HUD PIH Notice § 2011-22
Promotion of Integrated Pest Management (IPM) as an environmentally-sound, economical and effective means to address a major resident concern (HUD PIH Notices)
Operative Text
[pic] U.S. Department of Housing and Urban
Development
Office of Public and Indian Housing
Special Attention of: NOTICE: PIH-2011-
22
Regional Directors; State and Area
Coordinators; Public Housing Hub
Issued: April 26, 2011
Directors; Program Center Coordinators;
Troubled Agency Recovery Center Directors;
Special Applications Center Director;
________________________
Administrators; Offices of Native American Cross
Reference:
Programs; Public Housing Agencies; Public 24 CFR
903.7(e) (2)
Housing; Housing Choice Voucher/Section 8; 24
CFR 990.165
Tribally Designated Housing Entities;
7 U.S.C. 136r-1 Integrated Pest
Indian Tribes; Resident Management Management
Corporations
This Notice Supersedes
PIH Notice 2009-15, PIH Notice
2008-24, PIH Notice 2007-12
Subject: Promotion of Integrated Pest Management (IPM) as an
environmentally-sound, economical and effective means to address a major
resident concern.
1. Purpose. The purpose of this Notice is to promote and encourage the
use of IPM by Public Housing Authorities (PHAs), Indian tribes, Tribal
Designated Housing Entities (TDHEs), and owner/agents providing
assistance through the HCV program. This notice provides guidance to
Public Housing Authorities (PHAs) on the benefits of IPM, additional
technical assistance and training opportunities for PHAs. Pest
management is integral to the provision of safe and sanitary housing.
In accordance with 24 CFR 903.7 (e) (2), PHAs must include in their PHA
plans a description of any measures necessary for the prevention or
eradication of pest infestations. IPM is an ecological approach using
an array of methods to prevent and control pests with reduced reliance
on pesticides. Procedures contained within this notice remain in effect
until superseded by subsequent HUD Directive or guidance.
2. Applicability. This notice applies to PHAs administering the public
housing and project based Section 8 program, and may be of interest to
Indian tribes/TDHEs as well as owners/agents providing assisted housing
through the Housing Choice Voucher (HCV) Program. The decision to use
IPM techniques in their ongoing pest control effort is under PHA,
Indian tribes/TDHE discretion. 24 CFR 990.165(a) covers cost
associated with Project Expense Level (PEL) such as maintenance
expenses. IPM is a maintenance expense.
3. Background. The goal of IPM as defined by the Environmental Protection
Agency (EPA) is to control pests by the most economical long term
means, and with the least possible hazard to people, property, and the
environment. To undertake IPM, project managers should be committed to
ongoing or continuous monitoring and record keeping, educational
outreach to residents and staff as well as implementing good
communication strategies between residents and building managers. IPM
methods include: restricted pest access to food/water; vigilant
sanitation and waste management; mechanical control; physical barriers;
structural maintenance; and, where necessary, the judicious use of
pesticides.
4. Fundamentals of IPM. IPM efforts must involve PHA staff, contractors,
residents, and include:
a. Communicating the PHA’s IPM policies and procedures to be provided
in the appropriate format to meet the needs of all residents
including persons with limited English proficiency and in formats
that may be needed for persons who are visually or hearing
impaired. This applies to administrative staff, maintenance
personnel, and contractors as well.
b. Identifying the environmental conditions that lead to pests and
educating residents.
c. Identifying pests and immediately reporting the presence of pests.
d. Establishing an ongoing monitoring and record keeping system for
regular sampling and assessment of pests, surveillance techniques,
and remedial actions taken, include establishing the assessment
criteria for program effectiveness. This is a highly effective
preventative measure that can help reduce the possibility of a
pest infestation outbreak.
e. Determining, with the involvement of residents, the pest
population levels – by species – that will be tolerated, and
setting thresholds at which pest populations warrant action.
f. Improving waste management and pest management methods.
g. Selecting the appropriate pesticides and insecticides to use.
Some residents may suffer from Multiple Chemical Sensitivity or
other Environmental Illnesses.
h. Ongoing efforts to monitor and maintain structures and grounds
(e.g., sealing cracks, eliminating moisture
intrusion/accumulation) and adding physical barriers to pest entry
and movement.
i. Developing an outreach/educational program to ensure that leases
reflect residents’ responsibilities for: (1) proper housekeeping,
which includes sanitation upkeep and the reduction of clutter,
trash removal and storage, (2) immediately reporting the presence
of pests, leaks, and mold, (3) cooperating with PHA specific IPM
requirements such as obtaining permission of PHA management before
purchasing or applying any pesticides, and (4) avoiding
introduction of bed bugs and other pests into buildings on used
mattresses and other recycled furniture. See “Preventing and
Getting Rid of Bed Bugs Safely,” New York City Department of
Health and Mental Hygiene
http://www.nyc.gov/html/doh/downloads/pdf/vector/bed-bug-guide.pdf
j. Check with local health department to determine if your state has
laws for re-used furnishings.
k. The judicious use of pesticides when necessary, with preference
for products that, while producing the desired level of
effectiveness, pose the least harm to human health and the
environment. Residents should notify PHA management before
pesticides are applied.
l. Providing and posting “Pesticide Use Notification” signs or other
warnings.
