveillance) of violations before filing charges or authorizing 

Individuals recruited for smurfing have included the elderly, 

homeless, college students, the mentally handicapped, and inner city 

gang members, among others.

 

35U.S. Department of Justice. National Drug Intelligence Center, National Drug Threat 

Assessment 2011. (Washington, D.C.: August 2011). 

36Boxes of PSE purchased for $7 or less can be sold for between $30 and $100.
 

Page 28 GAO-13-204 Domestic Meth Labs 

arrests or search warrants.37

In summary, based on the experience of states that have implemented 

electronic tracking, while it has not reduced meth lab incidents overall, 

this approach has had general impacts, but also potential limitations, 

including the following:

This results in costly man-power-intensive 

investigations.

• Under the current arrangement with CHPA, the operating expenses of 

NPLEx are paid for by PSE manufacturers and provided to the states 

at no cost.

• Automating the purchase logbooks required by the CMEA and making 

the logbook information available in an electronic format to law 

enforcement is reported to be a significant improvement over paper 

logs that have to be manually collected and reviewed. This recordkeeping ability is reported to have also been useful in developing and 

prosecuting cases against individuals who have diverted PSE for 

meth production.

• Electronic tracking maintains the current availability of PSE as an 

OTC product under limits already in place through the CMEA and 

related state laws.

• The NPLEx system helps to block attempts by a consumer using a 

single identification to purchase PSE products in amounts that exceed 

 

37 NMPI is a national High Intensity Drug Trafficking Area (HIDTA) program initiative 

funded by the ONDCP through the Southwest Border HIDTA California Region. The NMPI 

is a national strategy, intelligence-sharing, and training initiative addressing 

methamphetamine and pharmaceutical drug crimes in the United States. The mission of 

NMPI is to reduce the availability of methamphetamine and its precursor chemicals 

throughout the United States. NMPI also seeks to reduce pharmaceutical drug crimes by 

utilizing best practices for investigations and intelligence collection and analysis. The 

NMPI has a National Advisory Board consisting of four federal and six state and local 

representatives from various regions of the United States. The purpose of the HIDTA 

program (created by the Anti-Drug Abuse Act of 1988, Pub. L. No. 100-690, 102 Stat. 

4181) is to reduce drug trafficking and production in the United States by, among other 

things, facilitating cooperation among federal, state, local, and tribal law enforcement 

agencies. There are currently 28 HIDTA regions, which include approximately 16 percent 

of all counties in the United States and 60 percent of the U.S. population. HIDTAdesignated counties are located in 46 states, as well as in Puerto Rico, the U.S. Virgin 

Islands, and the District of Columbia. The HIDTAs are directed and guided by executive 

boards composed of an equal number of regional federal and non-federal (state, local, 

and tribal) law enforcement leaders.
 

Page 29 GAO-13-204 Domestic Meth Labs 

the legal limit, and can prevent excessive purchases made at one or 

more locations.

• Although PSE manufacturers currently pay for the NPLEx system, 

depending on the circumstances, their financial support may not 

necessarily be sustained in the future.

• Although electronic tracking can be used to block sales of more than 

the legal amount to an individual using a given identification, through 

the practice of smurfing, individuals can undermine this feature and 

PSE sales limits by recruiting others to purchase on their behalf or by 

fraudulently using another identification to make PSE purchases.

• According to some law enforcement officials, the stop sale approach 

of the NPLEx system makes it more challenging to use the system as 

an investigative tool than a lead-generating system because it 

prevents individuals from exceeding purchase limits, which would 

otherwise make them more readily identifiable to law enforcement as 

persons of interest.

• The practice by smurfers of using fraudulent identification to purchase 

PSE products has been reported to diminish the ability of electronic 

tracking systems to assist in the prosecution of meth related crimes.

According to some law enforcement officials, the rising use of 

fraudulent identifications has also increased the need to gather 

eyewitness accounts or conduct visual surveillance to confirm the 

identities of the individuals, a development that in turn has been 

reported to lead to more time- and resource-intensive investigations.

Prescription-Only 

Appears to Help 

Reduce Lab Incidents; 

Full Impact on 

Consumers Is 

Unknown and May Be 

Limited on Health 

Care System
 

Page 30 GAO-13-204 Domestic Meth Labs 

The number of reported meth lab incidents in both Oregon and 

Mississippi declined following the adoption by those states of the 

prescription-only approach for PSE product sales (see fig. 7). In the case 

of Oregon, the number of reported meth lab incidents had already 

declined by nearly 63 percent by 2005 from their 2004 peak of over 600 

labs. After the movement of PSE products to behind-the-counter status in 

Oregon in 2005 and implementation of the CMEA and state-imposed 

prescription-only approach in 2006, the number of reported meth lab 

incidents in Oregon continued to decline in subsequent years. In 

Mississippi, after the adoption of the prescription-only approach in 2010, 

the number of reported meth lab incidents subsequently declined from

their peak by 66 percent to approximately 321 labs in 2011. See fig.7

below.

Figure 7: Reported Meth Lab Incidents in Oregon and Mississippi, 2002 through 

2011

Notes:

The number of lab incidents are in bold type for those years that the prescription-only approach was 

in effect for the state for a full year. Declines in the number of lab incidents that began prior to the 

states’ use of the prescription-only approach are likely due to legal restrictions on the sale of PSE 

being put in place through the states and the passage of the CMEA.

Data was accessed on October 1, 2012.

a

Mississippi implemented the prescription-only approach in July 2010.

b

The communities in Missouri that have adopted local prescription-only 

requirements also experienced a decline in the number of meth labs. For 

Oregon implemented the prescription-only approach in July 2006.

Implementation of 

Prescription-Only 

Approach Followed by 

Declines in Lab Incidents, 

although Some PSE 

Diverted from Other States
 

Page 31 GAO-13-204 Domestic Meth Labs 

example, while lab incidents statewide in Missouri increased nearly 7 

percent from 2010 to 2011, the area in southeastern Missouri where most 

of the communities have adopted prescription-only ordinances saw lab 

incidents decrease by nearly half.

Even as declines were observed in Oregon and Mississippi after 

implementing the prescription-only approach, declines were also 

observed in neighboring states that did not implement the approach, 

possibly because of other regional or reporting factors. For example, all 

states bordering Oregon also experienced significant declines in meth 

labs from 2005 through 2011, ranging from a 76 percent decline for 

California to a 94 percent decline for Washington state. In Mississippi’s 

case, except for Tennessee, all bordering states also experienced 

declines in lab incidents from 2009 through 2011, ranging from a 54 

percent decrease in Arkansas to a decline of 57 percent in Louisiana. 

Consequently, there may be some other factors that contributed to the lab 

incident declines across all these states regardless of the approach 

chosen. One potential factor for the declines observed from 2010 through 

2011 is the exhaustion of DEA funds to clean up labs. According to DEA 

officials, as the funds provide an incentive to state and local agencies to 

report meth lab incidents to DEA, the lack of funds from February 2011 to 

October 2011 may have resulted in fewer lab incidents being reported 

during this time period. Other potential factors within the states may have 

also contributed to declines in the number of lab incidents in neighboring 

states. For example, Arkansas law enforcement officials reported that in 

2011, a change in state law took effect that made it illegal to dispense 

PSE products without a prescription, unless the person purchasing the 

product provided a driver’s license or identification card issued by the 

state of Arkansas, or an identification card issued by the United States 

Department of Defense to active military personnel.38 In addition, 

Arkansas law requires that a pharmacist make a professional 

determination as to whether or not there is a legitimate medical and 

pharmaceutical need before dispensing a nonexempt PSE product 

without a valid prescription.39

 

382011 Ark. Acts 588. See Ark. Code Ann. §§ 5-64-1103 to -1105. 

As a result of these additional requirements, 

retailers such as Walmart decided to no longer sell PSE products OTC in 

Arkansas and instead require a prescription.

39Ark. Code Ann. § 5-64-1103. 
 

Page 32 GAO-13-204 Domestic Meth Labs 

According to state and local law enforcement officials in Oregon and 

Mississippi, the prescription-only approach contributed to the reduction of 

reported meth lab incidents within those states. For example, according to 

the executive director of the Oregon Criminal Justice Commission and the 

directors of the Mississippi Bureau of Narcotics and the Gulf Coast 

HIDTA, the decline in meth lab incidents in their states can be largely 

attributed to the implementation of the prescription-only approach. 

Although their perspectives cannot be generalized across the broader 

population of local law enforcement agencies, law enforcement officials of 

other agencies we met with in Oregon and Mississippi also credited the 

reduction in meth lab incidents to the implementation of the prescriptiononly approach.

To determine the extent to which the declines in lab incidents in Oregon 

were due to the prescription-only approach rather than other variables 

such as regional or reporting factors, we conducted statistical modeling 

analysis of lab incident data, the results of which indicate a strong 

association between the prescription-only approach and a decline in meth 

lab incidents.40 Specifically, our analysis showed a statistically significant 

associated decrease in the number of lab incidents in Oregon41 following 

introduction of the law, with the lab incident rate falling by over 90 percent 

after adjusting for other factors.42

With the decline in meth lab incidents, officials in the prescription-only 

states reported observing related declines in the demand and utilization 

 

40The analysis controlled for other factors that could have an impact on the number of 

meth lab incidents in a given state such as region of the country, ethnic composition, the 

proportion of the state population that is male, distance from the Mexican border to 

account for international supply, police presence, and the state drug arrest rate, among 

others. Consistent with completed peer-reviewed research, the analysis was run on 

incidents of all lab seizures of all productive capacities, as well as small toxic labs. For 

more information on the methodology used for this model and the results of this analysis, 

see appendix III. 

