California Department of Toxic Substances Control - Research Proposal Example

California Department of Toxic Substances Control INTRODUCTION Tennessee remains one of the top meth producing states in the country, and now lawmakers are introducing a new bill that is designed to make key ingredient pseudoephedrine (PSE) only available via prescription. This professional project will address the effect the passage of this law will have on the amount of clandestine meth labs reported in Tennessee that does not have a PSE prescription-only law versus states like Oregon and Michigan that do. Medicines containing pseudoephedrinecommonly used to treat allergies, sinus congestion are no longer used just for those purposes. For approximately the last thirty years PSE medicines have been used to manufacture methamphetamine. Methamphetamine has emerged as a highly addictive, illegal, substance that is second only to alcohol and marijuana in abuse rates (Nemes, 2011). In Tennessee, the number of new users and clandestine labs seizures has increased exponentially over the last five years. Reviews of the methamphetamine abuse has influenced legislators to enact regulations and statutes to help mitigate the surging rates of abuse; specifically regulating and monitoring the sales of precursor ingredients used to produce methamphetamine. Methamphetamine abuse affects communities in a number of ways. Users and those involved in clandestine production of meth are commonly treated in emergency rooms for illnesses or burns as a result of use or the harmful effects of producing methamphetamine. Children of users are commonly neglected and ultimately removed from their parents at the cost of the state government, private property becomes contaminated or damaged by fire, and law enforcement officials many times become contaminated when encountering users, their children, and clandestine labs. Despite the regulatory legislation enacted to limit the availability of precursor ingredients used to produce methamphetamine, clandestine lab seizure rates and methamphetamine incidents continue to surge in Tennessee. However, with any public policy there will be negative consequences. PSE has been readily available over the counter (OTC) for those who have legitimate needs for some time. This has been a concern for policy makers all along. How do you restrict PSE from those who misuse it and keep it readily available to those who need it for common colds and allergies? One report suggests that a policy decision based solely on a concern about the diversion of PSE medicines to meth production is shortsighted because it only considers one side of the issue (Brill, A. 2013). The researcher will examine the number of clandestine lab seizures in Tennessee in comparison to the states of Mississippi and Oregon who enacted prescription-only statutes for the distribution of pseudoephedrine products, which has almost eradicated methamphetamine production within their borders. The researcher will also examine the impact of PSE prescription-only laws on the average consumer. The researcher will evaluate the unintended consequences of prescription-only PSE such as extra doctor visits, lost work productivity, increased health insurance premiums and the overall financial burden that have been placed on citizens of Oregon and Mississippi that have already enforced such laws. This research is proposed to answer the following questions: 1.) Are prescription-only laws an effective tactic to mitigate methamphetamine production? 2.) Is the cost of prescription-only laws for PSE products worth the unintended burden it will place on the citizens of Tennessee? Through this research the researcher will determine if adding PSE to a legend drug status or to the drug schedules in Tennessee; will reduce the amount of clandestine lab seizures by law enforcement and if passage of a prescription PSE law will be worth the burden placed on the public. REVIEW OF LITERATURE A review of the literature was conducted to identify published studies evaluating the impact of state laws regulating methamphetamine precursors on methamphetamine abuse in Mississippi and Oregon, and the lack of regulation in Tennessee. Published reports utilize a variety of data sources to assess impact including healthcare-related data and data collected and accumulated from law enforcement agencies. In addition to the published literature, information from governmental agency reports, news reports, legislative policy reports and personal interviews will be used as instruments for gathering data evaluating the impact of prescription-only pseudoephedrine control laws. Impact can be assessed in three main ways –For the purposes of the report, the impact of state laws in each state is discussed separately. The researcher will discuss the literature in three categories. The first category will discuss the use of law enforcement data to determine the impact of PSE prescription-only laws in regards to changes in the manufacture of methamphetamine in domestic clandestine labs, amount of methamphetamine seized during lab raids and other law enforcement activities in Oregon and Mississippi which have passed PSE prescription-only laws. For the second category the researcher will address these issues in Tennessee which has not yet passed a PSE prescription-only law but is attempting to. The third category will discuss the data regarding the unintended impact on the consumer such as the cost of higher insurance premiums, the increased cost of PSE to those needing the drug legitimately, and the overall financial burden placed on the average citizen. The most common datasets used for assessing impact are summarized below. Researches from other states Mississippi. To start with, introduction of the law to eliminate meth labs in Mississippi helped in the reduction of meth production in the region. In 2010, Mississippi made pseudoephedrine only available through a prescription. This initiative by the government according to the locals led to lack of material for production of meth at the labs (Lakin 2013). 