Clandestine Drug Lab Remediation Guidelines

Clandestine Drug Laboratory
REMEDIATION GUIDELINES
Job No. 2109
2109 Remediation Guidelines_cover_FA.indd 1-2 6/04/11 5:12 PM

CLANDESTINE
DRUG LABORATORY
REMEDIATION
GUIDELINES
ISBN: 978-1-921725-63-0
© Commonwealth of Australia 2011
This work is copyright. Apart from any use as permitted under the Copyright Act 1968,
no part may be reproduced by any process without prior written permission from the
Commonwealth. Requests and inquiries concerning reproduction and rights should
be addressed to the Commonwealth Copyright Administration, Attorney-General’s
Department, The Robert Garran Offices, 3-5 National Circuit, Barton ACT 2600 or
posted at www.ag.gov.au/cca
Acknowledgements
The Australian Government acknowledges the professional input and assistance of the following
persons and organisations in the preparation of the Guidelines for Environment Investigations,
Remediation and Validation of former Clandestine Drug Laboratory Sites (Guidelines).
The principal authors of the Guidelines are:
Paul Newell Department of Environment and Conservation, Western Australia.
John Hugel Australian Crime Commission.
Peter Vallely Australian Crime Commission.
Jackie Wright Environmental Risk Sciences Pty Ltd.
Sharon Makin SEMF Pty Ltd.
Dr Larissa Borysko SEMF Pty Ltd.
Andrew Lau JBS Environmental Pty Ltd.
Organisations who have contributed to the development of these guidelines by previous research and
provision of information and/or review:
• The Australian Government Attorney-General’s Department (Attorney-General’s Department).
• The Australian Crime Commission (ACC).
• The Australian Government Department of Health and Ageing.
• The Australian Institute of Criminology.
• The Australian Federal Police.
• The New South Wales Police Force.
• The ACT Governmental Analytical Laboratories.
• The EnHealth Council.
Clandestine Drug Laboratory Remediation Guidelines iii

Preface
These Guidelines have been prepared by the Attorney-General’s Department and the ACC with the
assistance of industry and government specialists acknowledged in this document. They are intended
to provide a framework within which appropriate regulatory authorities and suitably qualified
environmental specialists may administer and conduct investigation and remediation of potentially
contaminated sites resulting from the operation of clandestine drug laboratories.
Limitations
These Guidelines are intended for use in the management and remediation of locations where
potential contamination exists originating from the operation of a clandestine drug laboratory.
They should be used in conjunction with other endorsed guidelines, such as contaminated land
management guidelines, which may be applicable depending upon the nature and location of the
contamination.
Disclaimer
The Attorney-General’s Department and the ACC have prepared this document in good faith,
exercising all due care and with attention to available information. Users of this document should
seek expert advice to determine if these Guidelines are applicable to their individual circumstances.
No liability or warranty, expressed or implied, is made or given in relation to these Guidelines.
Definitions
Appropriate authority, means any regulatory or statutory body empowered under the prevailing
health and/or environmental legislation or regulations of that jurisdiction, to take any actions in
respect to protection of human and/or environmental health or environmental contamination.
Assessment, means a set of formal methods for determining the nature, extent and levels of
contamination present on a site and the potential risk posed to human and environmental health.
CAS Number, means Chemical Abstracts Service number and is the unique number assigned to a
specific chemical by the American Chemical Society.
Chemical, means an organic or inorganic substance whether solid, liquid or gaseous.
Commonwealth, means the Commonwealth Government of Australia.
Contaminated, means a condition or state which represents or potentially represents an adverse
health or environmental impact because of the presence of potentially hazardous substances.
EHO, means Environmental Health Officer or other environmental officer authorised by the
applicable authority to exercise or enforce legislative or regulatory powers under State and Territory
environment legislation.
Emission, means the release or discharge of a substance to the environment whether in solid, liquid
or gaseous form.
EPHC, means the Environment Protection and Heritage Council.
iv Clandestine Drug Laboratory Remediation Guidelines

Investigation Levels (ILs) as described in this document, provide the basis of Tier 1 risk assessment
for clandestine laboratory sites. A Tier 1 assessment is a risk-based analysis comparing site data
with ILs to determine the need for further assessment or development of an appropriate remediation
action plan. ILs have been developed for indoor air, indoor surfaces and outdoor soil.
ILs, Health Investigation Levels (HILs) and Health Screening Levels (HSLs) each describe the
concentrations of a contaminant above which further appropriate investigation and evaluation will
be required.
HILs are described in the documentation for the National Environment Protection (Assessment of
Contaminated Sites) Measure 1999, (the NEPM). HILs are generic, deal only with contaminants in
soil, and apply across Australia to all soil types generally to a depth of 3 metres below surface.
HSLs for petroleum hydrocarbons depend on physicochemical properties of soil as it affects
hydrocarbon vapour movement in soil and the characteristics of building structures. They
apply only to contaminants in soil but account for different soil types, land uses and depths
below surface to >4 metre and have a range of limitations. HSLs have been developed by the
Cooperative Research Centre for Contamination Assessment and Remediation of the Environment
(CRC CARE), and are reported in the 2011 variation to the NEPM.
Mandatory Notification, where a Commonwealth Act and/or the equivalent provision of the
corresponding Act of any state or territory requires an individual or other entity to notify the
responsible authority of the presence of contamination.
NEPC, means the National Environment Protection Council.
NEPM, means a National Environment Protection Measure, and is a measure made under
subsection 14(1) of the National Environment Protection Council Act 1994, a Commonwealth Act and
the equivalent provision of the corresponding Act of each state and territory.
Occupier, in relation to any facility means a person who is in occupation or control of the facility
whether or not that person is the owner of the facility.
Pollutant, is equivalent to contaminant, meaning any substance or compound which is not naturally
occurring within a stipulated environment.
Remediation, means the clean-up or mitigation of pollution or of contamination.
RAP, means Remediation Action Plan.
Site (clandestine laboratory), means all areas identified as being subject to drug manufacture,
chemical, waste storage or any other activity carried out either completely or in part, and the
property upon which these actions have occurred.
Clandestine Drug Laboratory Remediation Guidelines v

Table of Contents
Acknowledgements III
Preface IV
Limitations IV
Disclaimer IV
Definitions IV
1. CONTEXT 1
1.1 Scope 1
1.2 Introduction 1
2. THE CLANDESTINE LABORATORY SITE REMEDIATION PROCESS 3
2.1 The Four Phases of Site Remediation 3

2.1.1 Phase 1 – Trigger for assessment 3
2.1.2 Phase 2 – Preliminary assessment and action 3
2.1.3 Phase 3 – Site assessment and remediation 3
2.1.4 Phase 4 – Validation 4
3. GUIDELINES FOR PHASE ONE – TRIGGER FOR ASSESSMENT 5
3.1 Interpreting police/forensic information 5

3.1.1 Background 5
3.1.2 Urgent / telephone notification 5
3.1.3 Written notification 5
4. GUIDELINES FOR PHASE TWO – PRELIMINARY ASSESSMENT and ACTION 7
4.1 Determining if a site inspection is required 7

4.1.1 Attending site while police are present. 7
4.1.2 Safety at a site inspection 8
4.1.3 Chemical contamination 9
vi Clandestine Drug Laboratory Remediation Guidelines

5. GUIDELINES FOR PHASE THREE – SITE ASSESSMENT and REMEDIATION 10
5.1 Preliminary Assessment Checklist 10

5.1.1 Outdoor and general assessment (environmental/
health assessment) 10
5.1.2 Indoor Assessment (health assessment) 10
5.2 Designing the sampling program 11
5.2.1 General principles and considerations for
detailed site investigation 11
5.2.2 Areas to target 12
5.2.3 Contaminants and wastes generated at sites 12
5.2.4 Surface contamination inside a building 16
5.2.5 Checking for Volatile Organic Compounds 17
5.2.6 Wastewater contamination 18
5.2.7 Sampling soils, surface water and groundwater 18
5.3 Assessment criteria 19
5.4 Remediation Action Plans 19
5.4.1 Site information 20
5.4.2 Site characterisation 20
5.4.3 Remediation goal 21
5.4.4 Extent of remediation required 21
5.4.5 Remediation options/ hierarchy of remediation
for structures 21
5.4.6 Remediation options – environment 23
5.4.7 Proposed testing for validation 24
5.4.8 Contingency plan 24
5.4.9 Site management plan 24
5.5 Building Decontamination Management Plan 24
5.6 Environmental Management Plan 24
Clandestine Drug Laboratory Remediation Guidelines vii

6. GUIDELINES FOR PHASE FOUR – VALIDATION 25
6.1 Site validation 25

6.2 Validation of buildings and structures 25
6.3 Validation of land 25
6.4 Soil validation 25
6.5 Surface water validation 26
6.6 Groundwater validation 26
7. References and Resource Documents 27
8. APPENDICES 28
Appendix 1: Summary of Investigation Levels (IL’s) 28

Appendix 2: Reporting and Data Quality Objectives 30
Appendix 3: Personal Protective Equipment 34
Appendix 4: Analytical Laboratory Services 36
viii Clandestine Drug Laboratory Remediation Guidelines

1. CONTEXT
1.1 Scope premises, remote rural properties, hotel and

motel rooms, watercraft, mobile labs mounted
This document is intended to provide the
in commercial vehicles, mines and purpose
required guidance to appropriate authorities and
built underground facilities. Frequently the
environmental professionals in the assessment
knowledge and technical skills of the operators
and remediation of contaminated sites where
are minimal and improvised or unsuitable
such contamination arises from chemical
equipment is utilised in the processes, resulting
processes associated with manufacture of illicit
in vessel failures, spillages and escapes
drugs. To reflect the nature and prevalence of
of reaction materials. The combination of
clandestine laboratories seized by Australian
compromised safety and inappropriate facilities
law enforcement agencies, particular
presents a high likelihood that some level of
emphasis has been directed to the materials,
environmental contamination will be a legacy of
practices and by-products associated with the
most clandestine laboratory sites.
manufacture of amphetamine type stimulants
(ATS), principally methylamphetamine and In an increasing number of instances, illicit
3,4-methylenedioxymethamphetamine (MDMA). laboratories come to the attention of authorities
The assessment and remediation principles only when catastrophe strikes in the form of fire
and practices outlined in this document are, or explosion. In these instances, contamination
however, generally valid for the wide range of issues are greatly compounded and present both
activities associated with the production and immediate and long term hazards to community
processing of other synthetic drugs. members resident in the vicinity.
These Guidelines are not intended to prescribe In order to minimise detection, clandestine
technologies, goals or precise rules for the laboratory operators will frequently avoid
remediation of former clandestine laboratory the use of industrial waste handling facilities
sites. Rather they are designed to provide a and dispose of waste materials through
framework for the key issues that need to be indiscriminate dumping on public lands,
considered throughout remediation programs, sewerage systems, industrial estates, national
and aim to ensure that every effort is made to parks or into waterways. In these events, the
protect human and environmental health. link between the contamination and illicit drug
synthesis may not be initially evident.
1.2 Introduction
The residual contaminants which arise from
It has been widely recognised by many a drug manufacture or “cooking” process can
governments, including the Australian be in the form of solids, liquids or vapours
Government, that the residual contamination and be absorbed by floorings, walls, drains,
arising from illicit drug manufacture carried ducting and any furnishings or fixtures in the
out in clandestine drug laboratories presents vicinity of the clan lab. Additionally there are
a serious risk of harm to human and significant quantities of waste produced from
environmental health. the drug manufacture process and, dependent
The contamination problems presented by such on the particular process being employed, may
criminal activities are frequently complex. The generate up to 10kg of waste for each 1.0kg of
inherent illicit nature of these undertakings drug produced. The manner of disposal for this
results in operators ignoring conventional contaminated waste product also represents
chemical manufacturing and handling a risk to environmental and human health.
good practices in order to avoid detection. These contaminants can in many instances
Consequently, the locations that have been persist within structures, furnishing and
chosen for establishing clan labs vary widely the environment and pose a risk to persons
and include residences, both suburban and occupying the premises, potentially for many
inner city high rise, commercial and industrial years into the future. There is clear evidence
Clandestine Drug Laboratory Remediation Guidelines 1

showing that many of the residual chemical The desired outputs are to ensure that the
contaminants produced during the drug adverse impacts of illicit drug manufacturing
manufacture process are of a hazardous nature operations on community health and the
and include heavy metals, carcinogens and natural and built environments are minimised
phytotoxic substances. through appropriate and nationally consistent
assessment, remediation management and
These national Guidelines have been developed
reporting practices.
to assist appropriate authorities in administering
their respective environmental acts and It is critical that at a minimum, sites suspected
regulations in addressing contamination arising or known to have been utilised for illicit drug
from clandestine laboratories adequately and manufacture are recorded within jurisdictional
in a nationally consistent manner, and in this environmental authority and property/lands
way provide protection to their local community database systems.
and the environment. Further, the Guidelines
will provide assistance for environmental
professionals and landowners to meet
appropriate assessment, remediation and
reporting criteria.
To assist in achieving national consistency in the
assessment of former clandestine laboratory
sites, the Guidelines have been developed with
close reference to the established and accepted
NEPC and NEPM’s currently utilised in all states
and territories within Australia.
The NEPM or subsequent revisions, provide a
recommended general process under Schedule
A of this measure, for the investigation of
contaminated sites. This NEPM should be
reviewed prior to the commencement of site
investigations and referenced in conjunction
with these Guidelines.
Although upon first consideration, the factors
associated with a clandestine laboratory
site may appear distinct from traditional
contaminated site issues, in reality such
locations are environmentally not dissimilar to
common contaminated sites such as a former
service station, or dwellings containing lead
or asbestos contamination. The principles,
objectives and processes of site investigation
are the same in all cases. For this reason,
and to facilitate ease of compliance with these
Guidelines and local legislation and regulations,
the investigation processes detailed are based
on existing nationally accepted NEPC, NEPM
guidelines and standards.
2 Clandestine Drug Laboratory Remediation Guidelines

