New Standards for Clandestine Labs Provincial Advisory Group on Marijuana Grow Operations and Crystal Methamphetamine Laboratories
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1 New Standards for Clandestine Labs Provincial Advisory Group on Marijuana Grow Operations and Crystal Methamphetamine Laboratories Stephen Booth (Consulting Rep) Pinchin Environmental Richard Quenneville (OHAO rep) T. Harris Environmental Management Inc. T. Harris Environmental Management Inc. Environmental Consultants Since 1979 Your Environmental Solution is THEM
2 History of PAG Fire Marshall s Office Formed Provincial Advisory Group on Marijuana Grow Operations and Crystal Methamphetamine Laboratories (formerly the Green Tide Action Group) 2003 MGO in school zones Not only policing problem Social, economic, environmental, public health and safety Recommended broad base process
3 Provincial Advisory Group Planned outputs: Changes to legislation, Building Code, Municipal Act, City of Toronto Act, Residential Tenancies Act Advisories to fire, police, municipalities, etc. Recommended protocols for notification, OH&S precautions, assessment and remediation
4 PAG Stakeholders Banks, Credit Unions and Mortgage Holders Contractors Environmental Response Companies Family & Children Services Fire, EMS, OFM and Police General Public Home Appraisers and Inspectors Justice System Landlord Associations Municipalities and Associations Property, Title and Mortgage Insurers Provincial Government Real Estate Boards and Associations Utilities and their respective Standard Setting Bodies
5 PAG Task Forces Six Task Forces created under and reporting to PAG: 1. Commercial 2. Legislative and Judicial 3. Research and Analysis 4. First Responders 5. Inspection and Remediation 6. Registry of Properties
6 Inspection and Remediation Identify and recommend strategies to address safe inspections and remediation of properties (guidelines) application of legislation or bylaws cost recovery training and education qualifications for environmental professionals and remediation contractors Other topics as identified by PAG
7 Protocol Breakout Group to PAG Inspection & Remediation Task Force Developed Draft MGO Environmental Assessment & Remediation Protocol (EARP) January 24, 2010 Currently working on similar protocol for clandestine drug labs.
8 2010 MGO Protocol
9 Small Scale Grow Operations Dozens of Plants
10 Large Scale Grow Operations, 1900 Plants, $2M
11 Large Scale Well Planned and Executed
12 Marijuana Grow Operation Small Scale
13 Assessment Qualified Assessor 1. Assessment to be performed by investigator with appropriate science or engineering degree, qualified by experience and training, and minimum 2 years experience in mould assessment. 2. ESA requires CIH, ROH, or P.Eng. with masters degree in occupational hygiene.
14 Assessment 1. Property secure, police reports, power? 2. No mould air samples unless absolutely certain no mould growth. 3. Inspect the attic, for condensation mould growth from venting. 4. Inspect all finishes for water damage. Check current moisture levels. Destructive Testing. 5. Limited bulk sampling for mould. 6. Check for pesticides, fertilizers, including in drains and traps. 7. Analysis ISO accredited laboratory (CALA, NVLAP and/or AIHA programs).
15 Abatement Recommendations 1. Abatement plan, prepared by competent professional. 2. Mould cleaning shall follow methods of Environmental Abatement Council of Ontario. 3. Abatement of attic mould growth consider options. 4. Asbestos disturbance must follow O. Reg. 278/ Lead paint, follow Ministry of Labour guideline. 6. Mercury, dispose of as hazardous waste. 7. Pesticide or chemical staining, detergent cleaning, encapsulate if necessary. Remove porous materials with persistent staining. 8. Clean HVAC systems including ductwork.
16 Post Abatement Assessment Inspection 1. Should be performed by investigator who previously inspected the property 1. The required scope of work has been completed. 2. All accessible surfaces free of dust and debris. 3. Surfaces are sufficiently dry to prevent mould growth. 4. HVAC and ductwork are clean.
17 Post Abatement Assessment Air Sampling 1. Spore trap mould air samples from all levels of the structure, including attics, basement, crawlspaces, attached garage. Compare indoor to outdoor, consider water damage indicator moulds. One per floor in open concept floor plans. Two (minimum) per floor on multi room floors. One in each of attics, garages, crawlspaces. Three outdoor reference samples. Field blanks 2. Asbestos air sampling, if required (Type 3 removal).
18 Final Reporting Requirements Report to document investigation, remediation, successful completion. Include all analytical reports, inspection reports. Comply with reporting requirements of ESA, municipality.
