Preliminary Assessment Procedures

After law enforcement has classified a property as being contaminated from illegal drug operations, the owner of the property or a decontamination specialist must perform certain preliminary assessment procedures before cleanup of the property can begin. This preliminary assessment is necessary to determine the nature and extent of both chemical contamination and physical damage to the property. This initial assessment is meant to help ensure the safety of those working on the property. Chemicals that may pose an immediate threat to human health or damage to the environment may be removed from the property before a complete work plan for decontamination is developed. Many meth labs are discovered by law enforcement after a fire or explosion has occurred on the property. Such a fire or explosion could potentially compromise the structural integrity of the property making it unsafe. In such cases, the owner of the property or the decontamination specialist needs to obtain a structural assessment of the property before beginning the preliminary cleanup assessment.

As defined by the Rule, there are several aspects that must be performed by the owner or decontamination specialist:

- obtain and review copies of any report that describes the illegal drug activity at the property. These reports may be from law enforcement agencies, and state or local agencies and may be beneficial in determining what chemicals and/or hazards may be present on the property.
- evaluate all information obtained regarding the nature and extent of both damage and contamination.
- determine which method was used in the production of illegal drugs. For example, there are three main methods used to generate meth, each of which uses a different set of hazardous chemicals. Knowing which method was used on the property will allow the property owner and/or cleanup specialist to have a better idea which chemicals may be contaminating the property.
- determine the chemicals used on the property. In order to know which safety precautions will be necessary during cleanup, it is important to know the identity and, if possible, the amount of each chemical used and remaining on the property.
- determine the specific locations of drug manufacture, drug use, chemical storage, and chemical disposal. There may be multiple locations within the property with differing contaminants. Certain contaminant concentrations will be highest in regions near the "cook" site. Meth residues from drug use may be at another location within the property site. Chemical storage and disposal locations may be at yet another location or locations on the property.
- use all available information to delineate areas highly suggestive of contamination. Reports from law enforcement and other agencies may describe where operations took place, where chemicals were stored, etc. This areas are the most likely to have chemical contamination.
- develop procedures to safely enter the property in order to conduct a preliminary assessment. Decontamination specialists and other workers need to determine the risks of entering a property based on physical risks such as a building that may have been damaged by fire or explosions. Workers also need to be properly prepared for inhalation and dermal exposure to chemicals. Meth labs may also pose risks due to unsanitary conditions such as human waste. Needles from drug use may also pose a biohazard to workers entering the property.
- wear appropriate personal protective equipment (PPE). What is considered appropriate equipment will vary from site to site. Based on the levels and nature of contamination, some contaminated properties may require gloves, thick boots, goggles, body suits, and respiratory equipment. Some sites may only require basic safety gear.
- visually inspect all portions of the property that may have been impacted by illegal drug production. This should include all indoor surfaces, outdoor surfaces, and trash piles. Particular attention should be paid to areas that have stained surfaces, areas where drug production and chemicals were stored, known areas of drug use, burn pits and trash piles, and areas where chemicals may have been disposed such as drains and outside soils.
- determine if the property contains a septic system. Hazardous chemicals may have been disposed of in the septic system. This contaminates not only the septic system itself, but may also affect nearby soils and groundwater. Such contamination may require environmental sampling and cleanup.
- determine the location of the ventilation system and components that may have been contaminated. Air vents near a meth cook may be contaminated along with any connecting ducts leading to other areas of the property.
- test for corrosive, flammable, combustible, and toxic atmospheres upon initial entry to contaminated property. All results should be documented. Testing may involve the use of instruments such as a Lower Explosive Limit/Oxygen (LEL/O2) meter, pH paper, Photo Ionization Detector (PID), Flame Ionization Detector (FID), and other appropriate equipment. This testing is useful in determining the safety conditions of the site and which hazardous chemicals may be present.
- if there is a lack of supporting evidence suggesting that the property is contaminated, confirmation samples will be taken to show that the property does not require further decontamination efforts in order to be in compliance with the rule. Confirmation sampling procedures and decontamination standards are described in section R392-600-6 and later in this document.

A preliminary assessment may show that the property is not contaminated as determined by the standards described in section R392-600-6 of the Rule. If all chemical concentrations are below the required values, the owner of the property or the decontamination specialist may submit to the local health department that the property be removed from the list of contaminated properties. This requires that a final report documenting the preliminary assessment is submitted to the local health department. If the local health department agrees with the suggestions of this report, that the property is not contaminated, the property will be removed from the list of contaminated properties.

If, however, the preliminary report does suggest the presence of contamination, the owner or decontamination specialist will then proceed with the procedures outlined in sections R392-600-4 through R392-600-7 of the Illegal Drug Operations Decontamination Standards rule. The contaminated areas of the property must than be kept secure against un-authorized access until all of the following have been completed:
            - the work plan has been submitted
            - required permits have been obtained from the proper authorities
            - and the property has been decontaminated according to the standards of the rule.