2. THE CLANDESTINE LABORATORY
SITE REMEDIATION PROCESS
2.1 The Four Phases of Site Given these examples, the nature of the action
Remediation undertaken by the appropriate authority will
be determined by their policies and practices.
The four phases of clandestine laboratory site Any actions should be commensurate with the
remediation are: level of risk.
1. Trigger for assessment;
2. Preliminary assessment and action; 2.1.3 Phase 3 – Site assessment and
remediation
3. Site assessment and remediation; and
4. Validation. If phase 2 indicates that risk exists to
community health, then the appropriate
The following information is a summary of these authority should, having imposed pollution
four phases and should be read in conjunction control, clean-up notices or similar orders,
with Figure 2.1. Each phase is described in and having determined who is responsible
greater detail in subsequent sections. for the detailed assessment and remediation,
engage the services of a suitably qualified
2.1.1 Phase 1 – Trigger for assessment professional, as defined below, to conduct
Law enforcement agencies from all jurisdictions such investigations, analysis, remediation and
within Australia encounter clandestine validation as may be necessary in accordance
laboratories. These may be either operating with these Guidelines. These investigations
at the time of police interdiction or have will be carried out to determine if the dwelling/
previously operated in that location. All state structure and/or property pose a risk to human
and territory police services maintain specialist or environmental health.
units, trained specifically to operate in the Investigations of potentially contaminated
hazardous environment created by these illicit dwellings or sites should be conducted by
manufacturing operations. Once the laboratory a suitably qualified expert with experience
site has been rendered safe and processed in the fields of environmental engineering,
for evidentiary purposes, police will usually environmental science, environmental health or
notify the appropriate authority within that occupational hygiene, who is in possession of
jurisdiction of the existence of the site. At this tertiary qualifications in one of these disciplines
time, information should be provided outlining from a recognised educational institution.
the nature of the suspected illicit manufacturing
activity and the identity of chemicals detected Detailed information regarding the selection
on the site. of a suitably qualified consultant can be found
in the NEPM, Schedule B (10) ‘Guidelines on
2.1.2 Phase 2 – Preliminary assessment Competencies and Acceptance of Environmental
and action Auditors and Related Professionals’.
Upon receipt of the notification of a clandestine Following engagement by a property owner,
laboratory, the responsible officer should authorised representative, mortgagee or other
conduct a preliminary assessment to determine party having legal claim or authority over a
whether further action is required, for example: property or dwelling, a consultant should review
• Declaring a dwelling or property ‘potentially available site documentation in accordance with
contaminated’ or unfit for habitation; or these Guidelines, and in reference to applicable
NEPM measures and guidelines. A consultant
• Compelling a property owner to provide should follow the process for site investigation
sufficient evidence that the site does not pose and reporting shown in Figure 2.2 and contained
a risk to human or environmental health, in detail within this document.
based on the requirements of this Guideline.

2.1.4 Phase 4 – Validation
Following site assessment and remediation,
a site validation report is prepared.
The appropriate authority may audit the report
before acceptance.
Figure 2.1: General Process for Site Investigation and Reporting
Trigger for Assessment

Phase 1 Police seize clan lab, process, render safe and provide appropriate authority
with notification letter and ‘site assessment report’.
Responsible authority orders preliminary No Risk

Phase 1 No further action required.
assessment to determine extent of risk.
Risk identified
Investigation and assessment checklist

indicates contamination
is present/potentially present.
Appropriate authority issues pollution control/prohibition or other environmental

Phase 3 order against property as may be deemed necessary. Authority issues order to provide
contamination report in accordance with guideline.
Completion of site assessment checklist and investigation, including laboratory

analysis, in accordance with guideline.
Contamination Identified No Contamination Identified
Assessment confirms contamination,

Responsible authority reviews
Remediation Action Plan (RAP) is devised,
investigation report.
responsible authority initiates remediation.
On completion of remediation activity,

a site validation report is prepared.
Appropriate Authority reviews report and audit checklist, issues site clearance
Phase 4
on acceptance of final validation report.

3. GUIDELINES FOR PHASE ONE –
TRIGGER FOR ASSESSMENT
3.1 Interpreting police/forensic then police may contact the appropriate

information authority by telephone while still present at
the site. In these instances, the responsible
3.1.1 Background officer receiving the notification should discuss
At a clandestine laboratory site, police and the nature of the hazard or contamination
forensic chemists gather evidence on the before attending onsite in order to ensure
nature of the operation to determine if a drug arrangements can be put in place for any
related offence has occurred. The operators necessary equipment and/or assistance as
of clandestine drug laboratories do not indicated by the conversation. In most cases, the
respect environmental laws, consequently responsible officer should attend onsite as soon
these operations frequently result in serious as practical, ideally while police and emergency
environmental contamination. Since hazardous services are still present.
chemicals are regularly used inappropriately in Some states and territories have dedicated
such operations, police and forensic services environment and/or pollution response units,
follow safety procedures designed to protect usually attached to their respective environment
themselves and the public from harm. In many protection agencies. It is expected that where
cases, units of the fire and rescue services will police or other attending services identify an
be present to provide assistance in maintaining imminent danger to the environment, these
safety. In addition to safety procedures, evidence units should be contacted.
gathering protocols are applied to ensure that
information obtained will be admissible in any 3.1.3 Written notification
subsequent court proceedings. Under non emergency circumstances, police
Police connected with the clandestine laboratory will inform the local appropriate authority in
case will normally inform the appropriate writing of any suspected clandestine laboratory
authority regarding any potential environmental seizure. Dependant on operational constraints,
contamination. Such notification can take one of notification should ideally be issued within 24
two forms. hours of the completion of site processing and
should include the following information:
(i) If the potential environmental contamination
is considered serious, attending police may • address of the suspected clandestine
contact the appropriate authority shortly laboratory – exact location;
after first attending the site and before they • nature of premise – (house, high rise
have finished gathering evidence. residential, industrial unit);
(ii) If the potential environmental contamination • status of occupancy;
is not considered to be serious, a formal
letter of notification may be relayed to the • identified potential hazards or threats –
appropriate authority shortly after the police chemical, environmental, electrical, physical,
have left the site. biological, human;
While a police objective is to render the site safe, • description (if known) of synthesis method(s)
police are not responsible for or experienced in suspected or believed to have been
the mitigation of environmental contamination. undertaken at the site;
3.1.2 Urgent / telephone notification • site sketch indicating suspected areas of

contamination e.g. location of chemical
If there is an apparent imminent danger to reaction processes, spillages, waste dump
the environment, or the nature of observed locations;
contamination is sufficiently widespread or of
a nature that immediate action is warranted,

• inventory of identified chemicals seized and
the locations where the items were found;
• an indication of scale and physical extent/
boundaries of any manufacturing operation;
• presence of children or indications children
reside at the premises; and
• contact information of a designated attending
police officer.
Standard letters of notification may not always
contain the level of information needed for
the appropriate authority to determine if a
site inspection is needed. In such instances,
communications should be established with
the police officer nominated on the notification
in order to obtain any further information
that is required. In some circumstances, the
responsible officer may need to also contact
a police officer or forensic chemist who was a
member of the evidence gathering team.
In the likely event that a site inspection is
required, communications with police officers
and/or forensic chemists should include all
information available on any identified or
suspected safety issues associated with the site.
(See section 4.1.2)

4. GUIDELINES FOR PHASE TWO –
PRELIMINARY ASSESSMENT and ACTIOn
4.1 Determining if a site inspection Unless the information received by the police
is required indicates that:
Any dwelling, within which a clandestine • all chemicals found at the site were sealed
laboratory has been detected should be and unopened; or
considered potentially unfit for human habitation • there was no evidence of any chemical
until such time as appropriate investigation processing at the site
can determine the presence or absence of
contamination. the responsible officer should personally attend
the site. Section 5.1.1 gives the decision matrix
In addition, the property upon which the dwelling which can be used to determine if further site
is located, or property where the reaction was investigation should be ordered.
carried out should also be considered potentially
contaminated. Illicit drug manufacture is 4.1.1 Attending site while police are present
a ‘chemical manufacturing process’. Most
Australian states and territories recognise When attending a clandestine laboratory site
within existing environmental guidelines that a before the police have vacated, the responsible
‘chemical manufacturing process’ represents a officer should identify themselves and request
potentially contaminating land-use. to speak to the officer in charge. At that time,
the site will be the responsibility of the police
Where a clandestine laboratory has been and/or fire service. Attending while the police
operating at an out-door, semi-enclosed or are present provides the responsible officer the
other out building separate to the principal advantage of working on a secure site in the
site dwelling, these areas and the property in knowledge proper safety precautions will be in
general should also be considered potentially place. In these circumstances, the responsible
contaminated, although this circumstance may officer should confer with attending police,
not preclude the continued occupancy of the emergency services personnel and forensic staff
principal site dwelling. Decisions in such events to gain an understanding of the circumstances
are at the discretion of the appropriate authority giving rise to concerns they may have regarding
and should be based on professional judgement. observed or suspected contamination of the
dwelling or environment. Early interaction,
Upon receipt of the notification of a clandestine
particularly with the attending forensic chemist,
laboratory, the responsible officer should
may prove valuable to the responsible officer in
examine the information provided, and obtain
developing a thorough understanding of what
additional information if necessary. It should
has occurred on the site, and subsequently
be remembered that the principal priorities of
assist in determining an appropriate course of
the law enforcement response team are the
action and the design of appropriate testing and
stabilisation of any processes active at the site
remediation protocols.
at the time of interdiction, and the subsequent
processing of evidence to ultimately determine Sites are designated crime scenes hence
the extent of criminality associated with the safety and evidence protocols will be in place
activity. While the general identification of while evidence is processed by police and
contamination issues is incorporated into their forensic chemists. On the completion of this
processes, the responsibilities and expertise of phase, the responsible officer will usually be
this unit is not primarily focused on this task. conducted through the crime scene, so as to
In almost all cases, a visit by the responsible be made aware of any areas where potential
officer to the site is highly recommended and contamination has been identified.
will often identify additional environmental
hazards which may need to be addressed under
local environmental requirements.

4.1.2 Safety at a site inspection air contaminants, and generally to provide
estimates of concentration of these substances.
The responsible officer who attends the site
Consequently, any information on potential
must ensure that their personal safety is
airborne hazards by process team members will
maintained at all times. Before attending any
frequently be limited to those substances which
suspected clandestine laboratory site, the
are monitored instrumentally, and may contain
responsible officer should contact a police
no information on ‘smells’ of other substances
officer or forensic chemist who attended the site
which may prove additional useful information to
to determine the nature and extent of potential
the responsible officer in establishing the nature
hazards likely to arise with the site inspection. In
and extent of contamination. It is important
this preparative phase it should be remembered to remember however that the specific
that threats to safety can arise from both data provided instrumentally on gases and
animate and inanimate sources. flammable solvents delivers reliable insight into
While there is wide diversity in the nature the likely chemicals and solvents which gave
and geographical location of sites utilised rise to the airborne substances identified.
by criminals to manufacture illicit drugs and The responsible officer should be aware of the
other controlled substances, the majority range of chemicals that can be encountered in
of clandestine laboratories detected are clandestine drug manufacturing operations.
situated in or adjacent to domestic dwellings. These may take the form of precursors,
It is frequently the case that, following the reagents and solvents procured in order to
police activity associated with the clandestine conduct synthetic phases of the process, or
laboratory seizure, the site of the laboratory may may be the by-products of such synthesis. It
remain occupied, and the person or persons is important that the responsible officer has
in residence may be the subject of charges in at their disposal the most comprehensive
relation to the activities of the laboratory. In information on the chemicals detected at the
this event, it is important for the responsible site, and ideally the identity of the substance
officer or other authorised officer to confer with under manufacture and the route of synthesis
police to determine whether an escort may be that was employed.
necessary whilst the environmental assessment
is carried out. In some instances, the identity of substances
at a site may not be readily evident at seizure
Police and other workers who attend and as label defacing or repackaging is frequently
process a suspected clandestine laboratory site practiced by clandestine laboratory operators
invariably employ personal protective equipment to obscure the identity and source of the
(PPE). The level of protection required for the chemicals. Depending on instrumentation
operation will be determined by a number of available, the response team attending may
factors, and may be scaled back during the be unable to positively identify many of the
processing of the site as facts are established, in chemicals on site, and will rely on subsequent
particular, issues of air quality. comprehensive laboratory analysis to reveal
their identity. In these instances, the original
Respiratory protection, either in the form notification presented to the appropriate
of breathing apparatus (BA) or air purifying authority by law enforcement will likely not
respirators (APR) are frequently required for the contain sufficient information to permit an
duration of the processing operation. By the very adequately informed initial assessment. In
nature of the protection both these equipment this event, should laboratory analysis reveal
types afford, no reliable information can be an unanticipated hazard, then a revision of the
gathered by the wearer as to any particular initial assessment strategy may be required.
odours or vapours that may be present in the
site or environs. Assessment of air quality While many of the hazards which may be
during the processing operation is provided encountered at a clandestine laboratory site are
through the use of portable instrumentation common to other built environments, a number
designed to detect specific flammable or toxic are peculiar to this form of illicit activity.

