How to Respond to a BHO Lab Incident

BHO Labs

Butane Hash Oil incidents have risen dramatically over the years. In California, the rise of BHO labs have been exponential with some areas experiencing triple digit increases in lab seizures. The rise of the BHO lab has been so fast, that police, fire and EMS have been left struggling to keep up with training demands to combat this trend. It is a trend that will not go away either. To respond to an incident, there are certain protocols to follow in regards to evidence collection, personal protective equipment and investigation.

So what do you do when you receive information on a BHO lab and need to take action? This article is a guide to help you with just such an incident. Your number one goal is to keep your people safe. To keep them safe, you must invest in time, money and training. Your officers will have to attend a one week basic lab safety school at a minimum. You will also have to invest in equipment that will protect them that is quite expensive.

You have to train and equip people, not only because it is our responsibility, but because it is required per OSHA regulation 29CFR1910.134. With that said, here is a guide to responding to a BHO lab incident. As you read it, you will notice that you will treat a BHO lab exactly as you would any other clandestine laboratory.

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Planning BHO Operations

When planning the tactical operation, the case agent first makes an assessment of the hazards likely to be encountered and determines who needs to be notified before the operation begins (i.e., local police, fire department, emergency rooms and hazardous waste contractor). BHO labs by the very nature present a unique series of hazards and risks to law enforcement personnel. The degree of hazard depends on the specific site, chemicals present, their concentrations, conditions of storage (sealed, open, or leaking containers), and their proximity to each other (which may lead to various chemical reactions). Hazards to be expected include:

  • Exposure to hazardous materials such as explosive and combustible chemicals,
  • Physical injury resulting from close quarters (confined spaces); and
  • Injury or death due to booby-traps.

Abandoned BHO labs and chemical storage areas present hazards similar to those at active laboratories, so similar precautions should be taken to ensure personnel safety.

With this in mind, the following safety procedures should be considered when planning the tactical operation:

  • Notify fire department, hazardous materials response team, and/or bomb squad, depending on the size of the laboratory and the degree of hazard (if known);
  •          Ensure fire extinguishers and first-aid kits are available;
  •         Avoid the use of weapons or diversionary devices such as flash bangs, smoke, or tear gas canisters – these weapons can ignite butane vapor;
  •         Do not turn switches on or off; unplug heating elements, or cooling equipment; open refrigerators or freezers; or move containers that are in the way, as they could be booby-trapped or cause sparks;
  •       Do not use matches or flames of any kind. Use an intrinsically safe flashlight to look in dark areas;
  •       Do not taste, smell, or touch any substance;
  •       Do not smoke, eat, or drink at the site;
  •       Do not touch your mouth, eyes, or other mucous membranes with your hands; and
  •       Decontaminate clothing, equipment and personnel (including prisoners) before leaving the laboratory site.

Once the potential hazards have been considered, the case agent assigns certified personnel to the tactical operation team to conduct the tactical operation. These teams should include a forensic chemist, if practical, and must include a site safety agent who is trained and equipped with requisite safety equipment.

A preliminary site safety meeting should be held prior to the Initial Entry phase with the tactical operation team to address preliminary site safety issues (e.g., What should be done in the event of a release of butane during the Initial Entry Phase?).

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On Scene Assessment

After securing the premises, everyone is evacuated and the Assessment Phase begins. Prior to reentry, the tactical operation team should meet to discuss specific site conditions (e.g., wind direction, emergency evacuation procedures, notification of downwind neighbors, etc.). Specially trained and certified officers/deputies and forensic chemists in the appropriate level of personal protective equipment (PPE), conduct a thorough assessment to determine what, if any, immediate health and safety risks (i.e., potential for fire and explosion, butane vapors, booby- traps, etc.) exist. Only the laboratory assessment team enters the laboratory; the laboratory is off-limits to all other personnel, particularly those that are not clandestine drug laboratory safety certified. For purposes of safety, OSHA requires that a backup team be ready to enter a clandestine laboratory site in the level of PPE as the original team should assistance be needed in an emergency during this phase.

The appropriate level of protection must be determined before laboratory assessment can be made. The team must take appropriate steps to reduce imminent risks (i.e., properly shutting down active “cooking” processes, ventilating the premises, etc.). The site safety officer should make decisions regarding the application of appropriate health and safety protocols. Information related to the levels of protective equipment can be found below.