6 news travelling to Mississippi found out that the law was actually effective. According to Mississippi Bureau of Narcotics, they had only napped one meth lab in the entire state in the past six months. This was at a home about 20km away from the state capital(Lakin 2013). Several people could also attest to the fact that meth production had reduced. Garrard, a former addict who has been clean for 12 years states that back them meth production was available at almost every corner around their area as it was easy to cook it. Back then, any person could walk into any drug store and order for pseudoephedrine; the key ingredient for production of meth. One could buy all other ingredients even at the local supermarket and afterwards prepare it with relative ease. Marshall, the director of the Mississippi Bureau of Narcotics, was influential in the making of the law. He testified that before the law, agents were in every street dismantling the meth labs but later to be erected again. According to statistics from Mississippi Bureau of Narcotics and Tennessee Meth Task force, there were 629 total meth incidents in Mississippi compared to 1437 in Tennessee in 2009. In 2013 Mississippi had 119 and only 8 meth labs: an astonishing decrease of 83%. In the same year, there were 1685 incidents of meth: a 17% increase from the previous year(Lakin 2013). According to 2013 study conducted by the Government Accountability Office, the restrictions on pseudoephedrine has led to a steady decrease to the meth incident. The GAO study indicated that electronic tracking system of pseudoephedrine like Tennessee NPLEX have enforced the sale of limits but not the meth lab incidents(Lakin 2013). The 6 news interviewed Pharmacist Kenny Willoughby who runs Polk Discount Drugs in Florence, Mississippi on the impact of the law. He confessed that there has been decline of the cases as there is no incident of people buying bulk of the product. The product according to him is just enough to get to the hands of those who really need it. This law have its effect to the people as they say it is inconvenient to get to the doctor to get a prescription for the common cold. Some dismiss this as tiring and hence they have decided to use other drugs like phenylephrine which works fine. Besides that, there are people with allergies that have to put up with drugs like Clinton D. Despite the efforts by the government, a critic to this method of fighting meth production is that some people are getting it from other state and smuggle it to the country. Due to the numbers of cartels in the region, Mexicans smuggle the meth across the border and making it available to the people in the area. In the previous year, there was a record amount of meth caught by the authority: 10kg to be precise. This is an estimated $1.3 million that was brought into Mississippi from Mexico(Lakin 2013). On top of all other factors, the economic impact of the law is quite significant. Taking an example of the largest manufacturer of the over the counter products in the region the CHPA we can get a clear picture of the situation. According to their statistics, the loss of production due to colds and allergies is estimated at around $524 million. This means that with the prescription requirement, the cost increase will translate to a loss of about $5.24 per every increase of cost (CDC 2013). Through that research by 6 News, the findings were 1. The law has helped in decrease of meth production in the area. 2. Through that law, the locals have benefited as the number of meth addicts has reduced considerably. 3. The over the counter medicine manufacturers have experienced loses due to the introduction of prescription requirement. The problem encountered by this approach is that more meth is coming in from other states like Mexico for sell in the area. It is important to notice that the decline of the meth use and production is consistent in the area. This means that the adoption of the law may bear fruits in Tennessee also. Oregon In November 2001, the state of Oregon implemented a rule requiring identification for over the counter purchase of pseudoephedrine. During this time, the law was to be implemented by all the pharmacies, chemists and even shops selling this product. A rule effective as of May 2005 specified further that these pseudoephedrine products must be placed behind a pharmacy counter and its purchase logged (CDC 2013). In that year alone, the lab incidences shot down from the previous years 632 to a new low of just 232. In the 2006, the state of Oregon implemented the rule further to prescription only requirement. This implementation led to a decline of the lab incidences from the 232 in 2005 to just 67 in 2006. This level has remained lower than that ever since 2006. Being the only state with a multi-year requirement, the emphasis placed on the fight against meth is really high (CDC 2013). There are two studies that were conducted in this state to find out the impact of the law to the people. Going by their statistics, they concluded that factors other than prescription-only policy for drug acquisitions, have led to the decrease. EPIC data (used in both studies) indicated there was a steady decline of meth lab incidents not only in Oregon but also the neighboring