4.1.3 Chemical contamination classes of substances will have been obliterated
Chemical contamination is best considered with the destruction of their labels or packaging
under two general classifications, transient and however the original compounds or their
residual. The notification provided by the initial combustion products will remain.
response unit will record those substances Biological hazards may include:
detected at the time of seizure. A number of
these may be directly generated by particular • used syringes and paraphernalia from
manufacturing processes active at that time drug abuse;
and be reasonably expected to not persist in • poor personal hygiene practices of occupants
that environment, this particularly applies to and domestic pets; or
airborne contaminants.
• airborne spores from fungi and moulds.
As methylamphetamine remains the most
common drug manufactured illicitly in Australia, Other hazards may include:
it follows that contamination associated with • compromised or improvised electrical
the various methods by which it is produced circuitry;
will constitute a major proportion of cases for
assessment and possible remediation. • modified or poorly maintained structures;
Airborne contaminants commonly associated • site accessibility;

with methylamphetamine production include:
• air quality/oxygen depletion in subterranean
phosphine, hydrogen iodide, iodine vapour,
non ventilated spaces;
hydrogen chloride, ammonia, vapour forming
organics, organic particulates and a number • anti personnel devices not detected by law
of organic solvents. The air spaces within a enforcement; or
laboratory site may also carry organic vapours
arising from spillages of a wide variety of • presence or appearance of persons
complex mixtures present at intervals during associated with the alleged offences.
the manufacturing process. The levels Appendix 3 outlines the range of PPE utilised by
of a substance in air spaces will depend law enforcement and emergency services and
on a combination of their relative vapour should be consulted as part of the preparation
pressure and the extent to which they have for a site inspection.
been distributed or adsorbed onto surfaces.
Dependent on available ventilation and the Police clandestine laboratory processing teams
time interval between the cessation of illicit take every reasonable step to remove chemicals
operations and responsible officer's assessment, or equipment that has been, or could be, used
no detectable evidence of some of the more in illicit drug manufacturing. On occasions
volatile of these substances may remain. however, items may overlooked. If an item is
located by a responsible officer that is believed
Potential contact hazards vary considerably. to be of interest to the police, they should
They may be in the form of acidic or basic contact the police to describe what was found.
deposits, precursor chemicals and reagents
including heavy metal salts, alkali metals, active In Western Australia, legislation does not permit
catalysts, reaction mixtures and intermediates, the pre-trial destruction of seized items. This
final drug products, reaction by-products, means that police in Western Australia on
wastes and solvents. In rare instances, some occasions are unable to remove some items that
pyrophoric substances and materials where would normally be removed.
elevated radiation levels are possible may be Sites present dangers not only to community
encountered. and the environment, but also to those people
In instances where the clandestine laboratory working there. Taking all necessary precautions
has undergone a fire or explosion, evidence when inspecting a site is essential in establishing
of the identity or presence of many of these and maintaining a safe working environment.

5. GUIDELINES FOR PHASE THREE –
SITE ASSESSMENT and REMEDIATION
5.1 Preliminary Assessment Checklist 4. Is there any evidence of soil contamination

such as staining, spillages, visible waste
The following check list of questions is designed
disposal sites or bare patches of soil?
to provide appropriate authorities and suitably
qualified experts assessing a potentially 5. Is there any current or historical evidence
contaminated clandestine laboratory site with a which indicates the possible use or the
rapid reference tool to indicate if additional site storage of chemicals or wastes associated
investigation is required. In some cases a police with chemical processing at the site?
officer who attended the scene may need to be
6. Is there any unexplained soil disturbance or
contacted for clarification of some matters.
evidence of excavation on the site? (Note:
For purposes of convenience, the questions historical aerial photographs may provide a
have been divided into ‘Outdoor and General reference source for this information.)
Assessment’ or environmental assessment
7. Is the site located in close proximity to
for use in the preliminary assessment of land
a waterway, other natural water body or
and surroundings of the site, and ‘Indoor
potable water source?
Assessment’ or health assessment for the
assessment of dwellings or other structures 8. Does the site adjoin, or is the site in
which may be affected by clandestine close proximity to any public utility such
laboratory related activities. Answering as a school, playground, swimming pool
‘Yes’ to any of the following questions will or park?
usually indicate a preliminary site investigation
will need to be conducted. 9. Does the site adjoin, or is the site in close
proximity to any sensitive environment?
As the dumped materials may provide important
evidence to police in respect of a case outside 5.1.2 Indoor Assessment (health assessment)
the geographic jurisdiction of the environmental 1. Was the clandestine laboratory located
authority, a notification protocol between within a dwelling or other site structure?
environmental authorities and law enforcement
is recommended. In this way, both parties may 2. Is there any damage (For example.
collaborate to establish both the identity of corrosion or staining) to fixtures or fittings
those responsible for the deposition and also the inside the building which is consistent with
nature and subsequent appropriate remediation chemical exposure?
strategies for the contaminants.
3. Are there any visible residues present on
5.1.1 Outdoor and general assessment fixtures, fittings or any internal surface?
(environmental/health assessment) This will include any staining of walls,
bench surfaces, furnishings, discolouration
1. Was contamination identified within of extraction fans, filters, vents or staining
the police/forensic information or site around sinks or drains.
assessment report?
4. Does the dwelling or structure have
2. Has police/forensic information identified internal or improvised air ducting?
the status of the clandestine laboratory
as a category A, ‘Active’ or category B, 5. Are there any noticeable odours of a
‘Used Inactive’? chemical or contaminant nature?
3. Is there evidence of any chemical process 6. Are there any modifications to the building
being undertaken at the site, recent or which could permit the transfer of
historical? contamination external to the building?

For example, extraction fans set into A sampling plan serves to determine the
external walls, holes cut in flooring or existence and the extent of any contamination.
improvised plumbing suited to the disposal The plan should include a rationale for the
of liquid wastes. sampling program, taking into consideration all
available information in relation to the activities
Other factors which should be taken into
conducted at the site. Given the nature of
consideration may include:
clandestine laboratories and the contamination
• The type and condition of fences, i.e. is the that is generated through their operation, both
site secure, and if not, is there a requirement systematic sampling and judgemental principals
for interim control measures to secure the may be applied.
property?
In sampling a dwelling or other structure
• Condition of roads, pavement and other allegedly used as a clandestine laboratory,
access issues should vehicular access testing should be primarily targeted at areas
be required. where contamination is most likely. After
decontamination, the site again needs to be
• What is the general down stream direction sampled to validate that decontamination
and destination of surface water runoff? procedures have been effective.
Are any waterways potentially at risk?
Efficiencies can be achieved providing the
• Does the site have any drainage channels responsible officer is in possession of all
or conduits? information pertaining to the site prior to the
formulation of a sampling plan. For example,
5.2 Designing the sampling program if a decision has been made that a building is
5.2.1 General principles and considerations to be demolished and the materials removed
for detailed site investigation as hazardous waste, there would be no need
to obtain samples from the building. Sampling
Each stage of the investigation has the potential of the soil post demolition on that property
to be reported separately, namely: may be all that is required to accompany an
• Preliminary site investigation; investigation and/or validation report.
• Detailed site investigation; Difficulties may arise in the assessment

of clandestine laboratory sites situated in
• Remediation Action Plan; and commercial premises. Here both licit and
• Validation and ongoing site monitoring. illicit manufacture may have been carried out
simultaneously. The responsible officer will
Sampling design information is based on the require information on both the legal and illegal
principals of NEPM, Schedule B (2) ‘Guideline on activities in order to discriminate between
Data Collection, Sample Design and Reporting’. chemicals and hence develop appropriate
When designing a sampling program both the sampling and waste disposal plans.
NEPM guideline and the following sampling
design information should be considered to These Guidelines provide advice on the numbers
ensure that the program adopted is the most and locations at which samples are to be taken.
appropriate given the information available. If there is information from any source that
would indicate a higher rate of sampling, then
Note: The discussion in this section does not those samples should be taken; e.g. a neighbour
include the sampling for clandestine laboratory may provide information about dumping areas,
growing marijuana. It does, however, include or suspicious odours.
sampling for a clandestine laboratory extracting
marijuana to produce cannabis (or hash) oil.

5.2.2 Areas to target conditions where inefficient or improvised
Contamination caused by clandestine condenser apparatus is used. The most
laboratories can take many forms so this must commonly encountered synthesis routes for
be reflected in the locations and the types illicit methylamphetamine involve the direct
of samples collected. Areas that should be or indirect use of hydrogen iodide, present
targeted for testing include where: as hydriodic acid. Aerosol deposits from this
class of synthesis will, either rapidly or with
• chemical processes were being conducted time, develop some degree of colouration
(from police information); from pale yellow to strong brown due to the
liberation of iodine. There are many other
• chemicals and/or used equipment had been
chemical processes associated with either
stored (from police information);
the manufacture of drug substance or their
• there is visible staining or encrusted solid chemical precursor which will generate
(judgement); entirely colourless deposits, hence visual
inspection is an unreliable indicator for
• preliminary testing indicates contamination, surface contamination.
For example moist pH indicator strips reveal
acidic or basic surface contamination; 5.2.3 Contaminants and wastes generated
• there is discoloured, distressed or dead at sites
vegetation (judgement); and The following is a description of some of the
liquids and solids that are likely to be found at
• children are believed to be living or playing
sites. The purpose of these descriptions is to
(police information and judgement).
assist the responsible officer in recognising a
Illicit drug manufacture generates significant substance likely to have originated from the
amounts of waste. The volumes produced illicit manufacture process and further, to
will depend on a number of factors including appreciate how contamination at a site occurs.
starting materials, routes of synthesis and the
In most jurisdictions, items associated with
technical skills of the operators. Estimates of
a clandestine laboratory will be removed by
waste from the production of a single kilogram
the police. In some jurisdictions, particularly
of methylamphetamine vary from 3 litres to 30
Western Australia, there is limited provision
litres and may take the form of liquids, slurries,
for the pre-trial destruction of items seized at
resinous to waxy oils, and solids. The fate of
clandestine laboratories. In some instances,
these wastes may involve hoarding by operators
certain items can be overlooked or deemed to
in the belief that valuable components may
be unimportant as evidence and therefore left on
remain to be recovered, or more generally,
site. These items, while perhaps of limited value
disposal at either the site or remotely. To
as evidence, may contain potentially significant
adequately determine if waste products are
environmental contaminants.
contaminating a former site, sampling plans
should include drainage systems (stormwater The deposition of residues from manufacturing
and sewerage), sewer traps, sullage pits, dams, processes may be intentional through dumping
ponds and water courses. or may be unintended, in the latter case through
spillage, catastrophic equipment failure or
The synthesis techniques generally
vapour/aerosol distribution. Irrespective of the
employed for the illicit production of ATS,
manner in which the contamination arises,
for example methylamphetamine and
the residues are frequently complex and may
3,4-methylenedioxyamphetamine (ecstasy),
contain not only controlled drugs and precursors
will frequently result in traces of the reaction
but also a wide range of organic and inorganic
mixtures being deposited on the inner surfaces
compounds. The identity and pharmacological
of a dwelling. The residues are deposited
activity of many of these substances is unknown.
through aerosols generated from boiling
The complexity of residual materials is further
reaction solutions under protracted reflux
compounded in instances where clandestine

laboratories experience fires as combustion mineral turpentine or shellite. Sodium hydroxide
and pyrolysis products are produced under is almost invariably used to establish basic
these conditions. conditions for extraction. This substance also
has further application in pH adjustment in a
The following contains a description of the
number of other techniques regularly applied in
characteristics and origins of some of the
illicit drug synthesis hence both strongly basic
residues and wastes found at sites.
liquid and slurry wastes are common. Tablet
Methylamphetamine synthesis operations extraction wastes can be single or two phased
are the predominant class of clandestine and of a high pH and contain tablet excipient and
laboratories reported nationally. An examination binder wastes.
of the chemicals and processes used for several
An examination of reagents outlined in (a)
of the routes of production for this drug can
above provides only a partial indication of
provide a useful general model to describe likely
the potential complex nature of the chemical
sources where contamination may arise in illicit
matrices associated with clandestine laboratory
drug laboratories.
remediation. For example, in the particular case
Pseudoephedrine has been shown to be the of hydrogen iodide driven pseudoephedrine
most common source of starting chemical or reductions, the group of reagents identified
precursor used in illicit methylamphetamine are variously present at the initial phase of the
in Australia. The reduction of this substance process, however as the reaction proceeds,
produces the desired drug. The reduction step a number of reaction products, including
can be achieved via a number of routes however methylamphetamine, are produced.
two classes of process are most frequently
At the completion of the reaction phase, an
utilised by illicit manufacturers:
extraction or cleanup process is undertaken to
a) Reduction using hydrogen iodide as the isolate the target substance from the unwanted
reducing species – this can be achieved spent reaction by-products. This is typically
through the direct use of hydrogen iodide in achieved through either of two processes,
the form of hydriodic acid, or the hydrogen distillation or solvent extraction. A common
iodide can be synthesised in situ by the technique widely utilised in the illicit production
application of various combinations of of methylamphetamine is the steam distillation
substances including hypophosphorous acid, of the reaction mixture. This process can give
phosphorous acid, phosphoric acid ,iodine, rise to significant levels of the amine in free
iodide salts and red phosphorous; or base form escaping in the form of vapour as
a consequence of inefficient condensation
b) Dissolving metal (Birch reduction), where equipment. The distillation residues freed of
condensed anhydrous ammonia is employed methylamphetamine also present a significant
both as a reagent and solvent, and the active source of potential contamination as they are
metal is generally lithium or sodium or frequently disposed of in drains or dumped on or
occasionally potassium. around the environs of the laboratory.
The pseudoephedrine precursor will generally In general, distillation residues from not only
be sourced from pharmaceutical preparations methylamphetamine production operations but
diverted from licit distribution channels. The from synthesis of the wide range of controlled
preparations are usually in the form of tablets drugs and drug precursors will regularly
however gelatine capsules and liquids are also contain a wide variety of organic and frequently
targeted. The extraction of the pseudoephedrine inorganic components. The sustained elevated
can be achieved through the powdering of the temperatures inherent in distillation processes
tablets and subsequent extraction by either, will create an environment where high molecular
direct dissolution and filtration using the lower weight oils, resins and waxes may be formed.
alcohols, or alternatively through solvent These are frequently water insoluble and will
extraction. The solvents used include toluene strongly resist conventional cleaning techniques.
or other readily available hydrocarbons such as