41Because of the lack of sufficient data from the time Mississippi adopted the prescriptiononly approach in July 2010, we could not perform a similar analysis for Mississippi. 

42Contrary to the findings in Cunningham et al. (2012) and Strauberg and Sharma (2012), 

our analysis found that the lab seizure rate fell significantly in Oregon after the 

prescription-only policy was implemented after adjusting for other factors. The differences 

in our findings are likely due to differences in model specification, analytical approach, and 

date we pulled the data from the NSS for analysis. See appendix III for more details on 

our methodology.
 

Page 33 GAO-13-204 Domestic Meth Labs 

for law enforcement, child welfare, and environmental cleanup services 

that are needed to respond to meth labs:

• Law enforcement: Local law enforcement officials in Oregon and

Mississippi reported that the reduction in meth lab incidents has 

reduced the resource and workload demands for their departments to 

respond to and investigate meth labs. For example, one chief of a 

municipal police department in Oregon reported that the decline in 

meth labs has resulted in reduced costs to his department largely in 

the form of reduced manpower, training, and equipment expenses 

and noted that lab seizures are now so rare that his department no 

longer maintains a specialized team of responders to meth labs. 

Another chief of a municipal police department in Mississippi noted 

that since the adoption of the prescription-only approach, the amount 

of time and resources spent on meth-related investigations has 

declined by at least 10 percent.

• Child welfare: Officials in both Oregon and Mississippi reported a 

reduction in the demand for child welfare services to assist children 

found in households where meth lab incidents occurred. For example, 

according to a coordinator in Oregon’s Department of Human 

Services, the state has not removed a child from a household with an 

active lab since 2007. In Mississippi, the Methamphetamine Field 

Coordinator with the state Bureau of Narcotics, which tracks the 

number of drug-endangered children for the state, reported that the 

number of such children declined by 81 percent in the first year that 

the prescription-only approach was in effect.

• Environmental cleanup: According to data from DEA and the Oregon 

Department of Environmental Quality, declines in costs to clean up 

labs in Oregon occurred prior to the implementation of the 

prescription-only approach, falling from almost $980,000 in 2002 to 

about $580,000 in 2005. However, since 2006, costs for lab cleanup 

continued to fall and were about $43,000 in 2011. Funding for 

cleanups in Mississippi showed more variation and fluctuation from 

year to year; however, between 2010, when the prescription-only 

approach was implemented, and 2011, cleanup costs dropped by 

more than half (from over $1 million to less than $400,000).

However, even as the prescription-only approach appears to have 

contributed to reducing the number of lab incidents in Oregon, the 

availability and trafficking of meth is still widespread and a serious threat 

in the state. According to a threat assessment by the Oregon HIDTA, 

while the number of reported meth lab incidents has declined, crystal 
 

Page 34 GAO-13-204 Domestic Meth Labs 

meth continues to be highly available in the area as Mexican drug 

traffickers import the finished product from laboratories outside the state 

and from Mexico.

Moreover, while the prescription-only approach appears to have 

contributed to a reduction in the number of meth labs in the states that 

have adopted it, the experience of these states to date has shown that 

the prescription-only approach does not preclude individuals from 

traveling to neighboring states to purchase PSE products for use in meth 

labs. Consequently, even as the number of meth lab incidents has 

declined in prescription-only states, law enforcement reports that many 

lab incidents that still occur in these states are largely due to PSE product 

obtained from states without a prescription requirement for PSE. For 

example, according to a threat assessment by NDIC, law enforcement 

officers interviewed in 2011 reported that the more stringent restrictions 

on pseudoephedrine sales in Mississippi have led many pseudoephedrine 

smurfing groups to target pharmacies in the neighboring states of 

Alabama, Louisiana, and Tennessee in order to continue operations. 

Officials of a sheriff’s office in a county located along the Gulf Coast in 

Mississippi stated that the department’s investigations have found that 

large numbers of individuals from Mississippi travel out of state to 

purchase PSE in an effort to circumvent the Mississippi prescription-only 

law. While some out-of-state purchases may be for licit uses, the officials 

stated that they believed a substantial proportion of the PSE brought back 

from other states was likely being diverted for the production of meth. 

According to law enforcement officials in Oregon, most of the incidents 

reported there in recent years involved either dumpsites or inactive 

“boxed labs” that had been used in previous years but have been 

dismantled and stored away for potential future use. According to the 

legal counsel for the Oregon Narcotics Enforcement Association, the 

association asked law enforcement to determine the source of PSE for 

lab incidents, in cases where that could be determined. In every case 

where a determination could be made, it was reported that the PSE was 

obtained from neighboring states, mostly Washington, but also Idaho, 

California, and Nevada.

According to PSE purchase activity data from the NPLEx electronic 

tracking system and the vendor that provides its software platform, 

individuals using Oregon identifications have purchased PSE products in 
 

Page 35 GAO-13-204 Domestic Meth Labs 

neighboring states.43 These data indicate that from October 15, 2011, 

through August 31, 2012, over 30,000 purchases were made by 

individuals using Oregon identifications. Similarly for Mississippi, reports 

by law enforcement of individuals traveling to neighboring nonprescription-only states to purchase PSE products is supported by PSE 

purchase activity data provided by the NPLEx electronic tracking 

system.44 Since the time the NPLEx system has been implemented in 

these states, the PSE purchase activity data indicate that over 172,000 

purchases have been made by individuals using Mississippi 

identifications.45

Some states have taken action to eliminate the opportunity for out-ofstate individuals to purchase PSE products without a prescription. For 

example, in 2011, Arkansas passed legislation making it illegal to 

dispense any PSE product without a prescription, unless the purchaser 

can provide an Arkansas-issued driver’s license or identification card, or 

an identity card issued by the U.S. Department of Defense for active-duty 

military personnel.46

 

43The only state Oregon shares a border with that has adopted electronic tracking during 

the period of this analysis was Washington, which implemented the NPLEx system on 

October 15, 2011. In addition, some retailers located in the neighboring states of 

California, Idaho, and Nevada, which have not adopted electronic tracking or the NPLEx 

system, use the software platform the NPLEx system is based on to track PSE sales 

within their stores and meet logbook requirements. Known as MethCheck, the software 

platform was developed by Appriss, Inc., a government technology provider based in 

Louisville, Kentucky. It is a real-time electronic reporting system that allows pharmacy 

employees to view each customer’s purchasing history at the point of sale and makes that 

information available to law enforcement. 

In 2012, Alabama enacted a similar law that requires 

individuals residing within a state that requires a prescription to obtain a 

PSE product to provide a valid prescription for the PSE products if they 

44Three states bordering Mississippi (Louisiana, Alabama, and Tennessee) have adopted 

the electronic tracking approach for restricting PSE product sales and have implemented 

the NPLEx electronic tracking system. These states implemented the NPLEx system at 

different times: Alabama in January 2011, Louisiana in June 2010, and Tennessee in 

January 2012. Arkansas also borders Mississippi and has adopted the electronic tracking 

approach but has implemented its own electronic tracking system. 

45Because these states adopted the system at about the same time or after Mississippi 

adopted its prescription-only approach, data are not available to determine the extent to 

which the volume of PSE sales-related activities involving individuals using Mississippi 

identifications changed over time. 

462011 Ark. Acts 588. See Ark. Code Ann. §§ 5-64-1103 to -1105. 
 

Page 36 GAO-13-204 Domestic Meth Labs 

seek to obtain the products in Alabama.47

In addition to obtaining PSE products from non-prescription states, 

another potential source of PSE for meth labs in prescription-only states 

and localities is through the illicit diversion of PSE obtained with a 

prescription. Similar to techniques used to divert other controlled 

prescription drugs such as pain relievers, diversion of prescribed PSE can 

occur through prescription forgery, illegal or improper prescribing by a 

physician, or “doctor shopping,” where an individual goes to several 

doctors to obtain a prescription from each doctor. Although these may 

provide potential sources of PSE for use in meth labs in prescription-only 

states, law enforcement officials in Oregon and Mississippi reported no 

known instances from their meth lab investigations of finding that a PSE 

product was obtained through one of those methods in order to make 

meth. Law enforcement officials in Missouri localities where the 

prescription-only requirement has been adopted reported a few instances 

of PSE obtained with a prescription being used to make meth. According 

to investigators from a regional drug task force in a county in Missouri, 

they have found PSE obtained by prescription in at least three meth lab 

incidents. Since the county has adopted the prescription-only approach, 

they are observing more instances in which prescriptions of PSE are 

found at lab incidents. However, they did not find any evidence in these 

cases that the PSE had been prescribed illegally or obtained through 

prescription forgery or doctor shopping.

In essence, the impact of these 

laws is to extend the prescription-only requirement for Mississippi 

residents into Arkansas and Alabama. Officials from the Mississippi 

Bureau of Narcotics said these laws will help prevent PSE product from 

being obtained and diverted to Mississippi for use in meth labs.

Judging from the experience of Mississippi, the volume of PSE products 

obtained by consumers after the adoption of the approach declined from 

levels that existed when PSE was available OTC. Data on Mississippi 

OTC PSE product sales and the number of prescriptions for PSE filled 

suggest that use of PSE products could have fallen by several hundred 

thousand units after the implementation of the prescription-only approach. 