states of California and the western states. Through the studies, the decline in Oregon did not very much differ from the rest of the other states. Contrary to Oregon, these other states have not adopted the prescription only policy. This was an overwhelming finding given the hype directed at the policy by its makers. Going by the findings by Cunningham et al. the seizures in Oregon and also other states had been “bottomed out’ (sic) already by all the other states long before the adoption of the policy. This findings floored and limited its impact to the fighting of meth. Both studies suggest that availability of meth is still high as smugglers and drug barons from Mexico are supplying the drug to the addicts. This importation from Mexico means that even though the lab incidents are at an all-time low in this region, its production has been transferred to Mexico. This is contrary to the belief that since the meth lab incidents have reduced then the state is free from the drug. Testimonies from the assistant chief of California Bureau of Narcotic Enforcement drew a conclusion that the western lab numbers are declining due relocation of the labs. In his testimony, he said that the sophisticated smurfing chains from the western states are facilitating the creation of major meth labs to California. This production is carried at the locations of the large drug lords in California, leading to the highest number of production in this state. Through this findings, cracks develop in the impact of the prescription only law of pseudoephedrine in this state. Some of the major talking points include 1. Other states are having a decline of the meth lab incidents by using other policies. This decline is consistent with the one in Oregon. 2. There is availability of the drug in Oregon because they are being smuggled across the border from Mexico. 3. There are facilitators from Oregon that have decided to facilitate creation of super lab in California where the meth production is high. The impact of the law in this state should not be denied but more factors have to be considered when carrying another research so as to discover the real impact of the drug to such states like Oregon. Some common Limitation to these studies. One of the limitation that is evident is that the EPIC lab incident has been underreported. Unfortunately, since the data follows the general seizures trends, it cannot be dismissed as accurate in both Mississippi and Oregon. Just as it is in many researches, it is not out of the box to say that maybe the findings in this states were merely as a result of some other unidentified factor like let’s say counseling of addicts. Another noted limitation is that the studies attempted to control the trends seen in the labs by ignoring the effect of all the other factors. For the studies to take place, there are factors to ignore and maybe some biasness in identifying data. The researcher in this forum is going to carry out an investigation to verify if the findings by these studies are true and consistent. The researcher is going to use a different approach of getting the data by including the number of addicts on rehabilitation in the rehab around Tennessee. Tennessee This state of Tennessee is attempting to pass the prescription-only policy of PSE. Tennessee is a state that is ranked among the top two in production and consumption of meth in the world. This bad reputation has led the governors of the state to consider signing the policy into law so that they can also reduce the lab incidents and the use in their state. The picture of Tennessee painted across the world is one that is filled with drug cartels in every corner and every street. Although this is merely the case, the use of drugs in this state surpasses all the other states. This led to the state to adopt the Federal Funding on Methamphetamine Production Enforcement and Cleanup(USGAO 2013). Ever since FFY 2002, the state of Tennessee has been receiving 37.2 million dollars for the enforcement initiatives and also the lab cleanups. The funding was coming in yearly to help Tennessee for their effort to fork out the meth labs in the area. Unfortunately, due to the fluctuations the funding has reduced and around 2011, the funding was becoming unavailable (USGAO 2013). With revised lower cost waste processing procedures in line, the federal government was made to cover for the expenses of the training and also the equipment. At this point, it has been apparent that the fight against meth would have to take a different turn. In this case, due to the statistical success of other states, the state has decided to adopt the law of prescription-only. Due to the withdrawal of the federal grants, the fight could become even more expensive. Even before its expiry at the end of the year, police officers have already seen 59 labs in the first eight days of this year(USGAO 2013). By 2005, Tennessee had adopted another system of limiting the amount of drug sold to an individual. This method was intended to cap the amount of pseudoephedrine that was legally acceptable to be bought by any individual at any given time by signing a log and producing an identification card. According to a recent release by Comptroller office, the electronic tracking adopted by the state has barely reduced the quantity of meth production in the region. This has just been a confirmation of the several complaints from people that the method is a waste of resources. Critics of the system have expressed their concerned of how easy it is for the meth producers to get the pseudoephedrine, the key ingredient to production of meth. There are two effective methods that are used by the addicts