Dos and Don'ts for Dealing with Bedbugs at Your Site

On Aug. 16, HUD issued Notice H2011-20 on the subject of bedbugs in project-based assisted housing programs. Bedbug infestations have become a serious problem in housing throughout the country, and the 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 owners and managers and residents with regard to bedbug infestations.

You can find the notice under Housing Notices at www.hud.gov. Here are some Dos and Don'ts developed from the information provided in the notice.

Educate Staff and Residents

The most critical safeguard against a bedbug infestation is education. Owners and managers should educate both staff and residents on how to identify bedbugs, basic prevention techniques, and the protocol for notifying management when they suspect the presence of bedbugs.

Special emphasis should be made to communicate to residents that bedbugs are not a hygiene-related pest. Therefore, residents who suspect that they have a bedbug infestation should not be embarrassed or ashamed. The presence of bedbugs is not associated with poor housekeeping or lack of cleanliness—they can emerge anywhere. Also, bedbugs may often go undetected and unreported, because they are active at night, and residents may not be aware of their presence. Owners may wish to hold workshops for residents to learn to identify bedbugs, to create unfriendly environments for pests, and to report suspicions of bedbugs as soon as possible.

Ultimately, HUD encourages owners and managers to have an integrated pest management plan (IPM) in place for controlling the spread of the infestation, inspection by a pest professional, and treatment. According to the Environmental Protection Agency, the principles of IPM include:

• Inspecting infested areas, plus surrounding living spaces;

• Checking for bedbugs on luggage and clothes when returning home from a trip;

• Looking for bedbugs or signs of infestation on secondhand items before bringing items home;

• Correctly identifying the pest;

• Keeping records—including dates when, 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.

Immediately Respond to Reports of Bedbugs

Staff should respond with urgency to any resident report of bedbugs. According to the notice, within 24 hours of the report, the owner should make contact with the resident, provide the resident with information about bedbugs, and discuss measures the resident 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 owner or manager should endeavor to take appropriate action within a reasonable time period. Following a report of bedbugs, the owner or a qualified third party trained in bedbug detection should inspect the dwelling unit to determine if bedbugs are present. It's 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 companies use canine detection to verify the presence of bedbugs. The inspection should cover the unit reporting the infestation and the surrounding units above, below, left, and right, and should be completed within three calendar days of a resident complaint if possible. Reputable licensed pest control companies are often unattainable within three calendar days, but the owner is required to retain documentation of the efforts to obtain qualified services.

If an infestation is suspected but can't be verified using the methods described above, the owner or manager should re-inspect the units 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. Chemical treatments may be necessary, but are 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.

Don't Discriminate Against Applicant with Bedbug History

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

Don't Charge Residents for Cost of Treatments

An owner may not charge a resident to cover the cost of bedbug treatment. Such costs should be covered by the owner from project funds authorized by HUD. If you're thinking about adding clauses pertaining to bedbugs in your leases, remember that HUD reserves the right to approve Lease Addenda. And Lease Addenda may not conflict with the notice.

An owner may contact HUD to request financial resources for bedbug control. The local program center director may honor requests for releases from the reserve for replacement or residual receipts accounts to reimburse an owner for bedbug treatment. The releases should follow the processes outlined in HUD Handbook 4350.1, Multifamily Project Servicing, Chapters 4 and 25. Owners are also encouraged to make advances (loans without interest) when no reserves are available.

HUD may also consider an increased pest control line item in the site's operating budget, if the Section 8 housing assistance payments (HAP) contract allows for budget-based rent setting in accordance with the Section 8 Renewal Policy Guide. However, any request for a rent increase should be part of an ongoing pest prevention program.

Keep HUD Informed If Inspections Report Bedbugs

Bedbugs should be addressed when reported by staff, residents, or the Real Estate Assessment Center (REAC), or if an audit by the HUD Office of Inspector General identifies possible infestation. Presently, REAC inspectors will deduct points only if bedbugs are observed in a unit or building.

However, inspectors now ask the owner or manager to identify any units and/or buildings that are infested before the inspection begins. If bedbugs are reported, the inspector will record the units affected in the comment section of the physical inspection report. The REAC inspector will then send a “Bedbugs Reported” email to the Program Center Director when bedbugs are noted in the comments section of a physical inspection report. The owner will see the information on the inspection report in the comment area.

HUD staff, upon receipt of the “Bedbugs Reported” email from REAC, regardless of the inspection score, will require the owner to describe what actions were taken or will be taken to eradicate the infestation, and the owner must inform HUD when the problem has been completely eradicated.

Search Our Web Site by Key Words: bedbugs; REAC inspection; HUD Notice H2011-20