HUD PIH Notice § 2011-22

[pic]                        U.S. Department of Housing and Urban
Development
                                  Office of Public and Indian Housing

Special Attention of:                                     NOTICE:  PIH-2011-
22
Regional Directors; State and Area
Coordinators; Public Housing Hub
   Issued:  April 26, 2011
Directors; Program Center Coordinators;
Troubled Agency Recovery Center Directors;
Special Applications Center Director;
________________________
Administrators; Offices of Native American                      Cross
Reference:
Programs; Public Housing Agencies; Public                            24 CFR
903.7(e) (2)
Housing; Housing Choice Voucher/Section 8;                              24
CFR 990.165
Tribally Designated Housing Entities;
   7 U.S.C. 136r-1 Integrated Pest

Indian Tribes; Resident Management                        Management
Corporations
                  This Notice Supersedes



                           PIH Notice 2009-15, PIH Notice

                           2008-24, PIH Notice 2007-12

Subject:  Promotion of Integrated Pest Management (IPM) as an
environmentally-sound, economical and effective means to address a major
resident concern.

 1. Purpose.  The purpose of this Notice is to promote and encourage the
    use of IPM by Public Housing Authorities (PHAs), Indian tribes, Tribal
    Designated Housing Entities (TDHEs), and owner/agents providing
    assistance through the HCV program.  This notice provides guidance to
    Public Housing Authorities (PHAs) on the benefits of IPM, additional
    technical assistance and training opportunities for PHAs.   Pest
    management is integral to the provision of safe and sanitary housing.
    In accordance with 24 CFR 903.7 (e) (2), PHAs must include in their PHA
    plans a description of any measures necessary for the prevention or
    eradication of pest infestations.  IPM is an ecological approach using
    an array of methods to prevent and control pests with reduced reliance
    on pesticides. Procedures contained within this notice remain in effect
    until superseded by subsequent HUD Directive or guidance.

 2. Applicability.  This notice applies to PHAs administering the public
    housing and project based Section 8 program, and may be of interest to
    Indian tribes/TDHEs as well as owners/agents providing assisted housing
    through the Housing Choice Voucher (HCV) Program.  The decision to use
    IPM techniques in their ongoing pest control effort is under PHA,
    Indian tribes/TDHE discretion.  24 CFR 990.165(a) covers cost
    associated with Project Expense Level (PEL) such as maintenance
    expenses. IPM is a maintenance expense.

 3. Background.  The goal of IPM as defined by the Environmental Protection
    Agency (EPA) is to control pests by the most economical long term
    means, and with the least possible hazard to people, property, and the
    environment.  To undertake IPM, project managers should be committed to
    ongoing or continuous monitoring and record keeping, educational
    outreach to residents and staff as well as implementing good
    communication strategies between residents and building managers.  IPM
    methods include:  restricted pest access to food/water; vigilant
    sanitation and waste management; mechanical control; physical barriers;
    structural maintenance; and, where necessary, the judicious use of
    pesticides.


 4. Fundamentals of IPM.  IPM efforts must involve PHA staff, contractors,
    residents, and include:

       a. Communicating the PHA’s IPM policies and procedures to be provided
          in the appropriate format to meet the needs of all residents
          including persons with limited English proficiency and in formats
          that may be needed for persons who are visually or hearing
          impaired.  This applies to administrative staff, maintenance
          personnel, and contractors as well.
       b. Identifying the environmental conditions that lead to pests and
          educating residents.
       c. Identifying pests and immediately reporting the presence of pests.