For example, annual unit sales of PSE dropped from almost 749,000 in 

2009 before the prescription-only approach went into effect, to 

 

472012 Ala. Acts 2012-237. See Ala. Code § 20-2-190(d).

Prescription-Only Status 

for PSE Appears to Have 

Reduced Sales of PSE 

Products, but the Full 

Impact on Consumers Is 

Not Known
 

Page 37 GAO-13-204 Domestic Meth Labs 

approximately 480,000 total units of PSE product sold OTC or prescribed 

in 2010, when the approach was in effect for half the year, to 

approximately 191,000 units prescribed or sold during 2011, when the 

approach had been in place for the full year (see table 3).48 Data are not 

available for Oregon on the sales of PSE products immediately before 

and after the implementation of the prescription-only approach to do a 

comparable analysis.49

Table 3: Units of PSE Products Sold OTC or Prescribed in Mississippi, January 2009-December 2011

52 weeks ending 12/27/2009 52 weeks ending 12/26/2010 52 weeks ending 12/25/2011

Dollar 

sales

Units sold or 

prescribed

Dollar 

Sales

Units sold or 

prescribed

Dollar 

sales

Units sold or 

prescribed

OTC PSE sales $7,374,772 731,522a $4,011,158 383,313a $21,341 3,328 

Percentage change 

from previous period

a, b

Not applicable. Not applicable. -45.6 -47.6 -99.5 -99.1

Percentage change 

from 12/27/2009

Not applicable. Not applicable. -45.6 -47.6 -99.7 -99.5

Prescriptions filled for 

PSE products

Not available. 17,221 a, c Not available. 96,454a Not available. 187,680

Total PSE 

prescriptions filled and 

OTC sales

a

Not available. 748,743 Not available. 479,767 Not available. 191,008

Source: GAO analysis of data from IMS Health Incorporated and the Mississippi Prescription Drug Monitoring Program.

a

Values shown are for the number of units of OTC PSE product sold or prescriptions filled for drugs 

containing PSE. Although the amount of PSE sold OTC or dispensed by prescription in any given unit 

can vary depending on the size of the OTC package or prescription, for the purposes of this analysis 

all units reported sold OTC or prescribed are assumed to contain equivalent quantities of PSE.

b

 

48Because Walmart does not report to outside parties the volume of sales in its stores of 

individual products, the sales data for PSE products do not include the PSE products sold 

at Walmart stores. Consequently, if sales at Walmart stores were to be included, the total 

volume of all sales for PSE products would likely be higher than reported by this estimate. 

Data on prescriptions for PSE are tracked through the Mississippi Prescription Drug 

Monitoring Program, which includes data from all licensed pharmacies in Mississippi. 

According to officials that provided these data, OTC PSE product sales may have been reported 

after the prescription-only approach was in effect because of a number of potential reasons: sampling 

error, data entry error, clerks overriding the system at the point of sale when a prescribed PSE 

purchase was being made but the system did not recognize it, or the possibility of retailers making an 

OTC sale of a PSE product despite the prescription-only requirement.

49Oregon did not initiate its prescription drug monitoring program until 2011. From October 

2011 to November 2012, Oregon officials report that about 140,000 prescriptions for PSE 

have been filled.
 

Page 38 GAO-13-204 Domestic Meth Labs 

c

Given the more restrictive access to PSE products consumers would face 

under the prescription-only approach, it is expected that consumers will 

be impacted. The extent of this impact depends on a number of variables 

such as the potential change in the effective price of PSE that the 

requirements of the prescription-only approach result in and the 

availability of effective substitutes or alternative remedies for PSE, for 

example. Under the prescription-only approach, the effective price of 

PSE, which includes costs associated with obtaining a prescription, such 

as the costs of time and travel to the physician for an appointment as well 

as any associated copays or out-of-pocket charges for the appointment 

itself, would increase if an in-person visit were necessary, having a 

negative impact on consumers. If the PSE prescriptions are being 

obtained by consumers at a higher effective price because of these 

factors, consumers can be expected to be negatively impacted to some 

extent by the prescription-only approach. At the same time, some of these 

costs, such as the costs of time and travel to go to an in-person 

appointment can be mitigated to the extent patients can obtain a 

prescription for PSE through a telephone consultation with their 

physicians. While it is likely that the effective price for PSE products is 

higher under the prescription-only approach, data on the cost to 

consumers for obtaining these prescriptions are not available to make this 

comparison. Further complicating the determination of the change in the 

effective price of PSE is the fact that the actual costs to a given consumer 

for that person’s time, travel, and insurance coverage can vary from 

consumer to consumer depending on the person’s individual 

circumstances. For example, given their lack of insurance, uninsured 

consumers or patients will likely face higher effective costs to obtain PSE 

products under a prescription-only approach than those with insurance. 

Because of the uncertainty involving these variables and factors, it is not 

possible to determine the magnitude of the change in effective price of 

PSE for consumers.

Prescriptions filled for PSE recorded before the implementation of the prescription-only approach in 

July 2010 reflect prescriptions for medications for which PSE is included as a combination ingredient 

with another ingredient for which a prescription is needed.

Despite the likely increase in the effective price of PSE because of the 

prescription-only approach, according to state agencies and consumer 

groups, consumers in Oregon and Mississippi have made few complaints 

about the approach since its implementation, although research or 

surveys on the issue have not been conducted. For example, according 

to the executive director of the Oregon Board of Pharmacy, the state 

agency that adopted the rule making PSE a controlled substance, the 

board initially received a small number of complaints from consumers 
 

Page 39 GAO-13-204 Domestic Meth Labs 

when PSE was initially scheduled, but after a number of months, the 

board stopped hearing about it. Officials at the Mississippi Board of 

Pharmacy also noted that they have not received any complaints from 

consumers about the prescription requirement since it went into effect. 

According to consumer and patient advocacy organizations such as the 

National Consumers League and the Asthma and Allergy Foundation of 

America, which conducted surveys of consumers regarding access to 

PSE products in 2005 and 2010 respectively, neither organization has 

received feedback or complaints from consumers or patients from either 

state about the diminished access imposed on PSE products by the 

prescription-only approach. Both organizations also noted that they have 

not conducted any additional research or surveys on the issue since their 

earlier surveys in 2005 and 2010.

Another variable that determines the impact of the prescription-only 

approach on consumers is the availability of substitutes for PSE that 

consumers can use as alternatives to offset any potential increase in the 

effective price to consumers for obtaining PSE by prescription. To ensure 

that consumers still have access to an unrestricted oral OTC 

decongestant, manufacturers of cold and allergy medicines reformulated 

many products by substituting the ingredient phenylephrine (PE), an 

alternative oral decongestant also approved by FDA for use in OTC 

medicines that cannot be used to make methamphetamine. However, 

according to sales data on PE products in Mississippi for the periods 

before and after implementation of the prescription-only approach, the 

changes in sales volume for PE products do not appear to show any 

direct substitution of PE for PSE by consumers. In fact, the change in 

volume in PE products shows a decrease for the 52-week period ending 

in December 2011 (see table 4).

Table 4: Sales of OTC PE Products in Mississippi, January 2009-December 2011

52 weeks ending 12/27/2009 52 weeks ending 12/26/2010 52 weeks ending 12/25/2011

Dollar sales Units sold Dollar sales Units sold Dollar sales Units sold

PE sales $6,280,693 1,137,699a $6,323,837 1,155,900a $6,042,349 1,087,800

Percentage change 

from previous period

a

Not applicable. Not applicable. 0.7 1.6 -4.5 -5.9

Percentage change 

from 12/27/2009

Not applicable. Not applicable. 0.7 1.6 -3.8 -4.4

Source: GAO analysis of IMS Health Incorporated data.

a

Although the amount of PE sold in any given unit can vary depending on the size of the package, for the purposes of this analysis all 

units reported sold are assumed to contain equivalent quantities of PE
 

Page 40 GAO-13-204 Domestic Meth Labs 

The lack of a consumer shift from PSE products to PE products could be 

the result of several potential factors, but data are limited or unavailable 

to ascertain their impact. For example, it could reflect, on average, 

consumer perception that PE is not an effective substitute for PSE.

Similarly, it could also be an indication that consumers are choosing to 

forgo medicating their conditions or are using other medications or 

remedies to relieve their symptoms. Another potential factor that could 

contribute to this lack of a consumer shift to PE from PSE is the extent to 

which PSE sales were being diverted for meth use. Although available 

estimates of the extent to which PSE sales are being diverted vary 

greatly, the drop in PSE sales without a corresponding increase in PE 

product sales could also imply that some of the PSE sales were likely 

being diverted for meth production. According to officials of the market 

research firm that provided the PE sales data, another potential 

explanation for the lack of a distinct shift in demand for PE is the fact that 

several PE products had to be recalled by the manufacturer because of 

manufacturing issues.

Industry has noted that PE has limitations as a direct substitute for PSE, 

and in 2007, FDA reexamined the effectiveness of PE at the approved 

dosing levels. At the request of citizen petitioners who claimed that the 

available scientific evidence did not demonstrate the effectiveness of PE 

at the approved 10-miligram dosage level, an FDA advisory committee 

reviewed the issue in December 2007, including two meta-analyses of 

studies provided by the citizen petitioners and CHPA.50

 

50The FDA Nonprescription Drug Advisory Committee held a hearing on December 14, 

2007, in response to a citizen petition submitted to FDA that asserted that the available 

data do not support the adult and pediatric doses of phenylephrine hydrochloride and 

phenylephrine bitartrate that are generally recognized as safe and effective in the OTC 

drug monograph as set forth in 21 C.F.R. part 341. The citizen petitioners included Leslie 

Hendeles, PharmD, Professor, Pharmacy and Pediatrics, University of Florida; Randy C. 

