In Utah, there are two kinds of tests for methamphetamine contamination, as defined by the EPA.[i]
In discrete sampling, also known as “individual” sampling, single samples are taken at spatially discrete locations. This sampling technique should be used in areas that are “hot spots” highly suggestive of contamination. R392-600-5 says areas highly suggestive of contamination must be tested by this method.
In composite sampling, multiple discrete samples are combined and treated as a single sample for analytical purposes. The State and County Health departments allow this sampling technique because they say it is less costly for consumers.
However, the State Health Departments is exceeding its authority by allowing testers to use the “compiling” instead of “averaging” method. This results in more properties failing and more work for decontamination specialists.
Here is a description of each of type of testing:
Contamination Limit - Less than or equal to 1.0 microgram (µg) Methamphetamine per 100 square centimeters.
Despite bringing to their attention multiple properties that failed under compiled composite testing that would not have failed if averaging (the scientific standard) was used, the County and State health Departments still refuse to back down. We have made several attempts to get them to operate within their authority and have failed.
Whether allowing compiled composite sampling is crony capitalism to generate more business for decontamination specialists or just sloppy science, it exceeds the Health Department’s authority and the real estate and property management industry ask the Administrative Rules Oversight Committee to intervene.
Utah R392-600 requires:
- Samples collected from areas highly suggestive of contamination shall be by grab samples that are not combined with other samples.[ii]
- "Grab Sample" means one sample collected from a single, defined area or media at a given time and location.[iii]
- Confirmation sampling from areas not highly suggestive of contamination… shall be collected in a manner consistent with the confirmation sampling [procedure laid out in the rule]. The samples may be combined together to form one sample per room or sampling area.[iv] [NO COMPILING OF SAMPLES IS ALLOWED BY STATUE]
[i] EAP Voluntary Guides for Methamphetamine Laboratory Cleanup, 2013; p 25