HUD Issues New UPCS Inspector Protocol Concerning Bed Bug Infestations

HUD is amending the inspection protocol requirements to be followed by all Uniform Physical Condition Standards (UPCS) inspectors who conduct physical inspections of HUD-assisted and -insured properties. In 2010, HUD issued Inspector Notice 2010-01 establishing requirements when an inspector is informed of bed bugs at a site that is being inspected. Those requirements addressed reporting of bed bugs and the conduct of inspections. The new notice amends the requirements and now requires inspectors to enter all units in which bed bugs are reported.

Researchers at HUD's Office of Lead Hazard Control and Healthy Homes have concluded that the likelihood of bed bug transfer to an inspector from an infested unit is remote. Bed bugs are nocturnal and usually hide on upholstered furniture or beds. They are not very active and do not quickly respond to a human host during the day. Furthermore, HUD concludes that an individual’s movement in a unit during inspection makes it even more difficult for bed bugs to find a host. Therefore, the threat to inspectors is infinitesimally low for bed bugs to be carried out on the inspector following a routine inspection.

Based on this research, effective Feb. 1, HUD is requiring the inspection of all units in the sample generated by the UPCS software, including those reported to have bed bugs.  

What to Expect at Inspection Time

Inspections are to be performed during the site’s normal business hours on Monday through Friday. Inspections may begin at any time during normal business hours on which the site representative and inspector mutually agree. A morning inspection usually begins no later than 9 a.m. and an afternoon inspection usually begins by 1 p.m. Inspectors must conclude the day’s inspections before the end of the site’s business day. And inspection of site and building exteriors must be concluded during daylight hours [REAC Compilation Bulletin Rapid 4.0].

Before beginning the inspection, when the inspector meets with the site representative, the inspector will ask if there have been any reports of bed bugs in any units. The inspector will record the answer in the “Comments” field under the “Property Information” tab of the Data Collection Device (DCD) software.

If bed bugs have been reported, the inspector will call REAC’s technical assistance center (TAC) to report the presence and location of the bed bugs and obtain a reference number. Then the inspector will write the reference number and identify the building(s) and unit(s) with bed bugs in the comments field.

Inspectors are required to enter all units reported to have bed bugs that show up in the sample units generated by the UPCS software and conduct the normal REAC inspection. The presence and treatment of bed bugs on a site won’t be scored in the UPCS inspection.

If bed bugs are discovered after the start of the inspection, the inspector will call TAC and report the presence of bed bugs and the building/unit location. TAC will issue a reference number that the inspector will record in the comments section of the DCD software.

If you or the site representative refuses entry to units reported to have bed bugs, the inspector will call TAC immediately and mark the inspection as unsuccessful.