Hatton, PharmD FCCP BCPS, Co-Director, Drug Information and Pharmacy Resource 

Center, Clinical Professor, University of Florida; and Almut G. Winterstein, PhD, Assistant 

Professor, Department of Pharmacy Healthcare Administration, University of Florida.

After reviewing 

this evidence, the committee concluded that, while additional studies 

would be useful to evaluate higher doses, the 10-miligram PE dose was 

effective. However, since the recommendation of the FDA advisory 

committee in 2007 to study the effectiveness of PE at higher dosage 
 

Page 41 GAO-13-204 Domestic Meth Labs 

levels, it appears that limited work has been undertaken to do so.51

According to CHPA, while it agrees that the approved dosage levels of 

PE are effective, PE has known limitations that make it a less than viable 

substitute for PSE in some long-duration applications and for many 

consumers.52

As would be expected under the more restrictive prescription-only 

approach, consumers of PSE products would be negatively impacted to 

some extent by enactment of the prescription-only approach, considering 

the variables that determine the change in the effective price of PSE 

products. However, because of uncertainties related to these variables, 

such as consumers’ individual situations regarding insurance or the need 

for an in-person consultation with their physicians, the effectiveness of 

substitutes such as PE or use of other alternatives, and the extent to 

which PSE sales have been used for illicit purposes, the net effect on 

consumer welfare resulting from enactment of a prescription-only policy 

cannot be quantified.

One of the concerns expressed by industry about the potential impact of 

the prescription-only approach is that it is likely to increase the workload 

of health care providers and the overall health care system to some 

extent. Both the Oregon and Mississippi laws required individuals to 

obtain a prescription from a health care provider which requires some 

type of visit or consultation with the provider. This visit or consultation

requires increased provider workload to process the prescriptions. In 

addition, individuals who do not already have an established relationship 

 

51According to FDA procedures and processes for making changes to approved OTC 

monographs, including those involving changes in dosage levels, additional studies of the 

effectiveness of higher dosages of PE would need to be conducted by industry or citizen 

petitioners. We contacted the citizen petitioners, who indicated they were not aware of any 

additional study of the issue since the advisory committee meeting in 2007. 

52In its briefing to the FDA advisory committee, CHPA stated that its assessment of 

available evidence at the time supports the conclusion that PE at dosages of 10 milligram 

is safe and effective as a nasal decongestant for over-the-counter use in adults. However, 

CHPA has also noted limitations of PE that make it a less than direct substitute for PSE in 

some applications. For example, PE is metabolized more quickly than PSE and is thus 

available only in conventional formulations to be taken every 4 hours, whereas PSE can 

be made available as 12‐hour and 24‐hour sustained formulations, a fact that is said to 

increase consumer convenience and reduce the risk of medication errors. Additionally, 

CHPA notes that as consumers respond differently to different ingredients, many choose 

PSE because it works better for them.

The Impact on the Health 

Care System Is Generally 

Unknown but Substantial 

Changes in Workload Have 

Not Been Reported to Date
 

Page 42 GAO-13-204 Domestic Meth Labs 

with a health care provider may require a more involved, initial in-person 

visit to obtain a prescription, and pharmacies may experience increased 

workload because of new dispensing requirements. Assuming that health 

care providers charge prices that reflect the costs of providing these 

additional services, any increase in the workload of health care providers 

should get reflected in the office charge billed the patient.

While the impact of the prescription-only approach on the health care 

system is generally unknown, on the basis of limited information available 

from health care providers in Oregon and Mississippi, it does not appear 

that there has been a substantial increase in workload demands to 

provide and dispense prescriptions for PSE products. According to a 

2011 study commissioned by CHPA on managing access to PSE, judging 

from Oregon’s experience, the number of health care provider visits did 

not grow significantly, as consumers have noted obtaining a prescription 

via telephone or fax request. Officials from associations representing 

physicians in Oregon stated that their members have not reported any 

real impact on their practices, and their research from members suggests 

that the benefits of fewer meth labs outweighs any inconvenience for their 

membership of requests for prescriptions. Officials from the association 

representing Mississippi physicians similarly reported that from the 

perspective of a limited sample of its members involved in family practice, 

emergency room care, and addiction treatment, no increase had been 

observed in the demand for appointments from patients seeking PSE 

products. In addition, representatives from the association representing 

pharmacists in Oregon stated that they have received few complaints 

over the prescription-only requirement. Further, reports from the 

experience of Oregon and Mississippi indicate that there has not been a 

significant increase in cost to the states’ Medicaid programs. In terms of 

an impact on states’ Medicaid programs, officials in those states said 

there was no net change in their programs’ policy with the implementation 

of the prescription requirement statewide because their programs already 

required that participants obtain a prescription for PSE products if they 
 

Page 43 GAO-13-204 Domestic Meth Labs 

wanted to have the medication covered under the states’ Medicaid 

pharmacy benefit formulary.53

In summary, on the basis of the experience of Oregon and Mississippi, 

the use of the prescription-only approach has had the following impacts:

• Its apparent effectiveness in reducing the availability of PSE for meth 

production has in turn helped to reduce or maintain a decline in the 

number of meth lab incidents in the states that have adopted the 

approach.

• The reduction in meth lab incidents has led to a corresponding decline 

in the demand or need by communities for child welfare, law 

enforcement, and environmental cleanup services to respond to the 

secondary impacts of the meth labs.

• Although it is difficult to quantify due to the lack of data and wide 

variation in the individual circumstances of consumers, the 

prescription-only approach has the potential for placing additional 

burdens on consumers to some extent.

• Increased the potential for additional workload and costs for the health 

care system to provide prescriptions for PSE products. From the 

limited information and data that are available to date, it is not clear 

that they have been substantial in the two states that have adopted 

the prescription-only approach to date.

• Increased possibility of consumers in a prescription-only state 

attempting to bypass the prescription-only requirement by purchasing 

PSE in a neighboring nonprescription state.

 

53Although it is possible that some Medicaid plan participants previously purchased PSE 

products on their own and at their own expense prior to the law being implemented but 

now would be required to obtain a prescription, the officials stated that the data are not 

available to quantify the number of patients this is the case for. To the extent that these 

participants are now having Medicaid cover their PSE prescriptions, there is likely an 

increase in cost to the program. 
 

Page 44 GAO-13-204 Domestic Meth Labs 

We provided a draft of this report to the Department of Justice and 

ONDCP for comment. Justice and ONDCP did not provide written 

comments on the report draft, but both provided technical comments, 

which we incorporated as appropriate. 

As agreed with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after its 

issue date. At that time, we will send copies of this report to the Attorney 

General, the Director of the Office of National Drug Control Policy, 

appropriate congressional committees, and other interested parties. In 

addition, the report will be available at no charge on the GAO Web site at 

http://www.gao.gov.

If you or your staffs have any questions about this report, please contact 

Carol Cha at (202) 512-4456 or chac@gao.gov. Contact points for our 

Office of Congressional Relations and Public Affairs may be found on the 

last page of this report. Key contributors to this report are listed in 

appendix IV.

Carol R. Cha, Acting Director

Homeland Security and Justice

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-13-204 Domestic Meth Labs 

Our objectives were to identify (1) trends in domestic meth lab incidents 

over the last decade and the impact of domestic meth labs on the 

communities affected by them; (2) the impact of electronic tracking 

systems on domestic meth lab incidents and the limitations, if any, of 

using these systems; and (3) the impact of prescription-only laws on 

domestic meth lab incidents and any implications of this approach for 

consumers and the health care system.

To identify the trends in domestic meth lab incidents over the last decade, 

we obtained and analyzed data for all states from the Drug Enforcement 

Administration’s (DEA) National Seizure System (NSS) data on nearly

149,000 lab seizure incidents that occurred during the last 10 calendar 

years, 2002 through 2011.1

To identify key factors that influenced lab seizure incident trends over 

time, we obtained the perspectives and information on meth lab incident 

trends and factors influencing this trend from state and local officials we 

interviewed in states that were selected as case studies. This 

nonprobability sample of states was selected to reflect a mix of 

characteristics such as the type of approach chosen for controlling the 

Using these data, we analyzed the number of 

incidents nationally and by region and by type of lab (i.e., P-2-P, 

Nazi/Birch and One Pot, or Red Phosphorus) and lab capacity. To assess 

the reliability of these data, we discussed the sources of the data with 

agency officials knowledgeable about the data to determine data 

consistency and reasonableness and compared them with other 

supporting data and documentation, where available, from states selected 

to be case studies for this review. As reporting by state and local law 

enforcement agencies of lab incidents to DEA is voluntary except when 

DEA provides funds to the agencies for lab cleanup, because of the 

exhaustion of DEA’s cleanup funds less than half way through fiscal year 

2011, the number of lab incidents reported for 2011 could be biased 

downward as compared with the number of incidents in previous years. 

We discussed this issue and its potential implications with DEA officials 

that manage the collection of the data and the steps they have taken to 

address it. From these efforts and discussions, we determined that the 

data were sufficiently reliable for the purposes of this report.