The use of solvent extraction as a purification of significantly contaminated structural
technique in the isolation of a controlled drug components such as flooring and walls
or drug precursor can involve the use of a may be necessary.
wide variety of organic solvents, these include
Cleaning operations may result in surfaces
toluene, benzene, xylenes, mineral turpentine,
testing negative to test analytes when
shellite, diethyl ether, dichloromethane,
re-sampled immediately after treatment.
chloroform, acetone, isopropyl alcohol,
The possibility of contaminants which have
methylated spirits and methanol. Dependent
deeply penetrated the surface being remobilised
on the chemical properties of the substance
through diffusion back to the surface should
intended for isolation, solutions containing
be considered. It may be advisable in cases
combinations of water soluble and water
where porous surfaces have been subjected to
insoluble wastes will be generated, in the
liquid inundation that drilling into the structural
form of single, or more typically, two phased
medium is carried out to determine the depth of
solutions, and frequently in large volumes.
contaminant penetration and/or the efficacy of
Spillages or leakages of liquid waste are a cleaning operations.
primary source of environmental contamination.
Seasonal temperature fluctuations can
Deposition can arise during transfer
contribute to changing air quality in clandestine
operations or through the failure of equipment,
laboratory environments. If air quality
particularly the failure of inappropriate storage
monitoring is carried out at low temperatures,
containers. The presence of solvents in plastic
an increase in ambient air temperatures
vessels or the containment of solutions of
with seasonal changes can result in organic
low pH in metal drums will often result in
contaminants exerting considerably higher
vessel failure. Upon release, the complex of
partial vapour pressures and hence, volatilising
components in the solutions may be carried
into the air space at higher concentrations than
deeply into the surfaces they contact due to
at the time of testing. While this circumstance
the efficient solvating properties of solvents.
primarily would apply to organic compounds,
Upon the evaporation of the solvents, the
the levels of inorganics, particularly iodine
contaminants can remain deeply embedded
vapour, may be similarly influenced. To avoid
in floor coverings, floor boards or composite
this possibility, the removal of contaminated
sheet flooring materials, concrete or any other
structural components may need to be
porous construction materials. In many cases,
carried out at sites where significant permeation
remediation processes such as the application
is suspected.
of surfactants detergents or high pressure
steam cleaning will succeed only in removing The technique of dissolving metal reductions
surface contamination and will be ineffective described in 5.2.3 (b) above presents a different
in removing materials which have penetrated group of potential contaminant compounds. In
into the medium. these reactions, pseudoephedrine (or ephedrine)
is dissolved in condensed anhydrous ammonia
Most liquids in their pure form are clear and
as solvent and subsequently reduced by the
colourless however liquids that have been used
action of either lithium or sodium (or rarely
in some way at a clandestine laboratory will
potassium). The condensation or trapping of
often carry some degree of colouration. Colour
anhydrous ammonia gas presents several
and colour intensity is variable and, in general,
extreme hazards at both the time of the
provides little useful insight into the chemical
process and subsequently in the storage of
composition of the solution. In cases where
the condensate. The process can be achieved
visual indications of spillages are evident, the
through the venting of compressed ammonia
responsible officer should exercise judgement
gas into a vessel chilled in a bath of typically
in determining if the cleaning of the effected
acetone and dry ice. The condensed ammonia
surface is likely to remove contaminants. In
may either be used immediately or stored. It
most instances the removal of floor coverings is
is the second practice where inexperienced
highly recommended however the replacement

operators have chosen non pressure rated should be considered suspicious and generally
sealed vessels to confine the liquid where be removed as hazardous waste. In instances
catastrophic failure and explosion events have where the clandestine laboratory was located in
occurred. Similarly, stolen ammonia may be a commercial environment, it will be necessary
decanted into gas cylinders intended for the to determine which liquids present were
storage of liquid propane. These vessels are associated with the illicit activity, and hence
fitted with brass valving, which when exposed to likely contaminants, and which are associated
ammonia for extended periods, will lose copper with any legitimate commercial activity
from the alloy and subsequently fail under operating at the location. The responsible officer
the pressure of the contained gas. A visual should exercise good judgement in deciding
indication of brass having been exposed to whether substances found at a site should be
ammonia is a blue-green colouration on the removed as hazardous waste.
surface of the alloy.
Concentrated mineral acids are used
An alternative process where anhydrous commonly in clandestine drug synthesis.
ammonia can be produced is through the These will include hydrochloric and sulphuric
chemical reaction of ammonia salts and sodium acid, with hydriodic and the phosphorous
hydroxide. Typically either ammonium nitrate or oxy acids, hypophosphorous, phosphorous
ammonium sulphate fertilisers are used. The and phosphoric being used particularly in
reaction is carried out in a closed vessel and methylamphetamine synthesis. A recognised
the ammonia thus generated is cryoscopically method used illicitly for the synthesis of
trapped. Improvised vessels used for this other ring substituted ATS requires the use
purpose may be sealed and stored or discarded of hydrobromic acid. Acids are used either as
while still containing significant quantities of reagents to perform specific reaction steps or
reactants. Disturbance through movement may for pH adjustment. The wide application of these
cause mixing of these components and re- substances results frequently in residues and
initiation of ammonia gas production, resulting waste liquids of low pH becoming sources of
in pressurisation and catastrophic release of environmental contamination.
the contents.
In nearly all instances, ATS are marketed in the
Clandestine laboratory response units and fire form of the hydrochloride salt. A final stage in
and rescue services have standard operating the manufacture process for these substances is
procedures to deal with operations where the conversion of the drug from the free base oil
ammonia is being illegally handled. While it form to the corresponding solid hydrochloride
is unlikely that a responsible officer would be salt. This is achieved by the dissolution of the
confronted with an active process, it is possible drug in oil form into a suitable solvent, i.e. a
that a propane gas cylinder or other vessel solvent in which the oil is readily soluble but
containing incorrectly stored ammonia gas or the hydrochloride salt is insoluble. While a
gas producing reagents may be overlooked or number of solvents are suitable for this purpose,
concealed and remain on the site after response acetone, toluene and occasionally diethyl ether
units have departed. Should the responsible are most commonly used for this process. The
officer suspect such a device, or become aware salt formation can be achieved by the addition
of any persistent indication of ammonia through of hydrochloric acid directly to the drug/solvent
instrumental monitoring or smell at the site solution however this technique produces some
that cannot be readily accounted for, the officer undesirable characteristics in the final product.
should immediately vacate the premises and An alternative method for salt formation is the
notify police and/or emergency services of passage of gaseous hydrogen chloride through
their concerns. the solvent solution. Hydrogen chloride is rarely
sourced commercially but rather is generated at
All liquids at a clandestine laboratory not
the site using improvised equipment. Hydrogen
in a properly labelled container, or whose
chloride is liberated when hydrochloric acid is
appearance is not consistent with its label,
added to concentrated sulphuric acid.

Alternatively it can be produced by the action of be fully identified. Under these circumstances, it
dropping sulphuric acid onto sodium chloride. will be advisable for the responsible officer not
To carry out these processes, common domestic to proceed until preliminary chemical analysis
or industrial vessels are modified into gas is available to reveal details on the nature of the
generators to effect the mixing of reagents and processes leading to possible contamination.
to facilitate the containment and controlled
The choice of synthetic route selected by illicit
delivery of the gas by way of piping or tubing. In
laboratory operators will be determined by a
some instances, gas cylinders have been used
number of factors, including ease of access to
as generators to contain sulphuric acid and
precursor chemical substances required.
sodium chloride mixtures.
The use of non pressure rated non acid 5.2.4 Surface contamination inside a building
resistant vessels for this purpose poses an The following outlines procedures for testing the
extreme safety risk as catastrophic failure is interior of a building that is suspected of having
virtually assured if the vessel is sealed. Once been used as a clandestine laboratory for the
the reagents are mixed, there is no means production of illicit drugs or related chemical
to control or stop the evolution of the gas. processes.
Generators discarded by laboratory operators
will generate gas if disturbed as unspent Methylamphetamine synthesis (or “cooking”)
reagents are further mixed. These devices operations will contaminate inside surfaces of
are sources of contamination at sites either buildings with residual methylamphetamine.
through the slow sustained emission of the Studies have also established that smoking
strongly acidic hydrogen chloride, or through methylamphetamine will likewise contaminate
their contents being poured out into drains the inside surfaces of buildings with
or on to soils. Extensive corrosion of metal methylamphetamine. Regardless, the presence
fixtures, or severe decomposition of cement, of methylamphetamine on inside surfaces at a
grout or other building materials are indicators level of greater than 0.5 micrograms (µg) per
of possible contamination by hydrogen chloride 100cm² is considered unacceptable.
or the solutions used for its production. The In designing the sampling plan for inside a
responsible officer should be mindful that such building, the following guidelines are provided:
apparatus exists and in the event that one is
encountered at a site, police or emergency 1. At least five samples should be taken inside
services should be contacted. the building.
The processes outlined above represent those 2. Areas that show evidence of contamination
employed for methylamphetamine synthesis should be sampled.
in the majority of clandestine laboratories
3. Surfaces used in the drug manufacturing
seized nationally. It should be remembered
process should be sampled. If those
there are many other processes, and hence
surfaces have been removed, an area as
chemicals, which have been applied by illicit
close as practicable to that area should be
operators for the production of ATS drugs. It
sampled.
is essential that the responsible officer is in
possession of all information pertaining to the 4. Any room or area inhabited by a child
process activities conducted at the site to be under 16 years of age should be sampled at
assessed This can be achieved either through least once.
documentation and/or direct communication
5. Sampling may be achieved through the
with police and forensic services, to ensure the
collection of wipe or swab samples of
sampling plan and techniques developed for
100cm² areas of non-porous surfaces such
the site are appropriate to evaluate all possible
as mirrors, bench tops, painted walls, and
contaminant candidates. In some instances,
metal surfaces.
initial observations carried out at seizure will
not permit the exact nature of the processes to

6. The selection of appropriate wipe media 15. Quality assurance protocols should be
and solvent should be made in consultation followed. The person sampling should
with the laboratory where sample analysis change gloves immediately before taking
is to be conducted. The wipe must be free every sample. Sample containers will
of interfering substances and be capable of normally be glass containers with PTFE
absorbing the suspected analyte so as to (Teflon) lined screw caps. Samples of porous
provide a true representation of the surface materials can be sealed in plastic bags.
contamination present. (While isopropanol
16. Blanks should be taken at regular intervals.
dampened swabs are widely used,
The number of blanks should equate to
consultation with the analysing laboratory
approximately 10 per cent of the total
is still advised).
sample number.
7. The technique by which the wipe is
The standards described in Appendix 1,
manipulated to collect the sample must
‘Investigation Levels’ will apply, in particular:
be consistent and provide reproducible
recoveries of the analyte. 1. If the suspected drug being manufactured
is methylamphetamine, its concentration
8. A porous surface may be sampled
should not exceed 0.5µg/100cm².
by removing a 100cm2 portion of the
surface and submitting the entire portion 2. If the suspected drug is any other
for analysis. amphetamine type stimulant (e.g.
3,4-methylenedioxymethamphetamine,
9. Surfaces that appear to have been recently
MDMA; 3,4-methylenedioxyamphetamine,
cleaned should be avoided.
MDA; para-methoxyamphetamine, PMA),
10. Areas behind furniture or appliances should its concentration should not exceed
be avoided. 1.0µg/100cm².
11. If there is reason to suspect that adjacent 3. If iodine is being used in the manufacturing
buildings or structures are contaminated method, then its concentration in any wipe
(on the same property), then testing should not exceed 22µg/100cm².
should be extended to those buildings
or structures. 5.2.5 Checking for Volatile Organic Compounds
12. Ventilation ducts (if present) closest to Australian Standard AS 2986.1 – 2003
the area of drug manufacture should be “Workplace air quality – Sampling and analysis
sampled. In most circumstances a swab of volatile organic compounds by solvent
sample should be sufficient. desorption / gas chromatography Part 1:
Pumped sampling method” or Australian
13. If the building is a commercial or industrial Standard AS 2986.2 – 2003 “Workplace air
property, the sampling plan should check quality – Sampling and analysis of volatile
for contamination in every immediately organic compounds by solvent desorption/gas
adjacent room (joined by a doorway or chromatography Part 2: Diffusive sampling
ventilation duct) to where illicit drug method” should be used for the analysis of
preparation had taken place or where volatile organic compounds (VOC’s) in air.
chemicals had been stored. Notwithstanding the sampling plan in the
relevant standards, sampling should be targeted
14. Chain of custody protocols should be
to where contamination is likely.
followed. Each sample container should
be uniquely labelled as the sample is In designing the sampling plan for testing for
placed within it, and each sample should VOC’s, the following guidelines should apply:
always be either under the control of
an authorised person or sealed in an 1. Each room where a chemical process
appropriate bag or container. was thought to have taken place should
be sampled.

