Development of Utah's Methamphetamine Decontamination Standard
Utah State Code 19-6-906 (Illegal Drug Operations Site Reporting and Decontamination Act) directs the Utah Department of Health (UDOH) to promulgate rules for property decontamination, and establishes the process for making rules. The UDOH's executive director of UDOH delegated the responsibility for rule writing to the Environmental Epidemiology Program (EEP) within the department.
To comply with this legislative directive, the UDOH promulgated Utah Administrative Rule R392-600 Illegal Drug Operations Decontamination Standards.
Rule Making Activities
As a result of the 2015 5-year rule review, the EEP elected to address some questions and inconsistencies that had been recognized after when the rule was first promulgated in 2008. As a result the EEP consulted with the Utah Department of Environmental Quality (UDEQ) and the Utah local health departments (LHD) as directed by state law to address those issues of the rule. In addition, the EEP organized a scoping committee of stakeholders to assist the EEP in understanding certain aspects involved in the process of decontamination. The scoping committee consisted of representatives of state, local, and industrial stakeholder representatives.
Several updated versions will promulgated to clarify the definition and interpretation of composite sampling along with other minor issues. The most recent version of the rule became effective August 24, 2018
The next 5-year review for this rule is scheduled to occur in the Summer of 2020. Anyone wishing to comment should do so in writing (mail or email) to the Environmental Epidemiology Program, Utah Department of Health, PO Box 142104, Salt Lake City, Utah 84114-2104 or firstname.lastname@example.org.
The following principles were applied while working through the process of determining Utah's decontamination standard:
- The mission of the Utah Department of Health is to protect the public's health. The sole objective of this rule is to protect the public from exposure to methamphetamine at a level that could be harmful.
- The state legislature (through passage) and the Governor of Utah (by signing) directed the department to:
- Consult with Utah's LHDs, and UDEQ. The Conference of Local Environmental Health Administrators (CLEHA) appointed several representatives for the LHDs and UDEQ appointed several staff to serve as consultants to the UDOH to fulfill this requirement.
- Apply best practices and appropriate methods.
- The Utah Governor's Executive Order EO/013/2011: Establishing Effective Oversite over State Agency Rulemaking. This order directs that the public burdens be minimized.
- The Utah Governor's Executive Order 2017-1: Establishing Effective Oversite over State Agency Rulemaking. This order directs rule making writing style, oversight, and analysis.
Approaches to Setting a Decontamination Standard
When national guidance is lacking, states have two approaches to take in establishing a state standard. The first approach is to use 'national wisdom.' In 2008, when the UDOH first addressed the issue of establishing a standard for cleanup, the nation lacked sufficient scientific evidence to help guide states in this process. As a result, the national wisdom adopted a standard of 0.1 µg/100cm² (read as one tenth of one microgram of methamphetamine per 100 square centimeters of surface area). The justification of that standard was based on the laboratory detection limit. When there isn't enough information to determine a safe level, then no level (or below detection) was thought to be the appropriate standard to set. Since the laboratory detection limit at that time equated to 0.1 µg/100cm², that value was considered the lowest value that could be achieved in clean up and became the standard. In Utah, the UDOH adopted that value as the Utah decontamination standard. At that time, the value was considered the 'best practice and appropriate method.'
Since 2008, a number of investigations into the health effects of low levels of chronic environmental methamphetamine exposure and the mechanical process of exposure have been published. As a result, a few states started investigating the second option which is to determine the standard through science-based exposure modeling.
Developing a Model to Determine the Decontamination Standard
When there is sufficient data to inform the process, the second approach based on known reference doses and exposure modeling can be used. This process requires knowledge about the exposure process and the dose levels that result in observable adverse health effects. Typically, there are three routes of exposure to environmental contaminates. Those are through inspiration of airborne contaminates; ingestion of contaminated food, water, or hand-to-mouth activities; and transdermal absorption from contact with contaminated surfaces. The modeling process determines how much methamphetamine is transferred (shown by the red arrows) through various compartments (shown by blue boxes) to reach the target organs where harm is done.