 

1

According to DEA officials, records of incidents can be updated within the NSS or new 

records added as new data and information becomes available or is submitted. 

Consequently, the number of total number of incidents may vary over time. The data 

analyzed for this review were pulled from the NSS on October 1, 2012. 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-13-204 Domestic Meth Labs 

sale of pseudoephedrine (PSE) products (electronic tracking or 

prescription-only), length of time the approach has been in use, and the 

number of meth labs seized relative to the state’s population size. The 

states selected for inclusion as case study states included Iowa 

(electronic tracking), Kentucky (electronic tracking), Mississippi 

(prescription-only), Missouri (electronic tracking), Oregon (prescriptiononly), and Tennessee (electronic tracking). While we cannot generalize 

any findings or results to the national level from our sample of states 

visited for our case studies, the information from these states provided 

perspective on meth lab trends and the experiences of the states in 

implementing these approaches. We also reviewed drug threat 

assessments and reports by the National Drug Intelligence Center (NDIC) 

and information from officials with DEA and the Office of National Drug 

Control Policy (ONDCP). We reviewed the methodology of the 

assessments and reports and found them sufficiently reliable to provide 

perspectives on meth lab incident trends and factors influencing these 

trends. We obtained additional information and input regarding factors 

that contributed to meth lab incident trends from federal, state, and local 

officials participating in the May 2012 conference of the National 

Methamphetamine and Pharmaceutical Initiative (NMPI), a national 

initiative funded by ONDCP.

To determine the impact of domestic meth labs on the communities 

affected by them, we first reviewed a variety of reports and studies on 

meth labs and their impacts from sources such as the Department of 

Justice (DOJ), DEA, the RAND corporation, media reports, and published 

academic research to identify the particular areas or ways that 

communities are directly affected as a result of the presence of labs. On 

the basis of this review, we identified the key ways communities are 

impacted by meth labs. These included the provision of health care to 

meth lab burn victims, threats and dangers posed to the welfare of 

children, environmental damage, and increased demand and workload for 

law enforcement agencies. While there are other areas or ways that can 

be impacted by meth labs, such as treatment for health-related conditions 

related to meth abuse and the demand for addiction treatment, these 

impacts are caused by the abuse of both imported and domestically 

produced meth and are not impacts unique to meth labs. Therefore, we 

did not include those areas in our review. To describe impacts on health 

care providers to administer care to meth lab operators injured or burned 

by their labs, we reviewed and synthesized information from published 

academic research comparing the injuries and treatment provided to 

meth-lab-burn victims as compared with non-meth lab burn related 

patients, documentation from DOJ on meth labs, and media reports on 
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-13-204 Domestic Meth Labs 

the reported impacts of meth labs on hospital burn centers. We also 

interviewed the director of the burn center at the Vanderbilt University 

Hospital in Nashville, Tennessee, to get his perspective, as the center 

has treated a significant number of burn patients that received their 

injuries from a meth lab. To describe impacts of meth labs on child 

welfare, we reviewed and synthesized information from DOJ on drugendangered children, meth lab incident data from DEA on the number of 

children reported to be affected by the labs, and published academic 

research on the impact of meth abuse on the need for foster care. To 

describe environmental damage caused by meth labs, we reviewed and 

synthesized information from DOJ on the impact of meth labs, DEA’s 

guidance for meth lab cleanup, and a report from the DOJ Inspector 

General on DEA’s meth lab cleanup program. For context, we also 

obtained information from DEA on its clandestine lab cleanup program 

and the funds expended on the program to assist state and local law 

enforcement agencies in cleaning up meth labs from 2002 through 2011. 

In addition, we obtained and analyzed information from the case study 

states of Mississippi, Missouri, and Oregon on any funds state agencies 

spent on the cleanup of meth labs. To describe impacts of meth labs on 

law enforcement agencies in communities, we reviewed and synthesized 

information from DEA’s guidance for meth lab cleanup, documentation 

from DOJ on meth labs, as well as information from state and local law 

enforcement officials we interviewed from our case study states.

To determine the impact of electronic tracking systems on domestic meth 

lab incidents, we analyzed DEA NSS data on the number of meth lab 

incidents that were reported in the 3 states that have implemented 

electronic tracking the longest—Kentucky, Oklahoma, and Tennessee— 

from 2002 through 2011 to identify any trends in lab incidents that 

occurred within those states before and after the implementation of 

electronic tracking within those states. To examine the volume of PSE 

sales activities the national electronic tracking system monitors and 

blocks when necessary, we obtained and reviewed PSE purchase activity 

data (purchases, blocks, and exceedances) for 2011 and 2012 from 

Appriss, the software firm that developed and manages the software 

program MethCheck, which is used as the operational platform for the 

National Precursor Log Exchange (NPLEx), the interstate electronic 

tracking system paid for by manufacturers of PSE products. We chose 

this time period because those were the most recent years for which data 

from multiple states were available. To assess the reliability of these data, 

we discussed the data with Appriss officials. From these efforts and 

discussions, we determined that the data were sufficiently reliable for the 

purposes of this report. To understand how electronic tracking works in 
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-13-204 Domestic Meth Labs 

practice and the limitations of this approach, we obtained information from 

officials with Appriss as well as officials with state and local law 

enforcement and the High Intensity Drug Trafficking Areas (HIDTA) in our 

electronic tracking case study states of Iowa, Kentucky, Missouri, and 

Tennessee. For these state and local law enforcement officials, we 

utilized a snowball sampling methodology in which we initially contacted 

key law enforcement officials in those states involved in dealing with the 

meth lab problem who identified and provided contacts for other officials 

in those states to meet with. From these state and local law enforcement 

officials, we obtained information and their perspectives on the use of 

electronic tracking, its impact on the meth lab problem within their 

jurisdictions, and any potential advantages or limitations of the approach 

identified through their investigations and experience with the system to 

date. Although their perspectives cannot be generalized across the 

broader population of state and local law enforcement agencies in 

electronic tracking states, their perspectives provided insights into and 

information on the use and impact of the approach in practice and its 

limitations.

To determine the impact of prescription-only laws on domestic meth lab 

incidents and any implications of adopting this approach for consumers 

and the health care system, we analyzed DEA NSS data on the number 

of meth lab incidents that were reported in the prescription-only states of 

Mississippi and Oregon and their border states (Alabama, Arkansas, 

California, Idaho, Louisiana, Nevada, Tennessee, and Washington) from 

2002 through 2011 to identify any trends in lab incidents that occurred 

within those states before and after the implementation of the 

prescription-only approach. To determine the impact of the prescriptiononly approach on meth lab incidents in Oregon, we conducted a statistical 

modeling analysis of the lab incident data that controlled for other factors 

such as region of the country, ethnic composition of the state population, 

the proportion of the state population that is male, distance from the 

Mexican border, and the state drug arrest rate, among others. For more 

details on the methodology used for this analysis, see appendix III.

To determine the impact of the prescription-only approach in counties and 

localities in Missouri that have adopted the approach, we also obtained 

and analyzed information from local officials in Missouri on how meth lab 

incidents have been impacted since the adoption of the approach within 

their jurisdictions. To obtain the perspective of state and local officials on 

the impact of the implementation of the prescription-only approach in their 

states and localities, we utilized a snowball sampling methodology in 

which we initially contacted key law enforcement officials involved in 
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-13-204 Domestic Meth Labs 

dealing with the meth lab problem or associations representing law 

enforcement in Mississippi, Missouri, and Oregon who then identified and 

provided contacts of other officials within their states for us to meet with. 

We interviewed these officials to obtain their perspectives on the impact 

of the prescription-only approach on the meth lab problem as well as the 

perceived impacts on other areas, where possible, such as the demand 

for law enforcement, child welfare, environmental cleanup, and the 

trafficking of meth within their states. Although their perspectives on these 

impacts cannot be generalized across the broader population of state and 

local law enforcement agencies in prescription-only states, their 

perspectives provided insights into and information on the impact of the 

approach in practice. To determine the extent to which individuals in 

prescription-only states have been traveling to neighboring states to 

obtain PSE product without a prescription or have diverted PSE product 

obtained with a prescription, we interviewed and obtained information 

from local law enforcement officials in Mississippi, Missouri, and Oregon 

on what they have found in their investigations into meth labs and PSE 

smurfing. We also obtained and reviewed NPLEx data on PSE purchase 

activity from Appriss for PSE purchases made in Washington state with 

identifications issued by Oregon from October 15, 2011, to the most 

recent full month available (August 2012). We chose the starting date of 

October 15, 2011, because that was the date that Washington state 

implemented the NPLEx system statewide.

To gauge the extent of PSE sales made in other states neighboring 

Oregon (California, Idaho, and Nevada) to individuals using identifications 

issued by Oregon that had not implemented NPLEx but had retailers 

within the states that used the NPLEx MethCheck software program, we 

obtained and reviewed the MethCheck log data on PSE purchase activity 

for those states for the same October 15, 2011, to August 2012 time 

period. For Mississippi, we obtained and reviewed NPLEx data on PSE 

purchase activity for purchases made with identifications from Mississippi 

in the NPLEx states neighboring Mississippi (Alabama, Louisiana, and 

Tennessee) between the time those states joined NPLEx to July 2012.2

 

2

The dates these states joined NPLEx were: Alabama, January 1, 2011; Louisiana, June 

15, 2010; and Tennessee, January 1, 2012.