2. Each room where chemicals or equipment Any samples taken under this section shall
was thought to have been stored should comply with chain of custody and quality
be sampled. assurance protocols as described in section
5.2.4 (items 14, 15 and 16).
3. Each room where there is evidence of
spillage or staining should be sampled. 5.2.7 Sampling soils, surface water and
4. Any bedroom or play room of a child under groundwater
16 years of age should be sampled. Waste from clandestine laboratories is seldom
disposed of lawfully and is often stored at
Any samples taken under this section should
the sites or poured on the ground near the
comply with chain of custody and quality
clandestine laboratory site, down a municipal
assurance protocols as outlined in these
drain or into a watercourse directly. In
Guidelines.
designing the sampling plan for sampling soils,
5.2.6 Wastewater contamination groundwater, and surface waters, the following
guidelines should apply:
As outlined in 5.2.2, waste from illicit drug
production is often poured into the wastewater 1. Any soil that shows evidence of
system of the dwelling. That wastewater can be contamination shall be sampled.
directed to the storm sewer system, a sanitary
2. Soil sampling should be systematic, with
sewer system flowing into a municipal treatment
judgemental sampling applied to areas of
system, or a sanitary sewer system flowing into
suspected contamination.
a septic tank. Each of these possibilities will be
discussed separately. 3. At least one sample should be taken
from the septic bed (tank) (if present) on
If the wastewater flows into the storm sewer
the property.
system, the dynamics of that system should be
examined to determine whether sampling is 4. If there is no evidence of contamination, at
needed. (If there has been a large amount of least two soil samples should be taken from
recent rainfall and illicit drug production has the property, close to well travelled paths.
been minimal in the recent past, analysis is
5. Groundwater should be sampled if the
likely not necessary unless there is evidence of
responsible officer considers, in their
an affected area.)
professional opinion, that sufficient risk to
If the wastewater flows into a municipal groundwater integrity exists based on site
sewage system, it has likely been diluted factors such as the presence of existing
to the point that detection of any of the groundwater bores, drug waste disposal on
contaminants is unlikely. The responsible site, shallow groundwater (within 15 metres
officer may nevertheless decide that it would of surface) or the presence of deep pits on
be advisable to inform the local utility in charge the site.
of wastewater treatment to check for some of
6. If there is a watercourse flowing through
the contaminants in the relevant reaction list.
the property, it may be sampled if there
This will be particularly relevant where the local
is any evidence of contamination (for
municipality recycles such water.
example visible surface film, bleaching or
If there is any evidence of clandestine laboratory crystallisation at waters edge or fish kill).
activity in a dwelling whose wastewater flows
7. Sampling should be conducted in
into a septic tank, all chambers of the tank
accordance with the NEPC publication
should be pumped out and the contents taken to
Schedule B(2) Guideline on Data Collection,
a wastewater processing facility. In addition, at
Sample Design and Reporting which
least one soil sample from the septic bed should
includes discussion on sampling soils,
be analysed. See section 5.2.7 regarding the
groundwater and watercourses for
sampling of soil.
environmental contamination.

The sampling plan is to follow the relevant The ILs have been derived using an approach
guidelines stated in NEPC publications. that is consistent with the derivation of NEPM
2011 HILs. The NEPM HILs only provide
8. Any samples taken under this section
guidelines for a limited number of chemicals
should comply with chain of custody and
in soil under a range of different land use
quality assurance protocols as described in
scenarios. The ILs derived as part of the present
section 5.2.4 (items 14, 15 and 16) and the
Guidelines follow an approach consistent with
data quality objective stated in Appendix 2 of
the NEPM HILs, for the same key land uses;
this document.
however they address the presence of key
chemicals in all media significantly impacted
5.3 Assessment criteria
by operations at a clandestine laboratory,
The ILs table is provided in Appendix 1 of namely soil (outdoors), air (indoors) and surface
this document and should be used for the residues (indoors).
assessment of analytical data obtained from the
investigation of sites. Investigation of potential It is noted that a number of guidelines
surface water or groundwater contamination, associated with the assessment and
where required, should be assessed against remediation of former sites are available in
relevant NEPM’s, The Australian and New the United States. These guidelines focus
Zealand Guidelines for Fresh and Marine Water on a limited number of compounds (mainly
Quality Guidelines or applicable state or territory methylamphetamine, VOCs as a group, lead
endorsed guidelines. and mercury). Many of the guidelines are based
on analytical limits of detection rather than
Due to the unique nature of clandestine protection of human health or the environment
laboratories and the contaminants they produce, and hence a more detailed review of illicit
the assessment criteria for these guidelines methods applied in Australia and identification
have been derived with reference to three of key compounds associated with these
primary documents1. methods has been undertaken.
Where required, additional guidance has
5.4 Remediation Action Plans
been obtained from relevant Australian and
international guidelines which are consistent This section provides guidance on the
with current industry best practice and relevant development and implementation of
to the exposures that require consideration for Remediation Action Plans (RAPs) at
clandestine laboratories. contaminated sites. It is important to note,
RAP’s for clandestine laboratories are not
With respect to the protection of the dissimilar to RAP’s which would be prepared
environment, published screening level for other contaminated sites within each state
guidelines (threshold or benchmarks) relevant or territory.
to the protection of the terrestrial or aquatic
environments have been referenced including RAPs are developed to address the issue of
NEPM’s and The Australian and New Zealand site contamination and remediation options
Guidelines for Fresh and Marine Water Quality and form a part of the contaminated site
Guidelines. These guidelines remain appropriate investigation process. The broad purpose of
for investigation of aquatic environments. RAPs is to establish remediation goals to ensure
contaminated sites, once remediated, will be
1
suitable for their proposed use and will not pose
• enHealth “Environmental Health Risk Assessment,
an unacceptable risk to human or environmental
Guidelines for Assessing Human Health Risks from health and delineate the evidence clearly
Environmental Hazards”,2011, in press]; to support the RAP. In order to achieve this,
• National Environment Protection (Assessment of Site the RAP should document in detail all of the
Contamination) Measure (NEPM), draft variation, 2011. procedures and plans that will be implemented
• enHealth “The Australian Exposure Factors Handbook” to reduce risks to acceptable levels as well
2011, in press.

as establish environmental safeguards to The current lot or plan (real property)
complete the remediation in an environmentally descriptions of all affected parcels and the
acceptable manner. The preparation of a RAP street or lot number and name of suburb are to
for clandestine laboratory sites requires the be provided. Where multiple lots are involved,
following components be addressed: plans which show lot boundaries in relation to
significant features should be provided. Maps
• Site information;
(including street map copies), plans or diagrams
• Site characterisation; should be used to clearly identify the location of
all affected parcels in relation to surrounds, for
• Remediation goal; example street access, neighbouring property
• Extent of remediation required; boundaries, parks, local watercourses and any
areas of environmental significance.
• Remediation options/ hierarchy of
remediation for structures; 5.4.2 Site characterisation
• Remediation options- environmental; The purpose of the site characterisation is to
assess the type and extent of contamination
• Building decontamination management plan; existing or potentially existing on the site. The site
• Environmental Management Plan; characterisation should include an assessment
of the type of environmental contamination
• Proposed testing for validation; including soil and groundwater contamination
• Contingency plan (for remediation failure); and chemical degradation products as well
as potential contamination of structures (For
• Site Management Plans; and example rooms, houses, sheds) and materials
(For example carpet, fittings). This information
• Remediation schedule.
should be sourced from the site investigation.
5.4.1 Site information This section should include a record of the
The purpose of the site information is to following (if known):
identify potential contaminants and areas of
• Known or suspected chemicals used;
contamination by site history and investigations
including a review of information sourced • Identification of chemical storage areas;
from the law enforcement agency responsible
• Identification of areas where chemical
for discovery/evaluation of the site. The key
processes (or ‘cooks’) were conducted;
information will relate to the type of reaction
being undertaken at the site (if known) and • Information on synthesis methods;
the locations where reactions are known or
suspected of having occurred. • Evidence of waste disposal methods and/or
areas;
If known, information should be gathered on
the illicit substances manufactured and the • Evidence of chemical stains, fire damage or
methods used. The identity of the drug(s) and/ other contamination;
or precursor chemicals being manufactured, the • Information about the premises- surfaces,
synthesis methods used and the stage at which fixtures, furnishings;
manufacture was disrupted (or reached) are all
important factors which have significant bearing • Evidence of discoloured soils;
on the chemicals and reaction by-products, • Evidence of dead vegetation;
and hence the nature of the contamination that
may be found at the site. Additionally, evidence • A summary of materials removed from the
of drug use, chemical spills and disposal of site in the initial seizure; and
chemicals within the premises will influence the
• Findings of any laboratory analysis carried
type and extent of contamination.
out during investigation.

5.4.3 Remediation goal regularly display ‘hand to mouth’ and ‘hand to
The purpose of the site remediation goal is to eye’ behaviour which introduces the possibility
identify the desired outcome of the remediation of additional exposure to residual contamination
works and the intended future use/s of the site. by ingestion or through eye contact.
In general, the remediation goal is to ensure
5.4.5 Remediation options/ hierarchy of
the contaminated site, once remediated, will be
remediation for structures
suitable for its proposed use.
In general, the remediation option(s)/
5.4.4 Extent of remediation required requirement(s) will be dependent on the state
The purpose of this section is to determine the of the site, the chemicals found, processes
extent of remediation that will be required for used and the period of time the clandestine
a site. This will need to be determined on a laboratory was active. It is likely however that
site-specific basis. comprehensive information on each of these
variables may not be available in all instances.
The facilities in which illicit drugs can be For structures, the requirements may range
manufactured vary from small clandestine from a simple ‘clean-up’ of a site through
laboratories through to industrial scale venting, detergent scrubbing, neutralization,
operations. These laboratories have been enclosure or encapsulation through to the
discovered in a range of locations including demolition of a contaminated structure.
urban and rural premises, motor vehicles and
caravans, demountable homes and motel rooms. For structures, remediation options
The nature and size of the site, the substances are determined through a hierarchical
being manufactured, the extent of contamination approach. Different remediation options and
and future land uses all influence the extent methodologies include:
of remediation required. Similarly, the risk of Clean Up/Wash Up
harm that former clandestine laboratories
potentially pose to human health will depend on • Ventilation;
the particular chemicals and the concentrations • Detergent washing surfaces followed by
at which they are present, and the potential rinsing with water;
routes available for human exposure. The extent
of remediation required, therefore, should be • Vacuuming surfaces with high efficiency
determined with regard to the following: particulate air vacuums;
Accessibility of residues, and frequency of • Steam cleaning/ high pressure cleaning;

direct contact • Neutralization of surfaces with weak acids/
The likely future use of a former site is an bases; and
important factor in estimating the frequency of • Flushing pipes with water.
human contact. For example, surfaces bearing
residues in a kitchen or bathroom of a house Stripping/Encapsulation
will likely be subject to contact more frequently
than residues in a non-residential outbuilding. • Removal of all structure contents, including
appliances, furnishings, floor coverings,
Characteristics of the inhabitants or users of curtains, blinds, panelling, drywall and
the structure wallpapers;
Information on likely future occupancy of a • Cleaning and vacuuming;

former site is important in estimating the harm
• Sealing of surfaces with paints or other
that contact may pose. For example, crawling
materials;
toddlers will have a high frequency of skin
contact, and hence likely skin absorption with any • Disposal of contents/stripped materials; and
residues present on flooring. Children of this age
• Flushing pipes with water.