19 Clan Laboratories
20 Methods of Meth Lab Production P2P Method phenyl 2 propanone true synthesis of methamphetamine currently not commonly used. Red Phosphorous Method reduction method higher potency than P2P. Birch Reduction reduction method uses ammonia highly hazardous to cooks. One Pot Method Birch Reduction on Small Scale.
21 Products used in Production Anhydrous Ammonia (fertilizer) Camp Fuel Ephedrine (cold medications) Ether (engine starter) Gas Line Anti Freeze Hydrochloric Acid (pool supply) Iodine (flakes or crystal) Kitty Litter Lithium (batteries) Lye Methanol (gasoline additive) Muriatic Acid Pseudoephedrine (cold medication) Red Phosphorus (matches or road flares) Salt (table or rock) Sodium Hydroxide (lye) Sodium Metal Sulfuric Acid (drain cleaner) Toluene (brake cleaner) Trichloroethane (gun cleaner)
22 Residual Hazards after First Response Phosphine gas absorbed in cat litter Iodine staining from vapour may persist for some time children can pick up high levels. Methamphetamine residue Pre cursers chemical residue Sharps SDB1 Mercury (P2P)
23 Slide 22 SDB1 Richard - Adjust as needed. Stephen Booth, 10/4/2011
24 Meth Lab Cleanup Standards Very little Canadian guidance. Numerous US State cleanup guidance documents and regulations: Minnesota and Colorado, very well thought out documents. AIHA Clandestine Methamphetamine Laboratory Assessment and Remediation Guidance, EPA Voluntary Guidelines for Methamphetamine Laboratory Cleanup, California Health based surface contamination guideline.
25 Clan Lab Standard
26 Team Working On PAG OHAO CLan Lab Standard EACO HIP Municipal Building Departments (Markham) Ontario Fire Marshal s Office Environmental Consulting Companies Chemical Spill Responders Abatement and Restoration Contractors
27 Purpose of PAG Clan Lab Standard Give best practices for the assessment and remediation of clandestine drug laboratories. Protect restorers and leave a safe environment for the ultimate occupants. Scope excludes Marijuana Grow Operations (MGO) but addresses all other clandestine drug operations (methamphetamine, Ecstasy, pill production, etc.) No specific Canadian or provincial regulations on this issue.
28 Clan Lab Standard Writing Sections Introduction Glossary Regulatory Background Hazards in Clan Labs Initial Stabilization Assessment of Residual Contamination Remediation Procedures Post Cleanup Assessment & Reporting References Appendix: Types operations in Clandestine Drug Labs
29 Regulatory background and governing legislation Summary of Bill 128 and duties of municipality Summary of OHS Act and duties of employers and supervisors Ontario Environmental Protection Act O. Reg. 153, Records of Site Condition O. Reg. 347, General Waste Management Transportation of Dangerous Goods Act Local property standards & bylaws
30 Hazards in clandestine drug Booby traps Chemical Physical hazards Active ingredients laboratories
31 Initial Stabilization of Clan Lab Coordination with police Qualifications of lab pack responder Personal protection Removal and disposal of chemicals
32 Assessment of residual contamination and other environmental risks Qualifications of environmental assessor Interviews and review of records Personal protection Ventilation and atmospheric monitoring Testing contamination on building surfaces Establishing a surface cleanliness acceptance limit Selection of laboratory (accreditation) Sampling strategy Exterior property Plumbing and septic systems Hazardous building materials Asbestos, mould, Designated Substances, etc.
33 Remediation procedures and recommendations Qualifications of remediation contractor Personal protection Contents and furnishings Appliances and electrical components Building finishes Cost effectiveness in remediation
34 Post cleanup assessment and reporting Inspection Post abatement quality assurance surface sampling Reporting
35 Current Update on PAG & Clan Drug Issues PAG have not met since issuing recommendations to Ministries & Agencies Nov 2010 Ontario Fire Marshall & Chief of Association of Police Associations have both retired No action from PAG until after election Increasing number municipalities & ESA referencing draft PAG MGO guideline ESA have CIH to review MGO reports PAG Clan Lab Protocol Breakout Group October 15 th deadline to submit draft sections November 3 rd meeting to review & finalize sections Favouring California clearance criterion 1.5 µg/100 cm 2 (Meth) Laboratory Accreditation
36 QUESTIONS? Richard Quenneville, CIH, ROH Director Occupational Hygiene T. Harris Environmental Management Inc. (416) Stephen Booth, LEED AP Operations Manager IAQ and Microbial Contamination Pinchin Environmental Ltd. (905) T. Harris Environmental Management Inc. Environmental Consultants Since 1979 Your Environmental Solution is THEM
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