In part 1 of this two-part series, published in the July issue of R&R, Julie outlined the background of this drug lab cleanup. In summary, after a meth lab bust at a residence, and the property owner said Grandma’s Secret Recipe and MightyMight chemical products were applied. MightyMight was designed for the “neutralization” of bio hazards such as anthrax and other microbial organisms. However, as much as a month later, residue from those chemicals remained and paint was starting to peel. So, a new company was called in to help with remediation – and teach a valuable lesson on product selection and remediation protocols. Julie writes from the new company’s point of view.
Visual & Chemical Assessment
The majority of state regulations require detergent washing and rinsing of all structural components (industry best standards and practices). This is a successful and proven method for the safe and effective removal of methamphetamine and other chemical residues associated with the manufacturing process. There are up to 67 known chemicals which can be utilized in three predominant methods of manufacture of methamphetamine and other illicit drug compounds. Neither the patent holder, manufacturer, nor any of the distributors have provided scientific data to support the claim that Grandma’s Secret Recipe/MightyMight addresses clandestine drug lab contaminants; most of which are Hazardous Material Class Substances and/or methamphetamine, a Schedule II Substance.
Heat vents were not cleaned prior to the chemical application; dust and debris, including a coiled wire remain within. As stated prior, Grandma’s Secret Recipe/MightyMight was fogged into the duct work. This product has not been approved by the Environmental Protection Agency (EPA) for this type of application. Chemical biocides are regulated by EPA under federal pesticide law. “A product must be registered by EPA for a specific use before it can be legally used for that purpose. The specific use(s) must appear on the pesticide (e.g., biocide) label, along with other important information. It is a violation of federal law to use a pesticide product in any manner inconsistent with the label directions.” No biocides are currently registered by the EPA for use in internally-insulated air duct systems.
The technicians also confirmed during their onsite inspection of this site that there did not appear to have been any preliminary cleaning of the residence prior to the introduction of Grandma’s Secret Recipe/MightyMight. Photographic evidence clearly shows window sills, counter tops, floors and other surfaces were not swept or vacuumed of dust and debris. The product was clearly applied to ALL surfaces - over debris. Also, the photos clearly show the access points of the heat system, i.e. exhaust vents, were not cleaned or vacuumed prior to the illegal introduction of the product into the system.
The site was evaluated using test procedures appropriate for the site of a clandestine methamphetamine manufacturing laboratory. The survey included an evaluation of the floors, walls, ceilings and other various surfaces within the functional spaces of the unit for methamphetamine surface contamination and visible or identifiable areas of chemical staining or contamination. Substrate testing was performed by surface wipe sampling. Samples were collected from distinct 100 square centimeter (100 cm2) sample areas of the floors, walls and ceilings of the residence. The clandestine drug lab technician preserved and handled all samples in accordance with a method equivalent to the principals outlined for volatile organic and semi organic compounds in EPA Method 8270D. The sampling media was then placed in a lab supplied plastic sampling vial, sealed, labeled individually, and stored until shipment to the certified laboratory for analysis.
B. RESULTS AND DISCUSSION
According to the National Jewish Medical and Research Center (NJMRC), Grandma’s Secret Recipe/MightyMight likely oxidizes the methamphetamine present into another compound. The use of known oxidizers has been banned in many regulated states because of the potential for “masking” the marker (meth). The manufacturer/distributors’ claim Grandma’s Secret Recipe/MightyMight has the ability to “completely neutralize” the marker (meth). Neutralization is a general description that in this claim means “complete oxidization” - which equals combustion. This means that “complete neutralization” would imply Grandma’s Secret Recipe/MightyMight has the ability to achieve complete bond disassociation of the meth molecule (C10H15N). The manufacturer/distributors have not provided any laboratory data to support this claim. There is a strong probability that the bond disassociation was limited to only a small percentage of the molecule, rendering it non-detectible by industry standard analysis at the laboratory. Partial oxidization is likely and the probability that contamination remains, is high.
Again, the manufacturer has not provided any scientific data to substantiate its claim of complete neutralization nor have they provided any scientific data to show that any remaining constituents of the molecule are safe or healthy. Therefore, a “non-detect” post sample result after use of the product is not defensible and does not render a site “fit for use” under current standards and practices of the industry. Additionally, methamphetamine is not a biological organism but is in fact a double bonded carbon based molecule with an inherent resilience based on its composition. This is, in part, why it is the chosen marker in regulated states.
The NJMRC also confirms the application and residue hazards of Grandma’s Secret Recipe/MightyMight. “Although the use of these oxidizing compounds, especially the quaternary ammonia compounds, resulted in a significant reduction in the amount of methamphetamine present, there are concerns regarding the use of these compounds. Individuals using these compounds must realize that the compounds can be very toxic when used in a confined space. Pulmonary problems have been reported when these products are used in a confined space. In addition, it is not known what by-products, if any, are left behind after the use of these compounds. Chlorine can combine with organic materials to form compounds that can result in further contamination of the residence. Until the by-products for this type of treatment can be determined, widespread use of these materials should be limited.”12
And conclusively, laboratory analysis of the samples taken after the “neutralization” event demonstrated that almost all of the surfaces sampled in the identified functional spaces remain above the most recognized meth residue remediation standard of 0.10 ug/100 cm². Based on the information available and presented in this report, the site remains subject to the clandestine drug lab decontamination requirements contained in regulated states.