Utah adopted and modified the model developed by Colorado. California has a model that is very similar to Colorado's model. The model uses "transfer efficiency factors" (indicated by the red arrows) to move methamphetamine from a surface to the target organs inside the body. Recent investigations into these factors allowed Utah to apply some improvements on the Colorado model.
The resulting dose generated by the model can be compared to a reference dose (RfD). The reference dose is based on the lowest level of exposure for which detrimental effects are observed.
Developing a reference dose
Both Colorado and California included a determination of a reference dose based on the literature available at the time their models were developed. Since that time, additional research has been conducted. EEP used the newer research to calculate a reference dose. Each scientifically validated (peer-reviewed) research report was evaluated by a number of criteria:
|Nature of Effects||
|Nature of the Study||
|Nature of the Measurements||
The EEP found a paper by Madden et al. that demonstrated permanent behavioral and physiological abnormalities in Rhesus monkeys. That paper found that the lowest observable adverse effect level (LOAEL) was when the body dose was 0.75 mg of methamphetamine per kilogram of body weight (0.75 mg/kg). This LOAEL was used to compute the reference dose (RfD). The computation included adjustments for the differences between a lowest effect level and a no-effect level, humans and monkeys, difference among people, and differences in the environments that people are exposed in. After adjusting for those differences the Utah RfD was calculated to be 0.00025 mg/kg-day.
The dose an infant experiences if the surface is contaminated at 1.0 µg/100cm² (read as one microgram of methamphetamine per 100 square centimeters of surface area) is 0.00024 mg/kg-day. That dose is just below the reference dose and is considered safe. Children and adults have an even lower dose level when exposed to 1.0 µg/100cm². Thus the 1.0 µg/100cm² is the best modeled level for establishing the decontamination standard for infants. It meets the requirements for using best practices and is the least burdensome on the public.
As a result of modeling efforts, in 2010, the UDOH raised the Utah decontamination standard to 1.0 µg/100cm². Nationally, the range of state standards is 0.1 to 1.5 µg/100cm². Thus, Utah also continues to follow the current national wisdom since Utah's standard is within that range. Since that time, additional research has been used to reassess the standard. In 2015, the model was adjusted for improved transfer efficiency factors. The new model resulted in the same decisions for standard setting as the previous model.
Future EffortsWhile the science is getting better, much needs to be learned. The EEP will continue to evaluate the standard and make adjustments as more information becomes available. In addition, the EEP has asked federal partners to develop and provide additional guidance regarding determining reference doses and the exposure modeling process.
Sources of Information
California Environmental Protection Agency. Assessment of Children's Exposure to Surface Methamphetamine Residues in Former Clandestine Methamphetamine Labs, and Identification of a Risk-Based Cleanup Standard for Surface Methamphetamine Contamination. February 2009.
Colorado Department of Public Health and Environment. Support for Selection of a Cleanup Level for Methamphetamine at Clandestine Drug Laboratories. February 2005
Environmental Protection Agency. Reference Dose (RfD): Description and Use in Health Risk Assessments. March 15, 1993.
Environmental Protection Agency. Voluntary Guidelines for Methamphetamine Laboratory Cleanup. Revised March 2013.
Madden LJ, Flynn CT, Zandonatti MA, May M, Parsons LH, Katner SN, Henriksen SJ, Fox HS. Modeling human methamphetamine exposure in nonhuman primates: chronic dosing in the rhesus macaque leads to behavioral and physiological abnormalities. Neuropsychopharmacology. 2005 Feb;30:350-359.
Salocks CB, Hui X, Lamel S, Qiao P, Sanborn JR, Maibach HI. Dermal exposure to methamphetamine hydrochloride contaminated residential surfaces: surface pH values, volatility, and in vitro human skin. Food and Chemical Toxicology. 2012 Dec;50(12):4436-40.
Salocks CB, Hui X, Lamel S, Hafeez F, Qiao P, Sanborn JR, Maibach HI. Dermal exposure to methamphetamine hydrochloride contaminated residential surfaces II. Skin surface contact and dermal transfer relationship. Food and Chemical Toxicology. 2014 Apr;66:1-6.
Van Dyke M, Martyny JW, Serrano KA. Methamphetamine residue dermal transfer efficiencies from household surfaces. Journal of Occupational and Environmental Hygiene. 2014;11(4):249-58.