To determine the impact of the prescription-only approach on consumers 

in Mississippi, we obtained data from IMS Health Inc. through DEA on the 

volume of PSE sales for three 52-week periods ending in December 
Appendix I: Objectives, Scope, and 

Methodology

Page 50 GAO-13-204 Domestic Meth Labs 

2009, 2010, and 2011 and analyzed the data for any changes in volume 

over time, comparing the 2010 and 2011 periods when the prescriptiononly approach was in effect with the 2009 period when it was not. To 

assess the reliability of the data, we reviewed documentation and 

information from IMS Health officials knowledgeable about the data to 

determine data consistency and reasonableness. From these reviews, we 

determined that the data were sufficiently reliable for the purposes of this 

report. Because data prior to the period Oregon implemented the 

prescription-only approach in 2006 were not available, we were not able 

to do a similar analysis for Oregon.

To examine the number of prescriptions filled in Mississippi for PSE 

medications, we obtained and reviewed data provided by the Mississippi 

Board of Pharmacy’s Prescription Drug Monitoring Program. To assess 

the reliability of the data, we discussed the data with officials that manage 

the program. From these efforts and discussions, we determined that the 

data were sufficiently reliable for the purposes of this report. To obtain 

additional information on the reported and estimated impacts of the 

prescription-only approach on consumers and the health care system, we 

reviewed a report of the potential impacts of the prescription-only 

approach prepared for the Consumer Healthcare Products Association

(CHPA). To help obtain perspective on the potential impact on 

consumers, we asked the state boards of pharmacy and state 

associations representing pharmacists in Mississippi and Oregon, such 

as the Oregon State Pharmacists Association, about the extent to which 

complaints may have been made by consumers about the prescriptiononly approach. We also asked the National Consumers League and the 

Asthma and Allergy Foundation of America if they had received feedback 

or complaints from consumers on the impact of the prescription-only 

approach. We chose these organizations because they have previously 

surveyed consumers about access to PSE products. 

To understand the prescription-only approach’s impact on the workload 

demands for physicians, we obtained the perspective of state 

associations representing physicians practicing in Oregon and 

Mississippi, such as the Oregon Medical Association and the Mississippi 

State Medical Association, on the extent to which their members have 

reported seeing an increase in demand for appointments for PSE 

prescriptions and any corresponding increase in their workload. While 

their perspectives cannot be generalized to the larger population of 

physicians in these states, they provided insights into the impact of the 

approach on their members’ practices. To determine the impact of the 

prescription-only approach on the Medicaid programs within Mississippi 
Appendix I: Objectives, Scope, and 

Methodology

Page 51 GAO-13-204 Domestic Meth Labs 

and Oregon, we obtained perspectives and information from Medicaid 

program officials in those states on what, if any, changes the approach 

required of their prescription formulary and any resulting changes in 

program costs.

We conducted this performance audit from February 2012 to January 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: State Level Data on Meth Lab 

Incidents, 2002 through 2011

Page 52 GAO-13-204 Domestic Meth Labs 

 State 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Total

Alabama 343 524 803 529 273 249 624 673 719 293 5,030

Alaska 35 54 120 66 20 7 18 13 22 5 360

Arizona 294 260 221 138 48 23 34 24 18 5 1,065

Arkansas 646 1,171 1,361 701 450 380 418 671 824 308 6,930

California 1,764 1,303 855 510 444 307 398 301 206 122 6,210

Colorado 527 523 419 274 136 72 62 48 32 13 2,106

Connecticut 2 1 0 4 3 0 1 2 1 0 14

Delaware 0 2 3 1 0 0 1 1 3 2 13

District of Columbia 0 0 1 0 0 0 0 0 1 1 3

Florida 188 319 438 470 202 186 214 415 526 161 3,119

Georgia 224 440 547 433 191 118 197 217 332 141 2,840

Hawaii 12 5 17 18 4 1 0 0 3 0 60

Idaho 134 121 75 35 23 23 14 17 19 8 469

Illinois 711 1,084 1,582 1,430 863 399 379 416 476 637 7,977

Indiana 753 1,046 1,384 1,506 838 815 739 1,328 1,243 1,437 11,089

Iowa 925 1,473 1,687 914 364 198 241 336 380 413 6,931

Kansas 792 705 650 417 194 101 161 184 241 202 3,647

Kentucky 388 516 622 616 336 310 442 743 1,359 1,758 7,090

Louisiana 146 136 178 144 28 54 45 163 218 70 1,182

Maine 0 0 4 5 5 1 4 1 4 5 29

Maryland 1 2 3 5 7 2 2 0 3 1 26

Massachusetts 2 2 2 8 3 4 3 3 2 2 31

Michigan 264 376 461 511 290 212 456 716 866 438 4,590

Minnesota 336 483 288 169 69 48 46 31 27 9 1,506

Mississippi 527 459 561 359 299 182 440 960 937 321 5,045

Missouri 2,765 2,897 2,924 2,340 1,326 1,292 1,520 1,810 1,979 2,114 20,967

Montana 104 131 107 36 13 10 10 18 21 11 461

Nebraska 373 294 327 287 35 30 67 40 27 19 1,499

Nevada 106 249 153 86 44 24 17 16 13 16 724

New Hampshire 1 2 2 9 6 3 1 7 8 15 54

New Jersey 3 1 3 4 6 1 4 0 1 0 23

New Mexico 170 305 226 103 52 45 73 67 64 21 1,126

New York 30 35 70 26 42 13 18 17 33 46 330

North Carolina 73 223 473 493 216 161 197 213 237 400 2,686

North Dakota 211 260 238 175 43 27 35 35 8 9 1,041

Appendix II: State Level Data on Meth Lab 

Incidents, 2002 through 2011
Appendix II: State Level Data on Meth Lab 

Incidents, 2002 through 2011

Page 53 GAO-13-204 Domestic Meth Labs 

 State 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Total

Ohio 141 227 535 669 375 232 260 344 381 364 3,528

Oklahoma 1,053 1,426 914 329 223 114 194 784 880 1,006 6,923

Oregon 614 584 632 232 67 43 48 17 21 11 2,269

Pennsylvania 31 65 138 101 65 18 24 44 39 9 534

Rhode Island 4 1 0 0 2 0 0 0 0 1 8

South Carolina 70 169 343 253 112 68 130 244 344 338 2,071

South Dakota 38 49 36 26 15 13 11 9 22 5 224

Tennessee 814 1,589 2,369 1,751 903 603 834 1,494 2,153 2,326 14,836

Texas 682 868 740 442 188 158 250 273 192 88 3,881

Utah 153 113 105 67 39 8 15 11 10 9 530

Vermont 0 0 1 2 0 2 0 0 4 0 9

Virginia 10 46 110 87 22 25 21 29 106 202 658

Washington 1,441 1,008 962 547 337 240 127 70 46 33 4,811

West Virginia 67 106 328 445 166 113 116 139 207 92 1,779

Wisconsin 95 128 110 80 33 7 16 27 45 41 582

Wyoming 68 36 27 13 6 9 6 0 11 2 178

Total 18,131 21,817 24,155 17,866 9,426 6,951 8,933 12,971 15,314 13,530 149,094

Source: DEA NSS.

Note: According to DEA officials, records of incidents can be updated within the NSS or new records 

added as new data and information becomes available or is submitted. Consequently, the number of 

total number of incidents may vary over time. The data presented above were pulled from the NSS on 

October 1, 2012.
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 54 GAO-13-204 Domestic Meth Labs 

We evaluated the impact of the prescription-only pseudoephedrine 

requirement on domestic production of methamphetamine separately 

using state-level data. We chose Oregon which implemented its 

prescription-only pseudoephedrine requirement in 2006. In order to 

evaluate the impact of the policy, we performed multivariate regression 

analyses using generalized estimating equations (GEE) to compare the 

trend in lab seizures, reported to DEA between 2002 and 2010. We 

compared the case study state with a selected group of control states 

using a method that improves upon the commonly used Difference-inDifferences (DD) estimation method. 1 We estimated robust standard 

errors for the DD coefficients by modeling the covariance structure in the 

GEEs. In addition to estimating a DD model, we, alternatively, estimated 

the intervention effect by comparing the case state to a single synthetic 

control using the synthetic control methods in comparison case studies 

following Abadie and colleagues2 and Nonnemaker and colleagues.3

These models are described in detail below.

All data were annual state-level characteristics from 2001 through 2011 

taken from multiple sources.

4

 

1

Bruce Meyer, ”Natural and Quasi-Natural Experiments in Economics” Journal of 

Business and Economic Statistics. JES Symposium on Program and Policy Evaluation, 

.vol.13(2) (2000):151-161. 

Each observation in the data represented a 

state for a given year between 2002 and 2011. Some factors were lagged 

1 year to account for a deterrent effect and to impute data missing for a 

later year. Eleven states were excluded from the final analyses as 

potential controls because they had implemented policies early in the 

postintervention period or because they were missing data on a key 

covariate; they include Arkansas, California, Hawaii, Kentucky, Louisiana, 

Iowa, Illinois, Tennessee, Oklahoma, Oregon, Mississippi, and Florida. 

2

Alberto Abadies, Alexis Diamond, and Jen Hainmueller, “Synthetic Control Methods for 

Comparison Case Studies: Estimaing the Effect of California’s Tobacco Control Program.” 

American Statistical Association. June 2010. vol. 105. (490): 493-505.