Demolition as to provide positive pressure ventilation to
the premises. Where possible, increasing the
• Removal of all structure contents;
temperature above 24°C also aids in the removal
• Demolition of structure; and of volatile chemicals.
• Disposal of structure/contents. If any materials are to be removed from the
site for cleaning through an external cleaning
Clean Up/Wash Up service, the items should be vacuumed first
In some cases, decontamination and and “bagged” or contained in a suitable vessel
remediation of former clandestine laboratory for transport. In addition, the cleaning service
sites may be accomplished through a ‘clean up/ should be notified in writing prior to receiving
wash up’ process. In these cases, nonporous the materials to notify them that the materials
and semi-porous surfaces such as windows, are from a former clandestine laboratory and
floors, tiles, walls, ceilings and other fixtures therefore potentially chemically contaminated.
may be decontaminated by scrubbing with
Stripping/Encapsulation
solutions of detergent and water. If the
contamination of porous materials such as When the extent or degree of contamination
carpeting and curtains is deemed to be minimal, is too great to be removed by clean-up/wash
they may also be decontaminated through up processes the structure and/or its surfaces
washing and vacuuming (commercial grade may require stripping, encapsulation and/or
vacuum cleaners equipped with HEPA dust removal. This may include furnishings, carpet,
collection systems are recommended). Large rugs, curtains, blinds, panelling, drywall and
areas of contamination may be steam cleaned wallpaper. All materials removed from a
or cleaned with high-pressure washers. clandestine laboratory must be legally disposed
of according to the nature of the material and/
If acids or bases have been used in the
or degree of contamination. Some materials
manufacturing process the potential
may not be suitable for general landfill and may
contamination may be reduced or removed
require disposal by a licensed contractor to an
through neutralization. For acids, neutralization
appropriate waste facility.
may be achieved by washing with solutions
of sodium bicarbonate, and for bases, Risks associated with contaminated surfaces
neutralization may be achieved by washing with may further be reduced by cleaning and
dilute solutions of acetic acid in water. vacuuming and encapsulation or sealing the
contaminated surfaces with layers of oil-based
It is important to ensure former sites are
paint, polyurethane or other materials.
well ventilated to assist in reducing airborne
contamination and decreasing odours when Demolition
undertaking remediation works. This form of
contamination can arise from the spillage and In cases where contamination is extreme,
subsequent absorption of liquids during former adequate remediation may not be achievable
laboratory operations and processes. While through washing, stripping or encapsulation
many solvents can effectively be eliminated and therefore may require the demolition of
through ventilation, liquid chemicals with the contaminated structure. All demolition
low vapour pressures may frequently prove materials must be legally disposed of according
resistant to this treatment. Ventilation may to the nature of the material and the type
be performed by opening windows and doors and degree of contamination. It should be
to facilitate cross-ventilation or be provided anticipated that, where demolition is required,
with the assistance of mechanical fans. In extensively contaminated materials will
instances where contamination arising from not be suitable for general landfill and will
flammable organic solvents is suspected, it require disposal by a licensed contractor to an
is recommended that the fans deployed are appropriate waste facility.
either (i) spark proof or (ii) are so arranged

Demolition should be considered when the • Some chemicals may have been spilled or
building and/or its associated structures deposited ad hoc (for example buried or
have suffered structural damage, for example incinerated) in soil depressions or ‘burn-
through explosion or fire. pits’. In these instances, the site may require
soil remediation or excavation to remove the
Recommendation for demolition should be
actual/ potentially contaminated material.
justified and reported in detail to the responsible
Following remedial actions, the surrounding
authority, and be accompanied by the required
soil or sediment will require validation testing.
analytical data to justify the decision based on
a risk assessment model. In most cases this Remediation of groundwater and surface water
will also require the responsible authority or
jurisdictional health department to declare the Contamination of groundwater by VOCs has been
dwelling unfit for habitation, and condemned, identified as a primary environmental hazard
by exercising their powers under the relevant caused by the manufacturing and processing
health/building or related acts and regulations. of illicit substances in clandestine laboratories.
Where initial site investigations reveal
5.4.6 Remediation options – environment contaminated groundwater, the remediation plan
will be required to detail methodologies to reduce
Chemicals associated with clandestine
contamination. The plan should incorporate
laboratories are often released both
follow up validation testing to confirm the
intentionally and unintentionally into the
success of the remediation activity.
environment. For example chemicals may
be spilled, buried, burned or disposed of into (Section 2.2 of schedule B(6) of NEPC1999
sinks, toilets, sewerage system and waste provides a clear framework for remediation
management facilities or piped directly onto soil. planning when groundwater assessment is
Once released, these chemicals may undergo required.)
processes such as sorption, degradation or
Alternatively, wastes from clandestine laboratory
leaching and thereby contaminate soil, sediment
operations may have been spilled or directly
and surface and groundwater. Such releases
discharged into surface waters including
have clear implications for human health and
ponds, dams, streams, lakes, wetlands and
the environment.
seasonally flooded areas. Where initial site
Where relevant, remediation of environmental investigations reveal contaminated surface
matrices may need to be addressed. This type of water, the remediation plan will be required to
contamination will require different remediation detail methodologies of reducing contamination.
plans to those developed for contaminated The plan should incorporate follow up
structures. validation testing to confirm the success of the
remediation activity.
Remediation of soils and sediments
Septic systems
The RAP should address the type and extent of
contamination and include details of the most Septic systems are often found on rural
feasible remediation options. The RAP should and semi-rural properties. If a clandestine
detail: laboratory has been operating on a property
with a septic system, it is possible chemicals
• The methods/technology to be used;
may have been dumped into the system. If
• The expected by-products, wastes, information or indicators suggest this may have
discharges and outputs (including the occurred, all plumbing and traps should be
management of these substances); and flushed thoroughly with cold water before the
septic system is pumped out. Effluent should be
• Any “clean” materials to be brought onto discharged to an appropriate water treatment
the site. facility. Management of the septic system needs
to be included in the RAP.

5.4.7 Proposed testing for validation Decontamination Management Plan (BDMP)
The purpose of validation testing is to confirm must be developed and form part of the RAP.
the success of the remediation plan by The BDMP should be structured to provide
reassessing levels of contamination and details on each environmental and OH&S impact
comparing findings to those of the site and the measures to be implemented to ensure
investigation. Testing that was initially conducted their correct management.
as part of the Stage 2 Investigation should at a For each of the proposed remedial options
minimum be replicated for all remediated a number of potential issues need to be
surfaces. An outline of the required validation addressed, see Appendix 2 – Reporting and Data
sampling should be included in the RAP. Quality Objectives.
5.4.8 Contingency plan 5.6 Environmental Management Plan

The purpose of a contingency plan is to provide To ensure all decontamination and remediation
another option to address the remediation of a procedures at former sites are undertaken in
site in the event that the selected remediation a manner that causes no undue harm to the
plan does not fulfil the remediation goal. environment an Environmental Management
Plan (EMP) must be developed. The aim of
5.4.9 Site management plan
an EMP is to ensure adequate consideration
The purpose of the site management plan is is given to the environment during the
to establish environmental and occupational decontamination of sites.
health and safety (OH&S) safeguards necessary
to complete the remediation in a manner that is An EMP allows the site remediators to
environmentally acceptable and which poses no reduce their impacts through environmental
risk to workers or the general public. The site management. In order to be able to manage
management plan will incorporate a number any potential environmental impacts, a
of more detailed individual plans that may be process must be undertaken to review all
applicable to each individual site. These plans decontamination/remediation activities and their
may only be necessary where the consultant potential for impacts, including impacts to the
determines, based on professional judgement, air, water, land, waste and noise.
that such a plan is required. Such plans An EMP outlines the actions required to manage
might include: environment impacts from the decontamination/
• Storm water management; remediation activities. The format of the EMP
is such that it should include (at a minimum)
• Soil management; the objective, the impact and aspect, the
control measures, monitoring and reporting
• Noise control;
requirements.
• Dust control;
The EMP may encompass and or consolidate
• Odour control; or the plans already mentioned above into a single
management plan.
• OH&S.
For each of the decontamination/remediation
5.5 Building Decontamination options a number of potential issues need to
Management Plan be addressed – see Appendix 2 – Reporting and
Data Quality Objectives.
To ensure all decontamination and remediation
procedures of clandestine laboratory buildings
and associated structures are undertaken in
a manner that does not pose a risk to human
health and the environment (including workers/
contractors, the general public) a Building

6. GUIDELINES FOR
PHASE FOUR – VALIDATION
6.1 Site validation • Re-sampling of surfaces from which initial

samples were taken;
Following remediation, a site must be ‘validated’
to ensure that the objectives stated in the RAP • Sampling of areas which are expected to
have been achieved. The details of the site have frequent contact, for example. kitchens
validation are compiled and presented in a and bathrooms; and
Validation Report.
• A combination of swab sampling and
At former sites the extent of validation required sampling for VOCs where required.
will depend on:
The validation of a building or structure prior to
• The type, concentration and quantity of re-occupancy is important to human health. In
contamination originally present; many instances a greater number of samples
will be taken at this stage in comparison
• The type of remediation processes that were
to the initial contamination investigation.
carried out; and
If contaminant levels are found to be above
• The proposed land use, for example the ILs then the area of concern must be
residential or other sensitive land use, re-cleaned or treated, or another remediation
commercial/industrial or public open space. option considered. The site is only deemed to
be validated once all samples are below their
Validation will be required on all areas
corresponding ILs stated in this document
remediated including, dwellings, structures and
(Appendix 1 – Summary of Investigation Levels
the environment.
(ILs) in the Assessment of former Clandestine
Lab Sites).
6.2 Validation of buildings and
structures 6.3 Validation of land
After remediation of a building or structure The environmental component of site validation,
small amounts of residual chemicals may or validation of land, will include soil, surface
remain and thus sampling should be undertaken water and groundwater. The validation
to ensure the objectives stated in the RAP requirements will vary depending on the nature
have been achieved and levels of chemicals and extent of contamination and the remediation
adequately reduced. The extent of the validation procedures employed.
sampling required will depend on:
• The preliminary assessment information; 6.4 Soil validation
• The chemicals used or found at the site; Following remediation of soil, sampling is
required to validate the site and confirm that
• The known or expected extent and severity of the remediation was successful in removing
pre-remediation contamination; (or adequately reducing) contamination.
Sufficient samples will be required in order to
• The type of remediation processes carried
be considered representative of the remediated
out;
area on the site.
• The proposed occupancy of the building or
Existing sampling design guidelines within each
structure; and
state or territory should be used to determine
• Professional judgement. appropriate sampling design and density, and
be considered the default guideline for this type
In general, the validation of a building or of validation. Alternately the sampling design
structure should include: and methodology detailed in Schedule B (2)
• A general inspection of the site to check for Guideline on Data Collection, Sampling Design
re-staining or odours; and Reporting, NEPM may provide guidance.

Compositing of samples is not considered For naturally occurring wetlands, validation
appropriate. sampling should be undertaken in ‘dry’
conditions and after a rain event. Samples
Where soil has been excavated, for example
should be collected from the sediment and from
where a pit was dug to remove contaminated
the overlying water.
soil or ash material, sampling should be
conducted as per relevant local requirements If contamination is detected in the sediment or
for the validation of excavations or underground surface water samples after remediation, the
storage tank excavations. These requirements remediation procedure should be repeated, or
vary from state to state, but generally require alternatively, a different remediation technique
samples be collected in a systematic pattern should be employed. Validation testing is
across the floor and walls of an excavation. required until the contamination is reduced to a
level that no longer represents a risk to human
If soil contamination is detected after
health or the environment.
remediation, the remediation procedure
should be repeated, or alternatively, a different If contamination was originally detected or
remediation technique should be employed. suspected to be present in moving water bodies
Validation testing is required until the soil such as creeks and streams, or in storm water
contamination is reduced to a level that no drains, sampling should be undertaken once
longer represents a risk to human health or under low flow conditions and once under
the environment. higher flow (rain event) conditions to validate the
site.
Monitored natural attenuation, particularly of
hydrocarbon contamination may be considered 6.6 Groundwater validation
an appropriate remedial technique within
some jurisdictions where no potential exposure The need for remediation or validation of
pathway exists for site occupants. groundwater in response to a clandestine
laboratory is unlikely, unless waste has been
6.5 Surface water validation either directly deposited into an existing
groundwater bore or deposited into the ground
Each state and territory within Australia has a
at a location with a high and water table.
specified standard for the sampling and analysis
of waters. The standards are generally based on Following any remediation of groundwater,
the Australian and New Zealand Environment samples should be collected from appropriate
and Conservation Council Guidelines. groundwater monitoring bores quarterly or
until contamination is reduced to levels that no
Sampling design and analysis for surface waters
longer represents a risk to human health or
should be developed in accordance with relevant
the environment.
local guidelines and/or Australian Guidelines for
Water Quality Monitoring and Reporting (2000),
and Australian and New Zealand Guidelines for
Fresh and Marine Water Quality (2000).
The sampling design and frequency required
to validate surface water will be dependant
largely on the type of water body also (for
example natural or man-made, dam, pond,
wetland, or creek).
For example if water was pumped or removed
from a pond or dam, sediment samples should
be taken from the walls and floor when the pond
or dam is dry and water samples should be
collected when the pond or dam has refilled.

