Bedbug Best Practices

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.
  • In 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 individuals?
  • 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. 
Not our problem!

 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.

FOR STARTERS
  1. Housing 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.

  2. Housing 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.

  3. Pest 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.

  4. No use of over the counter bedbug treatments by anyone: tenants, managers/maintenance staff, or contractors.

  5. Pest Control contractors should treat all adjacent units (side, top and down) and adjacent common areas.

  6. Pest 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.

  7. Pest 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 waste hauler.

  8. HUD should encourage adoption of Integrated Pest Management principles in accordance with PIH 2011-22 and HUD's new Healthy Homes initiative: http://portal.hud.gov/hudportal/HUD?src=/program_offices/healthy_homes/advhh 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.

  9. HUD 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.

  10. HUD 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 limited to

    • additional time for unit prep for treatment,

    • assistance with doing unit prep for persons who are unable to carry out that responsibility,

    • alternative forms of treatment for tenants with chemical sensitivity or breathing disabilities

      temporary relocation for tenants unable to stay in their units following treatment.





Notes & Links

Health risk?

Integrated Pest Management (IPM)

Real Voices



Subpages (1): Health Risk
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Spencer Wells,
Nov 24, 2012, 7:24 AM
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Spencer Wells,
Nov 24, 2012, 7:39 AM
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Spencer Wells,
Aug 26, 2013, 7:09 AM
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