HUD PIH Notice § 2012-17

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




SPECIAL ATTENTION OF:             NOTICE: PIH-2012-17


 Regional Directors; State and Area
Coordinators; Public Housing Hub
Directors; Program Center Coordinators;            Issued:  February 28,
2012
Troubled Agency Recovery Center Directors;
Special Applications Center Director;        Expired:  This Notice remains
Administrators; Offices of Native American         in effect until amended,
superseded,
Programs; Public Housing Agencies;           or rescinded
______________________________
Housing; Housing Choice Voucher/Section 8;   Cross References:
Tribally Designated Housing Entities;
Indian Tribes; Resident Management
Corporations


SUBJECT:  Guidelines on Bedbug Control and Prevention in Public Housing

 I. Purpose

    Bedbug infestations have become a serious problem in housing throughout
the country.  Public Housing properties are not immune to infestations.
This Notice provides information and references to best practices regarding
the prevention and control of bedbug infestations.  It also provides
guidance on the rights and responsibilities of HUD, Public Housing Agencies
(PHAs) and tenants with regard to bedbug infestations.

II. Background

    After a long absence, bedbug infestations are a growing problem in the
United States today.  According to the United States Environmental
Protection Agency (EPA), bedbug populations have increased dramatically.
Bedbugs are considered a pest of significant public health importance by
the EPA and the Centers for Disease Control and Prevention (CDC).  Although
the insects are not known to transmit disease, bites may itch and cause an
allergic reaction in some people, which may lead to secondary infections.
The presence of bedbugs may also contribute to stress or anxiety.


    Experts suspect the resurgence is associated with greater international
and domestic travel, lack of knowledge regarding the complex measures
needed to prevent and control bedbugs, changes in pesticide availability
and technology, and increased resistance of bedbugs to available
pesticides.  Bedbugs are not an indicator of poor sanitation, but excess
clutter can provide them more places to hide, making early detection and
targeted control difficult.


    HUD has received numerous reports of bedbug infestations in Public
Housing properties in various regions.  HUD is working closely with other
federal agencies to develop and share best practices for preventing and
controlling bedbugs.

III. Applicability

   This notice applies to PHAs administering the public housing and project
based Section 8 program. It may also be of interest to Indian tribes/TDHEs
as well as owners/agents providing assisted housing through the Housing
Choice Voucher (HCV) Program.

IV. Prevention of Bedbug Infestations

    The best approach to bedbug management is to prevent an infestation
from occurring in the first place.  Federal agencies, such as EPA and HUD,
are working in tandem to develop and share recommendations to prevent
bedbug infestations.

    PHAs are strongly encouraged to develop an Integrated Pest Management
(IPM) Plan.  Such plans describe the ongoing efforts the property
management will take to prevent and respond to pests.  For more details on
IPM, please see the online guide at http://www.stoppests.org.  According to
the EPA, principles of IPM for bedbugs include:


            • Raising awareness through education on prevention of bedbugs;
            • Inspecting infested areas, plus surrounding living spaces;
            • Checking for bedbugs in luggage and clothes when returning
              home from a trip;
    • Looking for bedbugs or signs of infestation on secondhand items before
      bringing the items home;
            • Correctly identifying the pest;
            • Keeping records – including dates and locations where pests
              are found;
            • Cleaning all items within a bedbug infested living area;
            • Reducing clutter where bedbugs can hide;
            • Eliminating bedbug habitats;
            • Physically removing bedbugs through cleaning;
            • Using pesticides carefully according to the label directions;
              and,
            • Following up on inspections and possible treatments.


    In addition or as part of an IPM plan, PHAs are strongly encouraged to
take the following preventive steps:


    • Provide training for staff to identify bedbugs, and to perform ongoing
      prevention actions as outlined in the IPM.  When a community is at
      high risk for bedbugs (for example, if the community has experienced
      prior infestations), periodic building inspections are recommended.

    • Actively engage residents in efforts to prevent bedbugs.  Education
      and involvement of tenants is a critical component of IPM for bedbugs.
       Bedbugs may often go undetected and unreported and because they are
      active at night tenants may not be aware of their presence.  PHAs may
      wish to hold workshops for tenants to learn to identify bedbugs, to
      create unfriendly environments for pests, and to report suspicions of
      bedbugs as soon as possible.

    • Provide orientation for new tenants and staff, and post signs and
      handouts regarding bedbug prevention.

    More information on bedbug prevention may be found by accessing the
following websites:[1]

    • Healthy Homes Training:  What’s Working for Bedbug Control in
      Multifamily Housing?:  Reconciling best practices with research and
      the realities of implementation.
http://www.healthyhomestraining.org/ipm/NCHH_Bed_Bug_Control_2-12-10.pdf.

    • National Pest Management Association Bedbug Hub:
http://pestworld.org/pest-world-blog/the-bed-bug-hub-one-stop-shop-for-bed-
bug-information

    • National Pest Management Association Best Practices Website:
http://www.bedbugbmps.org

    • Environmental Protection Agency:
http://www.epa.gov/pesticides/bedbugs/

    • Public Housing Environmental Conservation Clearinghouse (PHECC)
             http://www.hud.gov/offices/pih/programs/ph/phecc/pestmang.cfm

 V. Addressing Infestations

    The PHA should respond with urgency to any tenant report of bedbugs.
Within
24 hours of the tenant report, the PHA should make contact with the tenant,
provide the tenant with information about control and prevention of bedbugs
and discuss measures the tenant may be able to take in the unit before the
inspection is performed.  However, a bedbug inspection and, if necessary,
treatment, may take time to schedule.  The PHA should endeavor to take
appropriate action within a reasonable time period using the guidelines
provided below.