7. References and
Resource Documents
• The National Environment Protection Council • Department of Health and Aging. (2008).
(NEPC) 1999 Schedule B (2) ‘Guideline Development of Health standards for the
on Data Collection, Sample Design and Remediation of Clandestine Drug Laboratory
Reporting.’ Sites- Scoping Project.
http://www.ephc.gov.au/sites/default/ http://health.utah.gov/meth/html/
files/ASC_NEPMsch__02_Data_ Decontamination/AdditionalResources.html
Collection_199912.pdf
• Scott, T.L., Janusz, A., Perkins, M.V.,
• NSW EPA 2000 Guidelines for Consultants Megharaj, M., Naidu, R., Kirkbride, K.P.,
Reporting on Contaminated Sites ‘Effect of amphetamine precursors and by-
http://www.environment.nsw.gov.au/ products on soil enzymes of two urban soils.’
resources/clm/97104consultantsglines.pdf (2003). Bull. Environ. Contam.Toxicol: 70:
824-831.
• EPA Guidelines for Environmental
management of on-site remediation • Janusz, A., Kirkbride, K.P., Scott, T.L., Naidu,
R., Perkins, M.V., Megharaj, M.
http://www.epa.sa.gov.au/pdfs/guide_
remediation.pdf • ‘Microbial degradation of illicit drugs,
their precursors, and manufacturing by-
• Alaska Department of Environmental
products: implications for clandestine drug
Conservation. Guidance and Standards for
laboratory investigation and environmental
Cleanup of Illegal Drug Manufacturing Sites.
assessment.’ (2003). Forensic Science
2007, Revision 1.
International 134: 62-71.
http://www.methlabcleanup.com/AK%20
Standards • Pal, R., Mallavarapu, M., Naidu, R., Kirkbride,
P., (2009) Illicit Drug Laboratories and the
• Ministry of Health, Manatu Hauora, Environment. University of South Australia.
New Zealand. (2008). Draft Guidelines
for the Site Remediation of Clandestine • Abdulla, A.F., Miskelly, G.M., Yew, C.H., (2010)
Methamphetamine Laboratories. ‘Quality scientific approach for remediating
and analysing clandestine laboratory
• Minnesota Department of Health (MDH) and residues.’ Malaysian Journal of Chemistry
Minnesota Pollution Control Agency (MPCA). 12:1: 001-008.
(2007). Clandestine Drug Lab General
Cleanup Guidance.
http://www.health.state.mn.us/divs/eh/meth/
lab/guidance0407.pdf
• Colorado Department of Public Health
and Environment. Cleanup of Clandestine
Methamphetamine Labs Guidance
Document. 2007 Revision.
http://www.cdphe.state.co.us/hm/methlab.
pdf
• New Mexico Environment Department.
Clandestine Drug Laboratory Remediation
http://www.nmcpr.state.nm.us/nmac/parts/
title20/20.004.0005.htm

28
Appendix 1: Summary of Investigation Levels (ILs) – Assessment of
Former Clandestine Lab Sites
Residential (A) Recreational (E) Commercial/Industrial (F) Environmental #
Indoor Criteria Outdoor Outdoor Indoor Criteria Outdoors Outdoors
Surface Air Soil Soil Surface Air Soil Soil Water
Key Chemical (µg/100cm2) (mg/m3) (mg/kg) (mg/kg) (µg/100cm2) (mg/m3) (mg/kg) (mg/kg) (mg/L)
Methamphetamine 0.5 b 5 5 10 b 45 x x
MDMA 7 b 60 60 130 b 600 x x
Pseudo/Ephedrine 600 b 6000 6000 10000 b 50000 x x-
Ammonia a 0.1 1800 1800 a 0.3 10000 x 0.9AFM*
Iodine 20 0.0008 2 2 450 0.003 6 4U x
U
Bromide 2000 0.0008 2 2 50000 0.003 4 10 x
Phosphorus 0.07 b 0.6 0.6 2 b 7 x AFM**
N-Methylformamide 10 b 120 120 270 b 1200 x x
Methylamine a 0.004 70 70 a 0.01 600 x x
Clandestine Drug Laboratory Remediation Guidelines

Nitroethane a 0.4 4400 4400 a 1 20000 x x
Boron and compounds 1800 b 3000 (N) 6000 (N) 40000 b 15000 (N) 0.5U 0.37AF, 5.1AM
Mercury (inorganic) 35 b 15 (N) 30 (N) 800 b 75 (N) 1 (NE) 0.0006AF, 0.004AM
Lithium 46 b 230 230 1000 b 5700 2U 0.014U
Benzaldehyde 1500 0.4 6300 6300 35000 1 35000 0.6O 0.01O
Phosphine a 0.0004 c c a 0.001 c x x
Safrole and isosafrole 16 0.0002 1 1 16 0.001 6 0.4U x
APPENDICES
Chloroform a 0.1 240 240 a 0.4 1400 1.2U, 170R 0.37AFM

Dichloromethane a 1 120 120 a 4 3300 4U,D 4AFM
R
Benzene a 0.0095 (A) 1 (S) 1 (S) a 0.0095 (A) 1 (S) 210 0.95AF, 0.5AM
Toluene a 0.4 (A) 130 (S) 130 (S) a 0.4 (A) 130 (S) 1.4 (S) 0.18AFM
Ethylbenzene a 26 50 (S) 50 (S) a 80 50 (S) 3.1 (S) 0.08AF, 0.005AM
Xylenes a 0.9 (A) 25 (S) 25 (S) a 0.9 (A) 25 (S) 14 (S) 0.2 to 0.35AFM
TPH
C6-C9 (aliphatic)^^ a 0.8 1800 1800 a 3 4000 130C x
C10-C14 a 0.2 1000 (S) C10-C36, 1000 (S) C10-C36, a 0.7 1000 (S) C10-C36, 150C x
C15+ C
140 b 90 (N) 180 (N) 3000 b 450 (N) 400 x
pH 6.5-8.5 b 6.5-8.5 6.5-8.5 6.5-8.5 b 6.5-8.5 x (6 to 9) A**
Notes for Table above (refer to Environmental Risk Sciences [2009] report for full detail on derivation):
a No surface residue IL has been derived for these key chemicals as they are considered volatile and would not be present as surface residues (or dust) for sufficient time
to be of concern.
b No indoor air IL has been derived for these key chemicals. Only volatile chemicals (or gases) have been considered as they may continue to off-gas from porous surfaces
over time.
c No soil IL has been derived for phosphine gas as it is not expected to be present in outdoor soil for sufficient time to be of concern.
x No Tier 1 or screening level guidelines are available for these chemicals from peer reviewed sources that are relevant to the protection of the terrestrial or aquatic
environments.
^^ IL derived for TPH fractions C6-C9 are for the aliphatic fraction. This is calculated based on the total TPH C6-C9 reported minus total BTEX (the major contributors to
aromatics).
A Monitoring Investigation Levels are available and presented for benzene, toluene and xylenes in air as per NEPM (2004), converted (at STP) from ppmv to mg/m3.
Values relevant to chronic exposures (annual averages) have been presented for use in preference to derived ILs. Derived ILs are noted in the calculations presented in
Appendices C to E of the Environmental Risk Sciences (2009) report and can be referenced where relevant. ILs adopted should reflect any changes to NEPM guidelines.
N Investigation Levels are available from NEPM (1999b) for these chemicals in soil and are presented in this table, relevant to the land-use. Derived ILs are noted in the
calculations presented in Appendices C to ED of the Environmental Risk Sciences (2009) report and can be referenced where relevant. ILs adopted should reflect any
changes to NEPM guidelines.
NE Ecological Investigation Level available for mercury from NEPM (1999b) presented in this table. ILs adopted should reflect any changes to NEPM guidelines.
S No NEPM values are currently available, however ILs presented in NSW EPA Service Station Guidelines (1994) are commonly adopted as ILs in Australia. These
are presented in the table. Exceptions are in Queensland where state specific values should be considered. Derived ILs are noted in the calculations presented in
Appendices C to E of the Environmental Risk Sciences (2009) report and can be referenced where relevant. ILs adopted should reflect changes to state guidelines and/or
release of relevant NEPM guidelines.
# Environmental Screening Guidelines available from a ranges of peer-reviewed sources. Qualifiers noted in table refer to source of guidelines available as follows:
A = available from ANZECC/ARMCANZ (2000) for:
F = freshwater
M = marine water
* Guideline for ammonia based on pH of 8, guideline must be adjusted for other pH levels
** Range of guidelines available for phosphorous and pH in water for a range of ecosystems in different areas of Australia, refer to guidance document for relevant values
U = available from USEPA Region 5 or 6
R = Guideline available from RIVM (2001)
O = Guideline available from OECD (2005)
C = Guideline available from CCME (2000, 2008)
Clandestine Drug Laboratory Remediation Guidelines

29
Appendix 2: Reporting and The outcome of the DQO process is a clear guide
to data collection activities that are focused
Data Quality Objectives on collecting information needed to answer
questions that will lead to decisions being made
Reporting about the contamination on a site. In addition,
In general, each investigation report should the DQO process must include a plan for actions
contain the following sections either in detail or to be undertaken should the data not meet the
in summary: expected DQO.
• Executive summary; The DQO process
• Scope of work; The DQO process comprises seven steps that
build upon the initial statement of the problem
• Site identification;
to be addressed by the investigation (Step 1)
• Site history; to arrive at a framework for data collection,
quality control and assurance (Step 7). The
• Site conditions and surrounding
DQO process, as defined by the United States
environment;
Environment Protection Agency is as follows:
• Geology and hydrogeology;
Step 1 – State the problem
• Data Quality Objectives;
This step defines the questions that are to be
• Sampling and analysis plan and sampling answered by the investigation and identifies
methodology; the resources available to resolve the problem.
A conceptual site model is developed during
• Field and laboratory Quality Assurance and
this step.
Quality Control (QA/QC);
The following matters must be addressed
• QA/QC data evaluation;
during Step 1:
• Basis for assessment criteria;
• Objectives of the investigation or validation
• Results; must be defined and a consideration made of
the limits on the ability to meet the objectives
• Site characterisation; and that may be imposed by constraints such as
• Conclusions and recommendations. time, budget or site access;
Reporting requirement for RAP’s are detailed • Based on current knowledge of the
under Section 5.4. site, a brief summary is prepared of the
contamination issues known and expected
Data Quality Objectives and which are to be addressed by the
investigation or validation;
Establishment of Data Quality Objectives
(DQO) ensures that a study is carried out in • A reason must be provided for why
a structured way with the objectives stated the investigation or validation is being
initially, and the questions significant to attaining completed;
the objectives of the study defined early . In this
way, the data collected are appropriate and of • The composition and structure of
sufficient quality to allow decisions to be made the investigation team and members
about the site with respect to the contamination responsibilities must be provided;
status. A unique set of DQO must be established • Other factors that may impact on the design
for each site to be investigated or validated prior and implementation of the investigation
to the study commencing. or validation such as budget, community
relations, access limits must be considered;
• The regulatory authorities and the local
government area must be identified.

The outputs from this step should include: • What information should be obtained that
will allow decisions to be made so that the
• A clear definition of the problem to be
decision statement can be resolved;
addressed by the investigation;
• Which media (for example, soil/fill,
• A clear statement of the objectives of the
groundwater, sediment, carpet, paint) need to
investigation or validation;
be sampled;
• The composition of the investigation team
• What criteria are to be used to assess
and the responsibilities of its members
each medium;
including identification of the decision-
maker; and • What analytical methods for the chemicals
of concern are going to allow meaningful
• A conceptual model of contamination on the
assessment against the criteria;
investigation site based on a review of the
history and background of the site and of • Definition of the basis for decisions made from
past and present activities on the site. field screening instruments and methods;
The conceptual model of the site should • Any other information required to make a
be progressively refined throughout the decision; and
investigation process as additional inputs
• The outputs from this step are considered to
are obtained.
be a starting point for refinement during later
Step 2 – Identify the decision steps in the process, notably, in Step 7.
This step identifies the decisions that need to Step 4 – Define the study boundaries
be made to address the contamination issues
This step defines the spatial and temporal
on the site and what data are required to make
boundaries of the study to ensure that the data
the decisions. Based on the conceptual model
collected are representative.
of site contamination developed in Step 1, the
decision statements should link the problem The spatial boundaries of the study include
statement, also made in Step 1, to the data property boundaries, access to areas of the
collection part of the investigation or validation site and potential exposure areas. Physical
program. Acceptance criteria for each medium constraints to collection of a complete data set,
must be considered. for example, water bodies, fences or buildings,
should be defined in this step. The potential
An example of a decision statement is “Does
distribution, particularly on larger sites, of
contamination in the soil represent a significant
areas in which contamination is expected to
risk to human health or environmental given the
be uniformly distributed should be defined
proposed land use?”
so that appropriate chemicals of concern,
Step 3 – Identify inputs to decision sampling depths and media are considered, as
appropriate, for each area of the site.
This step identifies the information that is
needed to resolve the decision statements. The temporal boundaries of the study may be
When identifying the inputs, consideration constrained by seasonal conditions (for example,
should be given to the following: the effect of heavy rain or drought on the ability
to sample the soil), access restrictions (for
• What information is needed to resolve the example what times is the site open), availability
decision statement (for example, what is the of key personnel (for example, when will
proposed land use for the site?); personnel with knowledge of the site history
• Environmental variables and characteristics be available), the presence of near-surface
that will be measured (for example, what are groundwater or surface water and discharges
the chemicals of concern); (for example, does the presence of potentially
impacted surface water depend on the season).