       d. Establishing an ongoing monitoring and record keeping system for
          regular sampling and assessment of pests, surveillance techniques,
          and remedial actions taken, include establishing the assessment
          criteria for program effectiveness.  This is a highly effective
          preventative measure that can help reduce the possibility of a
          pest infestation outbreak.
       e. Determining, with the involvement of residents, the pest
          population levels – by species – that will be tolerated, and
          setting thresholds at which pest populations warrant action.
       f. Improving waste management and pest management methods.
       g. Selecting the appropriate pesticides and insecticides to use.
          Some residents may suffer from Multiple Chemical Sensitivity or
          other Environmental Illnesses.
       h. Ongoing efforts to monitor and maintain structures and grounds
          (e.g., sealing cracks, eliminating moisture
          intrusion/accumulation) and adding physical barriers to pest entry
          and movement.
       i. Developing an outreach/educational program to ensure that leases
          reflect residents’ responsibilities for:  (1) proper housekeeping,
          which includes sanitation upkeep and the reduction of clutter,
          trash removal and storage, (2) immediately reporting the presence
          of pests, leaks, and mold, (3) cooperating with PHA specific IPM
          requirements such as obtaining permission of PHA management before
          purchasing or applying any pesticides, and (4) avoiding
          introduction of bed bugs and other pests into buildings on used
          mattresses and other recycled furniture. See “Preventing and
          Getting Rid of Bed Bugs Safely,” New York City Department of
          Health and Mental Hygiene
          http://www.nyc.gov/html/doh/downloads/pdf/vector/bed-bug-guide.pdf
       j. Check with local health department to determine if your state has
          laws for re-used furnishings.
       k. The judicious use of pesticides when necessary, with preference
          for products that, while producing the desired level of
          effectiveness, pose the least harm to human health and the
          environment.  Residents should notify PHA management before
          pesticides are applied.
       l. Providing and posting “Pesticide Use Notification” signs or other
          warnings.

 5. Health Concerns.  Pests may adversely impact the health of residents
    and contribute to worsening some diseases, such as allergies and
    asthma.  Cockroaches can cause asthma in children and can transfer
    disease-causing organisms to food and surfaces they contaminate.
    Rodents, such as mice and rats, carry disease, can trigger asthma
    attacks and even cause fires by gnawing through electrical wires.
    Although bed bugs are not known to transmit infectious diseases, their
    bites can lead to secondary infections.  Bed bugs can cause emotional
    distress and sleep deprivation for residents as well.  Bed bug
    infestations can spread quickly and must be treated aggressively. All
    pest control methods are targeted to protecting the health of residents
    and staff.  Although applying pesticides may be effective in
    eliminating pest populations, many of these chemicals are associated
    with health and/or environmental risks, and their use should be
    minimized if alternative methods exist.  This is especially important
    in buildings housing vulnerable age groups such as children or the
    elderly and in buildings housing residents with compromised immune
    systems or who may suffer from Multiple Chemical Sensitivity and other
    environmental illnesses. Therefore, IPM offers the potential to ensure
    efficacy of pest elimination while protecting the health of residents,
    staff and the environment.


 6. Building.  Most of the effective methods of pest elimination, including
    ongoing repairs, erection of barriers, and monitoring, will extend the
    useful life of a building and as a result generate significant savings
    that could offset the costs of the pest control.  Many of these non-
    application methods, including structural maintenance, and inspecting
    for and repairing leaking pipes and cracks in roofs, walls, and windows
    are effective in preventing moisture intrusion and accumulation.
    Additionally, IPM-conscious PHAs assess the need to install physical
    barriers to both pest entry and pest movement within every structure
    thereby reducing the spread of pest infestations.

 7. Implementation. HUD promotes IPM as a pest control method.  IPM
    effectively eliminates pests in safer and long term cost-effective ways
    than traditional pesticide treatments.  IPM frequently has proven to be
    more effective in reducing pest populations than relying solely on
    broadcast pesticides.  The Boston Housing Authority (BHA) experienced
    approximately one-third reduction in pest related work orders over
    multiple years in multiple sites.  BHA has maintained this reduction
    and now uses IPM in all its BHA maintained properties.  Continuation of
    the IPM program after initial development cost is considered
    preventative  maintenance expense and is an eligible program activity
    under the Public Housing Operating Subsidy as codified at  24 CFR
    990.165.  Successful IPM requires resident participation through proper
    housekeeping, reporting of pest infestations, and trash removal.
    Residents can monitor pest populations and assist in identifying how to
    eliminate access to food and water for pests.  Resident organizations
    must be prepared to assist residents who need help to follow the IPM
    policy.  HUD encourages PHAs to partner with local pest management
    organizations.


 8. Procurement of IPM Services.  If a PHA uses an outside contractor for
    pest control, the PHA’s pest control/IPM policies and procedures should
    be incorporated into the specifications or statement of work for the
    pest management contract.  PHAs using an outside contractor are
    encouraged to use companies that are trained and certified to provide
    IPM services either through Green Shield certified
    (http://www.greenshieldcertified.org/) or Green Pro
    (http://www.npmagreenpro.org/). The PHA should also consider training
    for maintenance staff, residents, Resident Councils as well as PHA
    administrative staff who oversee housing developments or administer
    occupancy and rental duties such as unit housekeeping inspections.

