admissible if they fall within one of several exceptions. Quarles, 467 U.S. at 655, 687 n. 10, 104 S.Ct. 2626. In Quarles, the United States Supreme Court articulated one of these exceptions as occurring when the interrogation is prompted by a concern for public safety. Id. at 655-56, 104 S.Ct. 2626. In recognizing the public safety exception, the Court held that “concern for public safety must be paramount to adherence to the literal language of the prophylactic rules enunciated in Miranda.” Id. at 653, 104 S.Ct. 2626. [IT 23] Federal courts have held that the public safety exception applies to law enforcement questioning related to the location of a gassing generator or other methamphetamine manufacturing equipment. See, e.g., United States v. Noonan, 745 F.3d 934, 938 (8th Cir.2014) (<HOLDING>); United States v. King, 182 Fed.Appx. 88, 91
holding inter alia that experienced officers observations that the defendant was under the influence of either methamphetamine or cocaine did not by itself establish probable cause to believe that the defendant had committed a crime holding that during a routine traffic stop it is reasonable for an officer to search the driver for weapons before placing the driver in a patrol car if placing the driver in the patrol car during the investigation prevents officers or the driver from being subjected to a dangerous condition and placing the driver in the patrol car is the least intrusive means to avoid the dangerous condition holding that the public safety exception applied when a deputy had probable cause to believe that a stopped driver was a methamphetamine manufacturer and the officer asked if a one pot was in the car to avoid being sprayed with toxic chemicals holding that a police officer may as a matter of course order the driver of a lawfully stopped car to exit his vehicle holding that for general safety purposes an officer may routinely order the driver of a lawfully stopped vehicle to exit the vehicle because when the vehicle is already stopped the slight additional intrusion associated with being directed to exit the car can only be described as de minimis