3

James Nonnemaker, Mark Engelen, and Daniel Shive, “Are Methamphetamine Precursor 

Control Laws Effective Tools to Fight the Methamphetamine Epidemic?” Health 

Economics. vol. 20 (2000):519-531.

4

We would like to acknowledge Monica Wade and Creston Dalmadge at Winston-Salem 

State University for sharing their dataset with us for the preliminary analyses. All data 

used for this report come from the original sources.

Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents 

Evaluation of the 

Impact of 

Prescription-Only 

Requirement 

Data
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 55 GAO-13-204 Domestic Meth Labs 

Variables included in the analysis were similar to those controlled in other 

studies on the impact of precursors.5

Outcome variables: We modeled two outcome variables: the total lab 

seizure rate per 100,000 population and the small toxic lab seizure (STL) 

rate per 100,000 population. Small toxic labs are defined as labs with a 

capacity of 1 pound or less. Data on methamphetamine seizure incidents 

from the National Seizure System maintained by Drug Enforcement 

Administration’s El Paso Intelligence Center (DEA EPIC) were 

aggregated to get the number of methamphetamine lab seizures per state 

per year.6

Other factors were controlled in this model. The control variables included 

the following

The rates were computed using the Census annual population 

estimate as a denominator multiplied by 100,000. It is expressed as the 

rate per 100,000 people. The rates were transformed by taking the log 

base 10 to approximate the normal distribution required for a linear 

model.

7

• Client rate: The rate of substance abuse clients reported annually into 

the Substance Abuse and Mental Health Services Administration 

: 

 

5

For examples of peer-reviewed articles studying the impact of methamphetamine 

precursor restrictions, see James K. Cunningham, Jane Carlisle Maxwell, Octavio 

Campollo, Kathryn I. Cunningham, Lon-Mu Liu, and Hui-Lin Lin. “Proximity to the US–

Mexico border: A Key to Explaining Geographic Variation in US Methamphetamine, 

Cocaine and Heroin Purity,” Addiction 105 (2010): 1785-1798; James K. Cunningham, , 

Russell C. Callaghan, Daoqin Tong, Lon-Mu Liu, Hsiao-Yun Li, and William J. Lattyak. 

“Changing Over-the-Counter Ephedrine and Pseudoephedrine Products to Prescription 

Only: Impacts on Methamphetamine Clandestine Laboratory Seizures,” Drug and Alcohol 

Dependence 126 (2012): 55-64; James K. Cunningham, Lon-Mu Liu, and Myra Muramoto. 

“Methamphetamine Suppression and Route of Administration: Precursor Regulation 

Impacts on Snorting, Smoking, Swallowing and Injecting,” Addiction 103 , (2008): 1174-

1186; and James Nonnemaker, Mark Engelen, and Daniel Shive, “Are Methamphetamine 

Precursor Control Laws Effective Tools to Fight the Methamphetamine Epidemic?” Health 

Economics 20 (2010):519-531.

6

Methamphetamine seizure incidents were not completely captured by the NSS. 

Throughout 2012, EPIC added more than 30,000 new incidents from the HAZARD system 

into NSS. These incidents occurred in the period 1998 through 2012. The data for our 

analysis was extracted on Oct. 10, 2012. These data reflect all but 824 incidents that had 

not been reconciled between the two systems. 

7

The rate of treatment admissions from the Treatment Episode Data Set (TEDS) was 

considered as an additional control, but we decided to exclude it because of many missing 

data points in the series.
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 56 GAO-13-204 Domestic Meth Labs 

through the National Survey of Substance Abuse Treatment Services 

(N-SSATS) per 100,000 people. This factor is lagged 1 year to 

account for the possibility that the number of substance abuse clients 

has more of an impact on the future number of labs seized than the 

current number of labs. Lagging these data also allows us to make up 

for unavailable data in 2011. The client rate is not available for 2002. 

The 2001 value is used to impute that value.

• Region: Regional factors are expected to affect the methamphetamine 

problem and domestic production. We cannot identify or control for all 

of the potential factors that influence lab seizures for the region, so we 

include a set of dummy variables indicating the census division to 

approximate the potential influence of regional factors. Divisions 

include the following:

1 = New England

2 = Middle Atlantic

3 = East North Central

4 = West North Central

5 = South Atlantic

6 = East South Central 

7 = West South Central

8 = Mountain

9 = Pacific (referent category).

• Demographics: Some demographic groups are more likely to use 

methamphetamine than other groups. We controlled for the 

demographic composition of the state population to account for 

potential demand for the drug. The percentage of the population that 

is non-Hispanic white, male, Hispanic, and under age 18 were

computed annually for each state from Census intercensal population 

estimates.

• Distance to Mexico: The approximate number of miles between the 

state and the nearest Mexican border city was taken from 

Cunningham et al. (2010)8

 

8

See figure 1 on page 1787. 

. The number of miles were included as a 

set of categories with the farthest distance (1,800 miles) as the 

reference category. This variable attempts to account for the supply of 

imported methamphetamine on domestic production.
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 57 GAO-13-204 Domestic Meth Labs 

• Funding: The Community Oriented Policing Services (COPS) funding 

amount from DEA was adjusted to 2012 dollars using the Consumer 

Price Index and divided by 1,000 to adjust the scale of the dollar 

amounts. This variable controlled for law enforcement activity specific 

to methamphetamine lab cleanups. It also helped to adjust for a 

possible downward bias in the 2011 reporting because of a 

discontinuation of COPS funding for a portion of that year.

• Police: The presence of police was measured as the annual number 

of employed law enforcement officers as a percentage of the total 

population. Police data came from the Uniform Crime Report (UCR) 

Law Enforcement Officers Killed in Action (LEOKA) data set. This 

factor was lagged 1 year to account for the possibility that the 

presence of police has a deterrent effect on the future number of labs 

seized. Lagging these data also allowed us to make up for unavailable 

data in 2011.

• Arrests: The drug arrest rate was measured as the number of drug 

arrests (UCR offense code 18) per 100,000 population. The data 

come from the Uniform Crime Reporting Program Data: Arrests by 

Age, Sex, and Race, Summarized Yearly. Data for Florida were not 

reported in this data set. This factor was lagged 1 year to account for 

the possibility that the number of drug arrests has a deterrent effect 

on the future number of labs seized. Lagging these data also allowed 

us to make up for unavailable data in 2011.

While recent analyses of methamphetamine precursor laws have used 

relatively similar parsimonious models, our model may still be 

underspecified. For example, we did not control for alternative drug use.

The DD model is a regression model that compares over time the 

outcomes for a unit of analysis that has been exposed to a treatment or 

intervention (referred to as a case) with the outcomes of at least one unit 

that has not been exposed to the treatment or intervention (referred to as 

a control). The case is exposed to the intervention at some point after the 

first period of time; the control is never exposed to the intervention during 

the course of the study. The impact of the intervention is represented by 

the difference in differences. In this case there are two differences. The 

first difference is between the average outcomes of the case and the 

control, respectively, in the post-intervention period and the 

preintervention period. The second difference subtracts the control 

Difference-inDifferences 

Estimation Model
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 58 GAO-13-204 Domestic Meth Labs 

difference between the two periods from the case difference. It can be 

written as equation 1.

EQ. 1: DD = (y-bar Case,post- - y-bar Case,pre-) - (y-bar Control,post- - y-bar Control,pre-) 

For a DD model, the data consist of one observation for each geographic 

unit, which is represented by subscript i and each unit of time which is 

represented by subscript j. In our analysis, each observation represents a 

state in each year from 2000 through 2010. Since the interventions were 

implemented in 2006, the preintervention period spans 2000 through 

2006. The post period spans 2007 through 2010. A dummy-variable9

EQ. 2: Yij= β0+ β1Post-Intervention Dummy + β2Oregon+ β3Post-Intervention 

Dummy*Oregon + β4Time+ β5Xij +εij

indicating the postintervention period is specified; therefore, our DD 

model takes the form:

Where Yij is the outcome for state i at period j; β0 is the intercept term; β1

is the coefficient on the postintervention period dummy variable; β2 is the 

coefficient on the Oregon dummy variable; β3 is the coefficient on the 

interaction term between Oregon and the postinteraction period dummy 

variable; β4 is the coefficient on the time variable; β5 is the set of 

coefficients on the set of control variables; and εij is the error term.

This analysis primarily seeks to reliably estimate the coefficient β3. This

estimate indicates the average amount of impact the prescription-only 

policy implemented in 2006 had over the period 2007 through 2010. This 

estimate will allow us to say the extent to which each policy contributed to 

the change in domestic methamphetamine lab seizures after controlling

for other factors.10

DD estimation has some known limitations described in the academic 

literature. Beasley and Case (2000) describe the endogeniety of 

interventions, i.e., the fact that policies are made in response to the same 

conditions that lead to the outcome. Heckman (2000) and Bertrand and 

 

9

Dummy variables are also called indicator variables. They are used to indicate the 

occurrence or presence of a concept. They take the value of 1 when the thing occurs and 

the value of 0 otherwise.

10The control variables are described in the data section of this document.
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 59 GAO-13-204 Domestic Meth Labs 

colleagues (2004) showed that because of serial correlation in the 

outcomes over time, difference-in-differences models tended to 

underestimate the standard error of the intervention coefficient and 

therefore overestimate the test statistic, leading to the interpretation of 

statistically significant differences between the case and control units. 