    Following a report of bedbugs, the PHA or a qualified third party
trained in bedbug detection should inspect the dwelling unit to determine
if bedbugs are present.  It is critical that inspections be conducted by
trained staff or third party professionals.  Low level inspections may
escape visual detection.  For this reason, multiple detection tools are
recommended.  Recent research indicates that “active” bedbug monitors
containing attractants can be effective tools for detecting early
infestations.  Some licensed pest control applicators use canine detection
to verify the presence of bedbugs.  The inspection should cover the unit
reporting the infestation and no less than surrounding apartments
consisting of the units above, below, left and right, and should be
completed within three business days of a tenant complaint if possible.  If
reputable, licensed pest control companies are unattainable within three
calendar days, the PHA is required to
retain documentation of the efforts to obtain qualified services.  If an
infestation is suspected but cannot be verified using the methods described
above, the PHA should
re-inspect the unit(s) periodically over the next several months.


    When an infestation is identified, the unit and surrounding units
should be treated for bedbugs according to the IPM Plan.  Chemical
treatments are necessary, but not reliable.  Therefore, encasement,
interception devices, vacuuming, steaming, freezing and commodity or
building heat treatments may be utilized as part of the bedbug control
effort.  Infestations are rarely controlled in one visit.  Effective
treatment may require two to three visits, and possibly more.  The length,
method and extent of the treatment will depend on the severity and
complexity of the infestation, and the level of cooperation of the
residents.

VI. Additional Considerations

    PHAs may offer protective tools to residents to help safeguard
properties from infestation and recurrences.  For example, the PHA may
offer residents bed covers, climb-up interceptors, or other detection or
protection devices that may become available.  PHAs may voluntarily offer
to inspect tenants’ furniture before move-in.  PHAs may also offer tenants
a service of non-chemical treatment of household items upon tenant move-in,
non-chemical treatment or inspection of used furniture and/or non-chemical
treatment of luggage before it is unpacked when a tenant returns from a
trip.  Tenants may voluntarily use such services, but PHAs may not require
tenants to do so.  These services or products are to be offered at the PHAs
expense.

    A PHA may not deny tenancy to a potential resident on the basis of the
tenant having experienced a prior bedbug infestation, nor may give
residential preference to any tenant based on a response to a question
regarding prior exposure to bedbugs.  A PHA may not charge a tenant to
cover the cost of bedbug treatment; such costs should be covered by the
PHA. HUD reserves the right to approve Lease Addenda.  Lease Addenda may
not conflict with this Notice.










VII. Tenant Rights and Responsibilities


    Tenants are strongly encouraged to immediately report the suspicion of
possible bedbugs in a housing unit or other areas of the property.  Early
reporting allows the pests to be identified and treated before the
infestation spreads.  Tenants are the first line of
defense against bedbug infestations and should be encouraged to create
living environments that deter bedbugs.  This includes reducing
unreasonable amounts of clutter that create hiding places for bedbugs, and
regular checking of beds and laundering of linens.

    Bedbug infestations can cause health concerns, including physical
discomfort and may contribute to stress and anxiety on the part of the
residents.  Tenants should be advised of the following:


         • A PHA may not deny tenancy to a potential resident on the basis
           of the tenant having experienced a prior bedbug infestation, nor
           may an owner give residential preference to any tenant based on
           a response to a question regarding prior exposure to bedbugs.

         • A tenant reporting bedbugs may expect expeditious response and
           attention by the PHA, but should be advised that inspection and,
           if necessary, treatment of bedbugs may take time to schedule.
           The inspections should occur within three calendar days of the
           tenant report when possible.


         • Following a report of bedbugs, the PHA or a qualified third
           party trained in bedbug detection should inspect the dwelling
           unit to determine if bedbugs are present. It is critical that
           inspections be conducted by trained staff or third party
           professionals. The PHA may enter the unit to perform these
           activities, in accordance with the lease.

         • If bedbug infestation is found in the unit, the tenant may
           expect treatment to begin within five days of the inspection,
           though depending on the form of treatment, this may not be
           possible.  Tenants should be advised that treatment may take
           several weeks.

         • Tenants are expected to cooperate with the treatment efforts by
           allowing for heat treatment of clothing and furniture and
           refraining from placement of infested furniture or other items
           in common areas such as hallways. Tenant cooperation is shown to
           expedite the control of bedbugs and to prevent spreading of
           infestations.

         • Management may make staff available to help with moving and
           cleaning of furniture to accomplish the treatment effort.

         • The tenant will not be expected to contribute to the cost of the
           treatment effort.

         • The tenant will not be reimbursed the cost of any additional
           expense to the household, such as purchase of new furniture,
           clothing or cleaning services.

VIII. REAC Inspections

    Bedbugs should be addressed when reported by staff, tenants or the Real
Estate Assessment Center (REAC), regardless of the score of the REAC
physical inspection.  Inspectors ask the PHA to identify any units and/or
buildings that are infested before the inspection begins.  When bedbugs are
reported or observed, the inspector will record the units and/or buildings
affected in the comment section of the Physical Inspection report, noting
that bedbugs were reported. The inspector will then select an alternate
unit to inspect to replace any unit with observed or reported bedbugs.

    REAC sends a “Bedbugs Reported” email to the local PIH field office with
a copy to the PIH Regional director when bedbugs are noted in the comments
section of a Physical Inspection Report.  The PHA will see the information
about bedbugs in the comment section of the Physical Inspection Report
which provides PHAs with the necessary information to address the
situation.





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






Attachment

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[1] An additional resource for interested parties is the Bedbug Handbook.
L.J. Pinto, R. Cooper, and S.K. Kraft, Bedbug Handbook: The Complete Guide
to Bedbugs and Their Control (Mechanicsville, MD: S.K. Pinto & Associates,
2007).