Table 3 Summary of key areas of management of illegal drug laboratories and the roles and responsibilities of EHOs in Western Australia, Victoria and Queensland
From: Management of clandestine drug laboratories: need for evidence-based environmental health policies
Key areas of clandestine laboratory management | Roles, Responsibilities & Issues Relevant to Environmental Health Officers in Western Australia (WA Health, 2012) | Roles, Responsibilities & Issues Relevant to Environmental Health Officers in Victoria (Victoria Department of Health, 2012) | Roles, Responsibilities & Issues Relevant to Environmental Health Officers in Queensland (Queensland Health, 2012) |
|---|---|---|---|
Document relevance | Developed for relevant authority (local governments and DEC) and specifies roles of EHOs from relevant authority | Developed mainly for local government EHOs | Owners of properties where illegal drug activities or laboratory took place |
Clandestine lab hazards | • Outlines two distinct possible risks: dwelling contamination and environmental contamination | • Recognises potential risks to health and the environment | • Mentions potential health and environmental hazards |
Links to national guidelines | • Investigation levels (IL) developed by the national guidelines are used as basis for risk-based analysis and remediation | • Investigation levels (IL) developed by the national guidelines are used as basis for risk-based analysis | • The national guidelines are included as a useful link to consider, but does not provide explanation on their use and relevance |
EHO safety and use of PPE | • EHO safety and use of PPE are discussed. Guidelines on PPE use are based on national guidelines | • EHO safety briefly outlined with respect to responding to nuisance caused by clandestine labs • No instructions on PPE or other safety measures provided | • Only indicates that owners must contact Queensland Health regarding potential health risks but does not provide detailed guidance for EHOs |
Link to legislation | • Health Act 1911: sections (general powers, issuing notices, dwelling suitability, and remediation) relevant to EHO roles and legal proceedings are discussed | • Public Health and Wellbeing Act 2008 (PHWA): nuisance and powers sections | • Public Health Act 2005 is to be used by local government in relation to health risks from former clandestine labs |
• Municipal Association of Victoria’s PHWA Guidance Manual for Local Government Authorised Officers: nuisance, investigation and enforcement mechanism and procedures sections | • No explanation on which sections to be used, who is authorized to enforce them and when they are enforced | ||
• Environmental Protection Act 1986 and Contaminated Sites Act 2003: sections relevant to LG EHOs and DEC officers are discussed | |||
Notification and initial follow-up | • Police to WA Health to LGs and DEC | • Police to LG EHOs | • QLD Police to notify property owners |
• Role of EHOs, property | |||
• Role of EHOs clearly outlined and discussed, including their roles in access to sites, reporting and inspections | |||
• Access and safety considerations not clearly outlined | |||
• Role of LG EHOs discussed | |||
Roles in remediation | • EHOs are directly involved in the assessment and management of sites | • EHOs are not to be involved in assessment, testing or remediation, which is deemed the responsibility of owners | • Owners are responsible for assessment, investigation and remediation of sites |
• Owners to engage the services of an experienced cleaning company or a professional to manage the process; may follow the US EPA Voluntary Guidelines for Methamphetamine Laboratory Clean Up to clean properties themselves. The role of EHOs in verifying effectiveness of remediation is not discussed | |||
• LG EHOs to issue notices, determine management steps, contacting, directing and liaising with owners | |||
• EHO to assist owners in engaging qualified assessors for further assessment, investigation and remediation; issue improvement and prohibition notices if required; agree on remediation plans; and oversee the remediation process | |||
• Owners to engage forensic and cleaning contractors at the request of LG EHOs | |||
• EHO roles in industrial and occupational sites and where owners are not located are unclear | |||
• EHO roles where owners are not located are unclear | |||
• EHO roles in industrial and occupational sites are not discussed | |||
Environmental contamination | • WA DEC officers to respond to external environmental contamination. DEC to liaise with LG EHOs and decide on proper follow-up and statutory actions | • Assessed by contracted assessors | • No explanation on: agencies to report to and to be involved, EHO roles, owner’s responsibilities, who to contact if contamination is found and legalisation enforcement |
• Environment Protection Agency (EPA) Victoria to advise on transportation, disposal and landfill facilities | |||
• Relevant legislation and role of EPA Victoria in the process are not discussed | |||
• DEC pollution and contaminated sites branches to manage protection of the environment and contamination issues | |||
• Owners to engage environmental contractors in accordance with DEC instructions and directions | |||
Post-remediation assessment | • LG EHOs and DEC officers to verify compliance with legislation and notices using the forensic and environmental contractors’ written report | • LG EHOs to verify compliance with notices using assessor’s written reports | • Test kits to be used by owners to verify effectiveness of cleaning and remediation, with the assistance of the Queensland Health Forensic and Scientific Services |
Training on management and the use of documents discussed | • Information sessions on the interim guidelines and their use are being provided to LG EHOs. A training package for EHOs will be released in 2013 | • Not discussed | • Not discussed |