The team must have, and be trained in the usage of, appropriate monitoring instrumentation such as air-sampling meters, oxygen meters, organic-vapor analyzers, or other air- monitoring instruments that are used to determine the lower explosive limit (LEL) oxygen level and the concentration of organic vapors in the laboratory atmosphere. The LEL for butane is 1.8% to 8.5%. Level B equipment must be worn if it is 10% of 1.8% (if it is .18% concentration in the air). All monitoring devices must be intrinsically safe (i.e., designed to suppress sparks that may ignite explosive atmospheres).

After appropriate air measurements are taken, the next step is to identify the chemicals and equipment present in the laboratory and the potential hazards that may exist. If required, opening doors and windows can accomplish ventilation, provided that a natural draft exists. Before windows and doors are opened for ventilation, determine whether they are booby- trapped.

Evidence Recovery

The following should be completed in a BHO lab investigation. This will assist you with prosecution later on and will help your DA prosecute that case.

  • Drawing of clandestine drug laboratory site
  • Photographs
  • Photograph everything in place
  • General overviews
  • Close-ups
  • Specific items during inventory
  • Evidentiary samples and original containers
  • Visible contamination
  • Photograph site after removal of bulk materials
  •       Inventory
  • Inventory all equipment and paraphernalia present in terms of quantity, size, manufacturer’s serial number, condition, and location
  • Inventory all chemicals present for type, concentration, and quantity
  • Describe the type, size, condition, and labeling of all containers
    • Plastic, glass, metal
    • Five-gallon, 2-ounce, etc.
    • Punctured, rusty, leaking, corroded, damaged, uncapped, bulging
    • Label, markings, etc.
  • Identify the location of leaking or broken containers
  • Describe spilled solids or liquids, specifying odor, color, appearance, location, size of spill, etc.
  • Identify the leaking compressed-gas cylinders
  • Identify unstable container storage
  • Identify other concerns

Exit

Before exiting, the site must be secured and posted. When the removal of hazardous wastes has been completed, the case agent conducts a final inspection of the premises and posts a prominent warning on the premises. The posting consists of a “hazardous materials” warning sign that indicates that a clandestine laboratory was seized at the location. The date of seizure should also be included on the warning signs

Personal Protective Equipment (PPE)

The following PPE is needed when dealing with a BHO Lab

Level B

When to use Level B:

When the highest level of respiratory protection is needed, but the environment is not considered acutely toxic by skin contact or by gas or vapor absorption by the skin.

Recommended Level B equipment:

  • Pressure-demand, full-face piece, Self-contained Breathing Apparatus (SCBA) or pressure- demand supplied-air respirator with escape SCBA;
  • Chemical-resistant clothing (overalls and long-sleeved jacket; hooded, one- or two-piece chemical splash suit; disposable chemical-resistant one-piece suit);
  • Inner and outer chemical-resistant gloves;
  • Chemical-resistant safety boots/shoes;
  • Two-way radio communications; and
  • Hard hat (ballistic helmet works)


Author: Keith Graves
<p>Keith is a retired Police Sergeant and worked in the San Francisco Bay Area for 29 years. Keith was named as California’s Narcotics Officer of the Year and is a prior winner of MADD’s California Hero Award. He has years of experience as a Narcotics Detective and a Narcotics Unit Supervisor and is a Drug Recognition Expert Instructor (IACP #3292). Keith teaches both the DRE course and the Drug Abuse Recognition Course and has taught at the Police Academy. He has developed several drug courses for the California Narcotics Officers Association, California POST and California Colleges and currently consults POST on drug investigation procedures. Keith has held other assignments besides narcotics including Training Sergeant, Patrol Sergeant, COPPS Officer, Traffic Officer, and 20 years as a SWAT Team member and Sniper Team Leader. Keith has taught thousands of officers and businesses around the world about drug use, drug trends, compliance training and drug investigations. He is recognized as an international drug expert and has testified as an expert in court proceedings on drug cases, homicide cases and rape prosecutions. Keith earned a BA in Business Management from Saint Mary’s College of California and a MA in Criminal Justice. Keith is the Founder and President of Graves & Associates, a company dedicated to providing drug training to law enforcement and private industry.</p>

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