Abadie and colleagues (2010) argue that the selection of control units are 

made on the basis of subjective measures of affinity between case and 

control units and that there is uncertainty in the control units’ ability to 

produce the counterfactual outcome trend that the case would have 

experienced if the intervention has not taken place. This is an additional 

source of uncertainty beyond that measured by the standard error. We 

attempt to address these limitations in the analysis.

To account for autocorrelation, we implemented this model using 

Generalized Estimating Equations (GEE) in SAS Proc Genmod with a 

repeated statement specifying the compound symmetry covariance 

structure to account for the autocorrelation in the covariates across time 

periods for each state. The covariance structure was determined by 

examining the working correlation matrix estimated when specifying an 

unstructured covariance structure and by comparing the quasi-likelihood 

indicator criteria (QIC) statistics for models specifying five different 

covariance structures: independence, compound symmetry, first-order 

autocorrelation, unstructured, and 1-dependent. The unstructured 

covariance structure allows for correlations to be different in each 

comparison of times without any specific pattern. The unstructured 

working correlation matrix indicated high constant correlation over time. 

Since the correlations seem constant, a compound symmetry structure is 

more appropriate.

 The QIC values for the GEE models were similar with the independent, 

compound symmetry, and autocorrelation structures specified, but the 

QIC was usually lowest for the independence structure with 

autoregressive next. This indicates that those structures fit the model 

better. Independence in the measures across time is not a logical 

assumption given the nature of the data, and the structure of the 

correlation matrix specified by the unstructured covariance structure does 

not show declining correlations over time described in the autoregressive 

structure. The QIC supports our choice of a compound symmetry 

covariance structure.
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 60 GAO-13-204 Domestic Meth Labs 

We validated our model findings using the synthetic control method. The 

synthetic control method introduced by Abadie and colleagues (2010) is a 

modification on the DD method that creates a data-driven synthetic 

control that represents the counterfactual of the case in the absence of 

the intervention. The synthetic control method has two advantages. It 

allows for transparency and objectivity in the selection of control. It also 

safeguards against extrapolation of the counterfactual by creating the 

synthetic control to match the case closely in the pre-intervention period.

We implemented the synthetic control method in Stata using the synth 

ado program.11 The program uses the set control states to create a 

synthetic form of the case study state by weighting the control states. The 

treated and synthetic control states are matched on the outcome and any 

combination of covariates in the preintervention period so that the mean 

squared error of the prediction variables is minimized. Then the model 

interpolates the trajectory of the synthetic state over the postintervention 

period assuming that the intervention was not implemented. In preliminary 

analyses, we tested the robustness of the model matching the state and 

synthetic controls on the outcomes alone and on the outcomes and all 

covariates controlled in the GEE models. All results presented here are 

based on a model matching on the outcome and most covariates 

controlled in the GEE models.12

 

11Alberto Abadie, Alexis Diamond, and Jens Hainmueller. "Synth: An R Package for 

Synthetic Control Methods in Comparison Case Studies." Journal of Statistical Software.

vol 42(13) (2011):1-17. We would like to acknowledge Jens Hainmeuller who assisted us 

in our verification of the Stata program.

The synthetic control method does not 

generate a simple test statistic to determine whether the difference 

between the case study and synthetic control state is statistically 

significant. To test whether the results are likely to be found by chance in 

Oregon, we ran the model assigning Oregon’s neighboring states that 

met our criteria for inclusion as controls (Washington, Idaho, and Nevada) 

as the case study state and allowed the model to generate a synthetic 

control to compare what would have happened relative to the experience 

in each of those states. If the results were found to be similar to Oregon’s, 

then we could not dismiss the possibility that our findings for Oregon were 

due to chance.

12The regional division was not included as a covariate for matching to allow the model to 

select controls from across the country. The arrest rate was not included as a covariate 

because the pattern of missing data across the series made that variable incompatible 

with the Stata program.

Synthetic Control 

Method 
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 61 GAO-13-204 Domestic Meth Labs 

Prescription-only had significant impacts on lab seizure rates compared 

with a selected group of controls. Contrary to the findings in Cunningham 

et al. (2012)13 and Strauberg and Sharma (2012)14

Our analysis differs from the two recent studies cited above in the 

methodology, including the analytical approach and model specification, 

and the date on which the incident data were pulled.

, our analysis found 

that lab seizure rate fell by more than 90 percent in Oregon after the 

prescription-only requirement was implemented after adjusting for other 

factors. While 90 percent seems very high, the estimate should be 

considered in the context that the rate has been declining and was 

relatively low before the policy was implemented. The impact of the 

prescription-only requirement was validated when the case study state 

was compared with an empirically generated synthetic control. The 

synthetic control method confirmed the direction of the impact in Oregon. 

Our placebo analysis that assigned Oregon’s neighbor states as the 

control state showed that the reductions seen in Oregon were not 

projected in those states, giving some indication that the Oregon 

reduction was not found by chance. We cannot determine the extent of 

the impact using the synthetic control method because of the poor fit of 

the model in the period prior to the policy’s implementation.

15

 

13James K. Cunningham, Russell C. Callaghan, Daoqin Tong, Lon-Mu Liu, Hsiao-Yun Li, 

and William J. Lattyak. “Changing Over-the-Counter Ephedrine and Pseudoephedrine 

Products to Prescription Only: Impacts on Methamphetamine Clandestine Laboratory 

Seizures,” Drug and Alcohol Dependence 126 (2012): 55-64. 

14Christopher Stomberg and Arun Sharma, Making Cold Medicine Rx-Only Did not 

Reduce Meth Use. (Portland, OR: Cascade Policy Institute, February 2012). 

15Our data were pulled in October 2012, following the publication of these reports. 

Important changes in the number of seizures covered in the data are described in the data 

section. Cunningham et al. used an Autoregressive Integrated Moving Average (ARIMA) 

with quasi control by comparing the trend in monthly seizure counts in Oregon and 

Mississippi compared to seizure counts in their neighbor states.(See Cunningham, 

Callaghan, Tong, Liu, Li, and Lattyak. “Changing Over-the-Counter Ephedrine and 

Pseudoephedrine Products to Prescription Only” 55-64.). Stromberg and Sharma 

estimated a DD model, but specify it with the outcome variable measured as an index and 

control only regional and temporal trends. (See Stomberg and Arun Sharma, Making Cold 

Medicine Rx-Only Did not Reduce Meth Use. 

Results 
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 62 GAO-13-204 Domestic Meth Labs 

The key finding from the GEE model is the coefficient on the interaction 

between the case study state and the postintervention period indicators. 

Since the outcome data were transformed to improve the model fit, we 

back-transformed the coefficients for ease of interpretation.16

Table 5: Methamphetamine PSE Restriction Policy Impact on Lab Seizure Rates per 100,000 Population Estimated from 

Difference-in- Difference

Four 

estimates are presented in Table 5. They represent the model 

specifications. Each group of covariates was modeled on the two 

outcomes described above: the lab seizure rate including all capacities 

and the small toxic lab seizure rate. The unadjusted model adjusts only 

for the policy, state, time effects, and the interaction between the case 

study state and the postintervention period indicators. The adjusted 

model adjusts for those factors and controls all covariates described 

above. The unadjusted impacts are interpreted as the percent change in 

the rate resulting from the implementation of the policy adjusting only for 

temporal factors. Adjusted factors are interpreted as the percent change 

in the rate resulting from the implementation of the requirement after 

controlling for other factors that may also affect the change in the seizure 

rate. Impacts are determined to be statistically significant if the p-value is 

less than 0.05.

Unadjusted Adjusted for other factors

All lab seizures Small toxic labs All lab seizure Small toxic labs

Policy

impact P-value

Policy 

impact P-value

Policy 

impact P-value

Policy 

impact P-value

Oregon 

prescription-only -98.72 0 -98.53 0 -97.40 0 -97.01 0 

Source: GAO analysis.

Note: Statistical significance is indicated by a p-value of 0.05 or lower

The key finding from the synthetic control model is the difference in the 

estimated lab seizure rate in the years after 2006 between the case study 

state and the synthetic control. Differences in the postintervention period 

 

16Back transformation is preferred for precise interpretation of the results. See GAO, 

Women's Pay: Gender Pay Gap in the Federal Workforce Narrows as Differences in 

Occupation, Education, and Experience Diminish, GAO-09-279 (Washington, D.C.: March 

17, 2009). Since we used the log base 10 transformation, the back transformation is 10beta 

instead of ebeta, which is denoted in the GAO report referenced here.

Interpretation of 

Results 
Appendix III: Statistical Model Analysis of the 

Prescription-Only Requirement on Meth-lab 

Incidents

Page 63 GAO-13-204 Domestic Meth Labs 

can be attributed to the impact of the policy when the two match closely in 

the preintervention period. Since the states did not always have a close 

match in the preintervention period and the model does not generate a 

test statistic to indicate whether the differences between the case study 

and synthetic control are statistically significant, we do not present 

numerical results indicating the size of the impact of the policy from this 

analysis; instead we used the results to validate the direction of the 

findings of the GEE models. 
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 64 GAO-13-204 Domestic Meth Labs 

Carol R. Cha (202) 512-4456 or chac@gao.gov

In addition to the contact named above, Kirk Kiester (Assistant Director), 

Charles Bausell, Rochelle R. Burns, Willie Commons III, Yvette GutierrezThomas, Michele C. Fejfar, Christopher Hatscher, Eric Hauswirth, Eileen 

Larence, Linda S. Miller, Jessica Orr, and Monique Williams made 

significant contributions to the work.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(441017)
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