The potential use of the site should be in the preceding steps, and that the data
considered as it will influence the sampling are subject to various types of errors.
density required and the areas of a site that will Consequently, it is possible that an incorrect
be used for specific uses should be defined. conclusion, or a decision error, may be arrived
at and it is necessary to define performance or
Step 5 – Develop a decision rule acceptance criteria that the data will need to
This step defines the parameters of interest, achieve to minimise the possibility of making
specifies action levels and combines the erroneous conclusions.
outputs from the previous DQO steps into a Decision errors arise due to decisions about
single statement that provides a logical rule for the contamination status of a site being made
choosing from alternative actions. based on data that is not representative of
Consideration should be given to the the conditions on site because of sampling or
specification of action levels that will be used analytical error. The use of incorrect data may
to choose between alternative actions. Action result in the decision being made that the site is
levels may be pre-determined (for example, suitable to be used for the proposed use without
guidelines set by the regulator) or site specific clean-up when it isn’t or vice versa.
(for example, risk-based criteria calculated ‘Total Study Error’ arises from a combination
for the site). In general, pre-determined action of sampling errors and measurement errors.
levels will be more conservative (i.e. lower) that Sampling errors occur when the sampling
risk-based action levels. program does not result in the collection of
Consideration also should be given to the representative samples from all strata such that
definition of acceptable limits for chemicals of the variability of a contaminant from sampling
concern in blank quality samples (field blanks, point to sampling point is not adequately
rinsate blanks, laboratory method blanks); defined. Measurement errors occur during
recoveries from spike samples (matrix spikes, sample collection, handling, preparation,
surrogate spikes) and laboratory control analysis and data reduction.
samples; and relative percent differences of The total study error directly affects the
matrix spike and matrix spike duplicates. probability of making a decision error and is
This step should result in definition of the managed by the correct choice of sampling
statistical parameter (i.e. mean, median or program and measurement system. The use of
percentile) that characterises the population; a statistically-based sampling program allows
confirmation that the action levels are greater the nomination of the probability of a decision
than the detection limits of the method used; error occurring.
and development of an ‘If … then …else’ The possibility of making a decision error is
statement that allows the decision-maker to controlled by the use of hypothesis testing. In
choose alternative actions. hypothesis testing a baseline condition is set
An example of an ‘If…then…else’ statement is (for example, the site is contaminated such that
as follows: it requires remediation for the proposed use).
The test is then used to show that the baseline
If the mean concentration of chemical X in condition is true or false. The burden of proof is
the top 250 mm of soil in a particular grid of placed on rejecting the baseline condition i.e. it
the sampling pattern (a decision unit) exceeds is assumed that the baseline condition is true
the action level, then remove a 500 mm layer unless there is overwhelming evidence to the
of soil, else leave the soil intact. contrary. The stated baseline condition is known
as the null hypothesis and there are two types of
Step 6 – Specify limits on decision errors
decision errors that can occur as follows:
In this step it is acknowledged that the
• A Type I error occurs when the hypothesis is
investigation team does not have access to
rejected when it should be accepted (in the
perfect information, as has been assumed

example given above, it is decided that the of confidence (95%) that a Type I error has not
site is suitable for the proposed use without occurred in comparison to a Type II error (80%).
remediation when actually it is not); and This allocation of probabilities acknowledges
that, when considering contaminated sites,
• A Type II error occurs when the hypothesis
a Type I error has more serious implications
is accepted when it should be rejected (in
that a Type II error. The recommended α (0.05)
the example given above, it is decided that
and β (0.2) risk values are used to arrive at the
the site requires remediation to make it
constant (6.2) in the equation used to determine
suitable for the proposed use when actually
the number of samples required for determining
it does not).
the mean concentration in Step 7.
The implications of making either a Type I
or Type II error are different and depend on Step 7 – Optimise the Design for Obtaining Data
how the null hypothesis has been set. In the In this step the outputs from the other DQO
example provided, the implications of a Type are brought together into a resource-effective
I error to human health and the environment sampling and analysis program that will result
are considered greater than those of a Type II in the data collected satisfying the DQO. The
error, which would result in greater financial outputs of the preceding DQO are applied to the
costs than necessary, but would be protective design of the study that will satisfy the DQO,
of human health and the environment. including the optimal sampling and analytical
plan to meet the objectives of the assessment
As can be seen, setting the null hypothesis
and the DQO. The main output from this step
is an important step when considering the
is development of the Sampling Analysis and
implications of the Type I and II errors. If the
Quality Plan (SAQP) for the study.
phased approach to site assessment is followed
based on the guidelines (NEPC 19992), and An important aspect of optimising the design
following completion of a Stage 1 Preliminary is determining the number of samples needed
Site Investigation (PSI) a Stage 2 Detailed to arrive at the mean concentration for each of
Site Investigation (DSI) is indicated, the null the analytes using the following formula
hypothesis should assume that the site is (AS 4482.1-20053)
contaminated as indicated by the results of the
Stage 1 PSI, otherwise a Stage 2 DSI would not
be required. Consequently, in contaminated site
assessments the null hypothesis should always
assume that the site is ‘contaminated’. Where
n = Number of samples needed
The probability of a Type I error occurring is
known as the α (alpha) risk and the probability of σ = Estimated standard deviation of
a Type II error occurring is known as the β (beta) contaminant concentrations in the
risk, both of which are expressed as decimals. sampling area, mg/kg
The confidence level is the converse to the risk µ = Estimated average concentration in the
and for α and β risks would be expressed as sampling area, mg/kg
1-α and 1-β, respectively. Cs = Acceptable limit, mg/kg
Commonly, the probability of a Type I error The constant 6.2 is based on a 0.05 α risk and a
occurring (i.e. the α risk) is set at 0.05 when 0.2 β risk
assessing for a sensitive land use, with the
probability of a Type II error occurring (i.e. the
β risk) set at 0.2. This implies a higher level
3 AS 4482.1-2005, Australian Standard, Guide to the

2 National Environment Protection (Assessment of investigation and sampling of sites with potentially
Site Contamination) Measure, National Environment contaminated soil, Part 1: Non-volatile and semi-volatile
Protection Council, 1999 (NEPC 1999) compounds, 2nd Edition 2005 (AS 4482.1-2005)

Appendix 3:Personal per manufacturer’s instructions and disposed of
as hazardous waste after use. Those using the
Protective Equipment (PPE) APR’s must be trained in their use in accordance
with manufacturers’ recommendations. The
Guidelines on the Personal Protective wearing of separate eye protection and half
Equipment to be worn during face APR’s or dust masks is not recommended
attendance at a suspected clandestine as these do not provide a comparable level of
laboratory site protection nor the comfort of a full face APR.
Hand protection: ‘Nitrile’ disposable gloves
Background:
offer adequate hand protection against chemical
Clandestine laboratories involve the improper contamination under most circumstances
storage and use of toxic and corrosive arising during sample collection. Additional
chemicals. Although no odours or visible protection may be achieved through the
staining may be evident, residual chemicals may donning of a second set in instances where
be present. Any person attending a suspected puncture or tearing is possible. When sharp,
clandestine laboratory site which has not been rough or significantly contaminated surfaces
fully decontaminated should utilise appropriate are present, consideration should be given to
personal protective equipment (PPE). the use of heavy duty Neoprene gloves. Gloves
should be changed regularly hence access to
Personal Protective Equipment appropriately sized gloves in quantity will be
The following is provided to guide those required. Gloves are not to be re-used and are to
attending sites after the police and forensic be disposed of as hazardous waste. The use of
chemistry team are no longer in attendance. latex or vinyl gloves is not acceptable as they do
While the following recommendations describe not provide adequate protection against a range
PPE appropriate for the majority of cases, of chemical substances.
specific instances of heavy contamination may
Foot Protection: Two alternatives types of
require the use of more sophisticated PPE for
suitable foot protection are available:
example breathing apparatus. In this event,
only persons who have undergone appropriate • Boots – these may be either lace up or of a
training in the use of the equipment are to rubber or ‘gum’ boot design, and constructed
utilise same. Safety is the responsibility of of materials which are resistant to chemical
those attending the site hence consultation with attack. These offer protection against a
emergency services personnel and/or safety range of chemical substances and may be
equipment specialists is recommended in the decontaminated after each use.
selection of PPE.
• Disposable latex or plastic overshoes.
Before entering the site, the police officers These should fit properly and be disposed
who processed the site for safety and evidence of as hazardous waste after single use.
purposes should be contacted and any potential (While paper overshoes are available,
hazards discussed. Regardless of the level of their use is not recommended. They are
site contamination as determined by attending generally only suited for protecting against
police officers, as a recommended minimum, dusts and particulates and offer little
those attending a site should wear: protection from liquids).
Respiratory/eyepProtection: A full face mask Skin and clothing protection: Disposable
air purifying respirator (APR), equipped with cover all suits with an integrated hood are
broad spectrum cartridges that filter dusts, suited for the purpose and are available in a
organic vapour, acid vapour, solvents and variety of materials which offer differing levels
ammonia / methylamine. APR’s are to be of protection against exposure to chemical
decontaminated after use. Cartridges are to be contaminants. The range from composite
replaced dependent on contaminant burden as fabrics for example Tyvek® offering protection

principally against dust and particulates only
as many liquids will penetrate the fabric after
relatively short exposure periods. A higher
level of protection is offered by coverall suits
or ‘splash suits’ manufactured from a variety
of laminated chemical resistant materials for
example Tychem®. While these offer enhanced
penetration resistance to a range of chemicals,
they are not ‘chemical proof’. These suits cannot
be effectively decontaminated and are intended
to be for single use only, after which they are to
be disposed of as hazardous waste.
The choice of suit composition, and PPE
in general, should be made on a case by
case basis and be based on site specific
information including the degree and nature
of contamination, and with reference to the
maker’s specifications for the PPE garment.
Air monitoring instrumentation: When first
entering an indoor site, the site is to be checked
with a properly calibrated and functioning air
monitoring device. The air monitor must, as a
minimum, detect oxygen and lower explosion
limit levels. Before beginning sampling or
inspection, the air throughout the premises
must be assessed. Special attention is to be
paid to floor areas as many solvent vapours are
heavier than air and may accumulate in low
lying sections. If an air monitor alarms at any
time, those present must immediately evacuate
the premises and seek assistance from fire and
emergency service before re-entering.

Appendix 4: Analytical • ChemCentre
Resources and Chemistry Precinct
Laboratory Services South Wing, Building 500
Analytical Laboratories South Entrance Drive (off Manning Road)
Determining the identity and concentration Curtin University
of any chemical contaminants is an integral Bentley WA 6102
part of the remediation for sites. Authorities Phone: +61 (0)8 9422 9800
engaging in remediation processes will require Fax: +61 (0)8 9422 9801
the services of laboratories which can provide
quantitative analysis on, at a minimum, the • National Measurement Institute
substances contained in Appendix 1.
1 Suakin Street
It should be noted that Appendix 1 contains Pymble NSW 2073
some substances which are controlled under Phone: +61 (0)2 9449 0111
federal and state drug legislation. Laboratories
Fax: +61 (0)2 9449 1653
offering analytical services for these substances
will need to be in possession of appropriate
• Queensland Health Forensic and
licences and permits to access the necessary
Scientific Services
standards and reference materials
39 Kessels Road
It is recommended that, prior to the Coopers Plains QLD 4108
commencement of any sampling from a site,
Phone: +61 (0)7 3274 9111
discussions be held with the laboratory which
will carry out the analysis of the samples. This Fax: +61 (0)7 3274 9119
is to ensure any solvents, sampling media,
sample containers or any other materials used
in the collection process are compatible with
laboratory requirements and will not interfere
with the analysis.
The following are some of the laboratories
which may be able to provide the analytical
services required in the remediation of former
sites. The list is provided as information only and
should not be interpreted as a recommendation
or an endorsement of the services offered by
these institutions.

Clandestine Drug Laboratory
REMEDIATION GUIDELINES
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Clandestine Drug Laboratory Remediation Guidelines iii

iv Clandestine Drug Laboratory Remediation Guidelines

Clandestine Drug Laboratory Remediation Guidelines v

2. THE CLANDESTINE LABORATORY SITE REMEDIATION PROCESS 3

2.1 The Four Phases of Site Remediation 3

3. GUIDELINES FOR PHASE ONE – TRIGGER FOR ASSESSMENT 5

3.1 Interpreting police/forensic information 5

4. GUIDELINES FOR PHASE TWO – PRELIMINARY ASSESSMENT and ACTION 7

4.1 Determining if a site inspection is required 7

vi Clandestine Drug Laboratory Remediation Guidelines

5.1 Preliminary Assessment Checklist 10

Clandestine Drug Laboratory Remediation Guidelines vii

6.1 Site validation 25

7. References and Resource Documents 27

Appendix 1: Summary of Investigation Levels (IL’s) 28

viii Clandestine Drug Laboratory Remediation Guidelines

1.1 Scope premises, remote rural properties, hotel and

Clandestine Drug Laboratory Remediation Guidelines 1

2 Clandestine Drug Laboratory Remediation Guidelines

Clandestine Drug Laboratory Remediation Guidelines 3

Figure 2.1: General Process for Site Investigation and Reporting

Trigger for Assessment

Responsible authority orders preliminary No Risk

Investigation and assessment checklist

Appropriate authority issues pollution control/prohibition or other environmental

Completion of site assessment checklist and investigation, including laboratory

Contamination Identified No Contamination Identified

Assessment confirms contamination,

On completion of remediation activity,

4 Clandestine Drug Laboratory Remediation Guidelines

3.1 Interpreting police/forensic then police may contact the appropriate

3.1.2 Urgent / telephone notification • site sketch indicating suspected areas of

Clandestine Drug Laboratory Remediation Guidelines 5

6 Clandestine Drug Laboratory Remediation Guidelines

Clandestine Drug Laboratory Remediation Guidelines 7

8 Clandestine Drug Laboratory Remediation Guidelines

Airborne contaminants commonly associated • site accessibility;

Clandestine Drug Laboratory Remediation Guidelines 9

5.1 Preliminary Assessment Checklist 4. Is there any evidence of soil contamination

10 Clandestine Drug Laboratory Remediation Guidelines

• Detailed site investigation; Difficulties may arise in the assessment

Clandestine Drug Laboratory Remediation Guidelines 11

12 Clandestine Drug Laboratory Remediation Guidelines

Clandestine Drug Laboratory Remediation Guidelines 13

14 Clandestine Drug Laboratory Remediation Guidelines

Clandestine Drug Laboratory Remediation Guidelines 15

16 Clandestine Drug Laboratory Remediation Guidelines

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Accessibility of residues, and frequency of • Steam cleaning/ high pressure cleaning;

Information on likely future occupancy of a • Cleaning and vacuuming;

Clandestine Drug Laboratory Remediation Guidelines 21

22 Clandestine Drug Laboratory Remediation Guidelines

Clandestine Drug Laboratory Remediation Guidelines 23

3.1 Interpreting police/forensic then police may contact the appropriate