Recommending bedbug guidance to HUD, USDA, OHFA, ODOD, ODMH and ODD
Help keep the little buggers at bay
Many tenant advocates are aware that HUD's latest guidance on bedbugs (see attached) leaves out a lot of important information for owners seeking to develop a local bedbug policy. The problem is made worse in Ohio where the Ohio Department of Health has taken a "hands off" approach to addressing bedbug concerns. Therefore most owners get their bedbug education FROM PEST CONTROL COMPANIES...which have a vested interest in selling their products and services...
USDA guidance attached below
Five incidents over the past year have brought this home to RHINO advocates.
August 2012, HUD Hub Director Bill Graves invited Joe Maskovyak and Spencer Wells to do a
presentation for the HUD project managers. In the Q&A the HUD staff
wanted to know what we recommended to owners about bedbug control.
Lacking clear guidance from HUD in DC...they have little to offer.
At Rockefeller Park Towers, Spencer was given a spray
bottle--"smell that" the tenant leader said. I did-it smelled like
vinegar and that's right because, according to the label, it was mostly
water and vinegar. Tenants were offered this 'bedbug' spray (sometimes
paying $!6/16 oz bottle) for a useless product. Really expensive salad dressing!
Tenants at Washington Square III (aka: the plaza, aka: the
bedbug building) have taken their campaign to Newark City Council to
address using the property maintenance code to address their bedbug
crisis. Some of their efforts are documented in the current and
previous issues of rhinoUP!
A provider of special needs housing called COHHIO to find out if the
housing provider could bill developmentally disabled client/tenants for
bedbug infestation. Our response: Forcing your clients to pay or be
evicted...is that why you became a housing provider to disadvantaged
A housing provider has written into its lease that the property
manager can seize tenants' belongings IF THE PEST CONTROL CONTRACTOR
determines that they cannot be exterminated.
Jul. 5, 2014 ZANESVILLE — Other than noting when
it gets calls about infestations, the Zanesville-Muskingum County Health
Department doesn’t track or record bed bug infestations in the county.
They’re not considered a public health risk, so bed bugs are not in the
same category as rats, cockroaches or mosquitoes, Public Sanitarian
Matt Hemmer said. Nor is there funding available to conduct
inspections, Hemmer said. However, officials do track the calls that
come in, in case that record is ever needed. They have received 33 calls
about bed bugs in 2013 and so far in 2014.
PS: if ODH won't do the work, maybe legislation might help?
So here's what
we're proposing. the Bed Bug Best Practices Working Group wants to get HUD, USDA, OHFA, ODOD, ODMH, and ODD to adopt these recommendations AS
GUIDANCE to owners in their programs. These would be recommendations,
not mandates, but they would be coming from the regulators to the
housing providers over which they have jurisdiction.
providers must use only licensed Pest Control contractors (it's the
law in the state of Ohio). Good
idea to seek out companies that are experienced with bed bugs (check
references) and with Integrated Pest management.
providers in cooperation with Pest Control consultants and pest
control contractors should prepare a bed bug treatment plan and
share that plan with tenants early and often. Plans should include
staff and tenant training, frequent inspection of every unit and
quick intervention when bed bugs are detected.
Control contractors must be barred from side sales of any product to
tenants. Pest Control Providers are not getting paid by management
to have a fearful, captive market of tenants.
use of over the counter bedbug treatments by anyone: tenants,
managers/maintenance staff, or contractors.
Control contractors should treat all adjacent units (side, top and
down) and adjacent common areas.
Control contractors or trained management staff should make a follow
up inspection within 15 days after the first treatment to address
bounce back from newly hatched eggs.
control contractors should treat tenants furnishings and minimize
the removal infested furnishings from affected units. When
furnishings must be removed, housing provider is responsible to
assure that furnishings are sealed and labeled to prevent spread of
the bedbugs and promptly removed from the property by a licensed
should encourage adoption of Integrated Pest Management principles
in accordance with PIH 2011-22 and HUD's new Healthy Homes
Use of IPM does NOT MEAN shifting responsibility to tenants.
Housing providers should be advised to seek assistance from an IPM
professional to develop an IPM plan for the property. HUD staff
provide links to IPM training materials.
should initiate a review of all house rules and lease addenda
created by housing providers. Encourage housing providers to reach
out to HUD when they have questions about bed bug control.
should remind housing providers that housing providers have an
obligation under Section 504 (24 CFR 8) to provide reasonable
accommodations for tenants with disabilities, including, but not
time for unit prep for treatment,
with doing unit prep for persons who are unable to carry out that
forms of treatment for tenants with chemical sensitivity or
relocation for tenants unable to stay in their units following