as discussed below:- One of the many methods of going round that system is by fake identification by college students who are sent in numbers to buy the drug from the stores. By combining the many student’s efforts, the producers get enough raw material for the production of meth(Darke 2011). Another method has been the use of the shake and bake method that requires a few ingredients that are placed in just one bottle. This method is easy to follow and production of meth is simple. Going by this findings, the state of Tennessee has decided to borrow a leaf from the states pf Mississippi and Oregon who have found success through the prescription-only policy of purchase of PMS(Darke 2011). Police agencies in Tennessee had called for the policy to be implemented back in 2011 but the legislator and Governor Bill Haslam preferred the electronic tracking that was to be interstate and privately managed system(Bovett 2011). A system known as the Meth Check enables a real-time tracking of pseudoephedrine sales by both the police and the pharmacies. They have since both concluded that there has not been any change concerning the problem and dismiss the effort as a waste of time. Sources from Tennessee Methamphetamine Task Force have indicated that, there has been a total number of 2,082 meth labs reported in 2010 (Darke 2011). Statewide at the year 2012, there were around 1,808. Also the number of children taken to custody due to meth related crimes are 722 with 1,365 inmates serving sentence. This numbers are a true reflection of how badly the state needs new policies to fight the production of meth (Bovett 2011). Research The researcher is going to relate the amount of meth produced in the Tennessee after the law has been passed. To do that, it will require the information from sources such as the federal police-who will give the information on the number of meth lab incidences in the area then. Additional information will come from the Tennessee Comptroller office. To find out the effects of the meth production to the lives of the people, statistics will be requires from former addicts of meth. This information will also give the impact of the law in Tennessee. This research will expound on the one that was carried out by EPIC to find and Cunningham et al on Oregon but this time the research is to be done in Tennessee (Bovett 2011). DEFINITIONS OF VARIABLES The first part of the research is to find out if the introduced policy will be effective in Tennessee. To carry out the research, the researcher has to use various variables-the number of meth lab incidents is to be treated as a dependent variable while the number of years since the law was flagged as the independent variable. Secondly, the number of children detained due to meth related incidents as the dependent variable against the year after the law has been put to action. This will be able to show the number decline or increase of the cases in the prisons. In the same research, the issue the number of victims that are reforming from the meth addition in every city should be indicated as the dependent variable against the number of days after the introduction of the prescription-only law has been put to act. In the next category of research, to find out for if the prescription-only policy for PSE products worth the unintended burden it will place on the citizens of Tennessee? The researcher is going to carry out two separate observations: The first observation will be the trend in sells of the over the counter medicine by from manufacturers of over the counter medicine. The data to be collected will be from leading pharmacies and the previous sells compared to the current sales as the dependent variable. The independent variable will be the years before and after the introduction of the law. The starting dependent variable should be the year 2011. Secondly, the incidences of allergies and colds in the region should be investigated. The number of the people getting complications due to allergies and colds should be mastered from the records of the local hospitals across the state. The independent variable being the year should begin from the point just before the introduction of the law. This will be the year 2011. During the research, there are other factors that should also be noticed. To begin with, the number of those who have reformed from the use of meth and have gone to stated rehabilitation out of will should be indicated as intervening variables. These people will affect the research in a way that it is not the new policy that has led to their revoke of the drug. Other factors to consider would also include the seizures of the products from outside the state and the number of smuggles taken outside the state. This is important so that they can be reduced later as external factors in the report delivery. These factors should be deducted and considered too in the report as they have some impact on the result from the research. All these should be dependent variable against the number of years as the dependent variable. To complete the research, the researcher has to obtain all the data from the Oregon and Mississippi. These data will be consisting of the meth lab incidences, the number of meth seizures and the METHOD OF INVESTIGATION To conduct this experiment, official data depicting meth lab seizures and official data depicting the additional cost to consumers will be collected from three states; two of which requires a prescription to access PSE products, Oregon as of July 2006,and Mississippi as of July 2010 and the other, Tennessee not requiring a prescription to access PSE products (CDC, 2013). For the purposes of data collection, the