 9. PHA Maintenance Staff.   If a PHA uses its own maintenance staff for
    pest management, proper training in the PHA’s IPM procedures is
    essential.  It is especially critical to be trained in the proper
    treatments methods PHAs can use when treating for bed bugs.  The
    contract administrator for any pest management contract should be
    trained as well.  Successful results rely upon proper implementation;
    training is therefore of critical importance.  IPM training is
    available at: http://www.stoppests.org/ and
    http://www.healthyhomestraining.org/ipm/training.htm.

10.  Area of High Concern, Bed bugs.  As the number of bed bug infestations
    rise throughout the country, HUD is in the process of developing
    protocols to address this growing problem.  HUD is addressing the unit
    inspection process as well as developing the tools necessary for PHAs
    to identify, treat and monitor the effectiveness of bed bug treatments
    in its portfolio.  Identifying, reporting, treating and monitoring pest
    infestations are all critical components of IPM and are effective in
    addressing the bed bug problem.

11.  Reference Materials for Implementing IPM.  The below list of IPM
    practices does not constitute a HUD endorsement of any specific
    practice, but provides IPM ideas and practices that have been used to
    improve pest management while reducing unnecessary dependence on
    pesticides.  HUD encourages PHAs, Indian tribes/TDHEs to share their
    policies, procedures, resident leases, and written case studies so that
    these may be published on the HUD website for others to read.

    a. National Center for Healthy Housing:
       http://www.healthyhomestraining.org/ipm
    b. Bed Bugs:  “What’s Working for Bed Bug Control in Multi-family
       Housing”
       http://www.healthyhomestraining.org/ipm/NCHH_Bed_Bug_Control_2-12-
       10.pdf      http://pestworld.org/pest-world-blog/the-bed-bug-hub-one-
       stop-shop-for-bed-bug-information
    c. National Pesticide Information Center:  http://www.npic.orst.edu/
    d. Integrated Pest Management (IPM), A Guide for Managers and Owners of
       Affordable Housing, Boston Public Health Commission:
       http://http://asthmaregionalcouncil.org/uploads/IPM/asthma_ipm_guide.
       pdf.
    e. U.S. Environmental Protection Agency:

1 General IPM information http://www.epa.gov/opp00001/contolling/index.htm
        housing): http://www.epa.gov/pesticides/ipm


2 EPA staff contacts:  http://www.epa.gov/pesticides/about/contacts.htm#ipm




       3 List of EPA IPM publications and instructions for ordering
       documents:
       http://www.epa.gov/oppfead1/Publications/catalog/subpage3.htm


       Massachusetts Department Agriculture Resources – Building Managers
       and Landlords:
       http://www.mass.gov/agr/pesticides/docs/CIB_Building_Managers.pdf



    f.  HUD funded “Healthy Public Housing Project” conducted by the
       Harvard School of Public   Health In Boston Public Housing,
       http://www.hsph.harvard.edu/hphi/
    h.   Bed Bug Fact Sheets in English and Spanish produced by Dr. Dini
       Miller, http://www.vdacs.virginia.gov/pesticides/bedbugs-facts.shtml

12.   PHA Case Studies On IPM Application.

5 Cuyahoga Housing Authority:
        http://www.healthyhomestraining.org/ipm/Case_Study_Cuyahoga_10-20-
        07.pdf

     i. Boston Housing Authority:
        http://www.http://www.healthyhomestraining.org/ipm/casestudy_holgate
        .pdf
    ii. New York City Department of Health, Columbia University and the New
        York City Housing Authority:
        http://www.beyondpesticides.org/dailynewsblog/?p=1604


13.  For further information contact Leroy Ferguson at (202) 402-2411 or
email at Leroy.Ferguson@hud.gov or you can contact the nearest HUD Field
Office of Public Housing within your state.  Indian tribes and TDHEs should
contact the nearest HUD Office of Native American Programs.  Locations of
these offices are available on HUD’s website at
http://www.hud.gov.



                                       _____       /s/
                                  Sandra B. Henriquez, Assistant Secretary
for
                            Public and Indian Housing