independent variable will be ratio data from each state regarding numbers of clandestine lab seizures, and the dependent variable will be ratio data involving reported additional cost to the average consumer. The design of the proposed research will be a cross-sectional, quasi-experimental design consisting of a control group, experimental group, and a treatment. Data for the number of clandestine drug seizures for both requiring a prescription Mississippi and Oregon and the other Tennessee, which does not, will be sought from the Drug Enforcement Administration’s El Paso Intelligence Center. Data regarding the reported cost passed on to the unintended targets of the law will be collected through data provided by pharmaceutical companies who manufacture PSE and through surveys to members of the public who use PSE for legitimate needs. The control group will consist of official data of reported meth lab incidents occurring in the State of Tennessee and the experimental group will be data of reported meth lab incidents occurring in the States of Mississippi and Oregon. The treatment examined by this research is to measure the effect of prescription-only laws as they are related to the number of reported meth lab incidents and unintended impact of the prescription-only law of the average consumer. The data for this research will be collected at the same time. Data will be over an eight year period, beginning in January, 2005, the year before Oregon established their prescription-only statute, and ending in December, 2013. The population for this experiment will be purposive; specifically collecting all clandestine lab seizures numbers from the states of Mississippi, Oregon and Tennessee. The researcher will analyze the number of meth lab seizures and it relates to the number of reported violent crimes to determine if there is a strong or weak, positive or negative correlation between the numbers of meth lab seizures to the reported incidents of violent crime. Analysis The importance of analysis in every research ids that it gives the picture of the research findings and makes it possible for the intended recipient to relate. Through this method, the researcher is able to carry pass his findings out to the audience in a simpler way. The analyzed date present the researcher with an opportunity to guide the findings to his/ her conclusions. To analyze the data, the researcher is going to line graphs for the lab seizures in each state under one graph. This should show the trend every year beginning at 2005. The analyzed line graph will also include the independent variable on the y-axis (This variable should be the number of lab seizures) The use of a bar graph to show the trend of lab incidents in the area each year should be calculated and represented. This bar graph will be able to virtualize the trend of the meth lab incidents across the state each year in comparison to the rest. Calculating the percentage increase and decrease in every incident in the state will not be ignored. This information should be presented in a pie chart and the information graded against Mississippi and Oregon States everyyear since 2005. Calculating the average cost per customer should be inform of ratios. This ratio is to be compares with the other states to find out which is having a larger cost of production and what trend is the cost moving towards every single Lastly, the researcher will calculate the average seizures of the meth labs in this state and compare it with the Mississippi and Oregon states. This analysis will be key to establishing whether the method is working better than the tracking method. REFERENCES 1. Bovett, R. (2011). Stop Meth making Meds. The Truth about the Oregon Experience, Oregon Alliance for Drug Endangered Children [PowerPoint slides]. Retrieved March 16, 2014, from:http://www.oregondec.org/ResponseToIndustryPowerPoint.pdf\ 2. Brill, A. (2013), An Analysis of the Economic Impact of Requiring Prescriptions for Pseudoephedrine products, Matrix Global Advisors. Retrieved March 18, 2014 fromhttp://www.matrixglobaladvisors.com/storage/PSE.pdf 3. CDC, (2013).Pseudoephedrine: Legal efforts to make it a prescription-only drug. 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A 24-Hour Study to Investigate Chemical Exposures Associated with Clandestine Methamphetamine Laboratories. www.nationaljewish.org/pdf/Meth-24hour-study.pdf 24. North Carolina Department of Health and Human Services. (2005). Illegal Methamphetamine Laboratory Decontamination and Re-Occupancy Guidelines, pg. 13. 25. Alaska Department of Environmental Conservation. (2004). Guidance and Standards for Cleanup of Illegal Drug- Manufacturing Sites, pg. 29. 26. Colorado Department of Public Health and Environment. (2005). 6 CCR 1014-3, Regulations Pertaining to the Cleanup of Methamphetamine Laboratories, Appendix C. 27. California Department of Toxic Substances Control. (2004). Preliminary Analysis of the Efficacy of Using Cleaning Products to Break Down Methamphetamine. www.dtsc.ca.gov/SiteCleanup/ERP/upload/SMBRB_MEMO_Prelim_ Analysis.pdf 28. Serrano, Martyny, Kofford, Contreras, and Van Dyke. (2012). Decontamination of Clothing and Building Materials Associated with the Clandestine Production of Methamphetamine, Journal of Occupational and Environmental Hygiene, vol. 9:3, pgs. 185-197. 29. Washington State Department of Health, Division of Environmental Health. (2005). Guidelines for Environmental Sampling at Illegal Drug Manufacturing Sites, pg. 12. 30. United States Environmental Protection Agency. (2000). Data Quality Objectives Process for Hazardous Waste Site Investigations. www.epa.gov/quality/qs-docs/g4hw-final.pdf Read More