5. Health Concerns. Pests may adversely impact the health of residents
and contribute to worsening some diseases, such as allergies and
asthma. Cockroaches can cause asthma in children and can transfer
disease-causing organisms to food and surfaces they contaminate.
Rodents, such as mice and rats, carry disease, can trigger asthma
attacks and even cause fires by gnawing through electrical wires.
Although bed bugs are not known to transmit infectious diseases, their
bites can lead to secondary infections. Bed bugs can cause emotional
distress and sleep deprivation for residents as well. Bed bug
infestations can spread quickly and must be treated aggressively. All
pest control methods are targeted to protecting the health of residents
and staff. Although applying pesticides may be effective in
eliminating pest populations, many of these chemicals are associated
with health and/or environmental risks, and their use should be
minimized if alternative methods exist. This is especially important
in buildings housing vulnerable age groups such as children or the
elderly and in buildings housing residents with compromised immune
systems or who may suffer from Multiple Chemical Sensitivity and other
environmental illnesses. Therefore, IPM offers the potential to ensure
efficacy of pest elimination while protecting the health of residents,
staff and the environment.
6. Building. Most of the effective methods of pest elimination, including
ongoing repairs, erection of barriers, and monitoring, will extend the
useful life of a building and as a result generate significant savings
that could offset the costs of the pest control. Many of these non-
application methods, including structural maintenance, and inspecting
for and repairing leaking pipes and cracks in roofs, walls, and windows
are effective in preventing moisture intrusion and accumulation.
Additionally, IPM-conscious PHAs assess the need to install physical
barriers to both pest entry and pest movement within every structure
thereby reducing the spread of pest infestations.
7. Implementation. HUD promotes IPM as a pest control method. IPM
effectively eliminates pests in safer and long term cost-effective ways
than traditional pesticide treatments. IPM frequently has proven to be
more effective in reducing pest populations than relying solely on
broadcast pesticides. The Boston Housing Authority (BHA) experienced
approximately one-third reduction in pest related work orders over
multiple years in multiple sites. BHA has maintained this reduction
and now uses IPM in all its BHA maintained properties. Continuation of
the IPM program after initial development cost is considered
preventative maintenance expense and is an eligible program activity
under the Public Housing Operating Subsidy as codified at 24 CFR
990.165. Successful IPM requires resident participation through proper
housekeeping, reporting of pest infestations, and trash removal.
Residents can monitor pest populations and assist in identifying how to
eliminate access to food and water for pests. Resident organizations
must be prepared to assist residents who need help to follow the IPM
policy. HUD encourages PHAs to partner with local pest management
organizations.
8. Procurement of IPM Services. If a PHA uses an outside contractor for
pest control, the PHA’s pest control/IPM policies and procedures should
be incorporated into the specifications or statement of work for the
pest management contract. PHAs using an outside contractor are
encouraged to use companies that are trained and certified to provide
IPM services either through Green Shield certified
(http://www.greenshieldcertified.org/) or Green Pro
(http://www.npmagreenpro.org/). The PHA should also consider training
for maintenance staff, residents, Resident Councils as well as PHA
administrative staff who oversee housing developments or administer
occupancy and rental duties such as unit housekeeping inspections.
9. PHA Maintenance Staff. If a PHA uses its own maintenance staff for
pest management, proper training in the PHA’s IPM procedures is
essential. It is especially critical to be trained in the proper
treatments methods PHAs can use when treating for bed bugs. The
contract administrator for any pest management contract should be
trained as well. Successful results rely upon proper implementation;
training is therefore of critical importance. IPM training is
available at: http://www.stoppests.org/ and
http://www.healthyhomestraining.org/ipm/training.htm.
10. Area of High Concern, Bed bugs. As the number of bed bug infestations
rise throughout the country, HUD is in the process of developing
protocols to address this growing problem. HUD is addressing the unit
inspection process as well as developing the tools necessary for PHAs
to identify, treat and monitor the effectiveness of bed bug treatments
in its portfolio. Identifying, reporting, treating and monitoring pest
infestations are all critical components of IPM and are effective in
addressing the bed bug problem.
11. Reference Materials for Implementing IPM. The below list of IPM
practices does not constitute a HUD endorsement of any specific
practice, but provides IPM ideas and practices that have been used to
improve pest management while reducing unnecessary dependence on
pesticides. HUD encourages PHAs, Indian tribes/TDHEs to share their
policies, procedures, resident leases, and written case studies so that
these may be published on the HUD website for others to read.
a. National Center for Healthy Housing:
http://www.healthyhomestraining.org/ipm
b. Bed Bugs: “What’s Working for Bed Bug Control in Multi-family
Housing”
http://www.healthyhomestraining.org/ipm/NCHH_Bed_Bug_Control_2-12-
10.pdf http://pestworld.org/pest-world-blog/the-bed-bug-hub-one-
stop-shop-for-bed-bug-information
c. National Pesticide Information Center: http://www.npic.orst.edu/
d. Integrated Pest Management (IPM), A Guide for Managers and Owners of
Affordable Housing, Boston Public Health Commission:
http://http://asthmaregionalcouncil.org/uploads/IPM/asthma_ipm_guide.
pdf.
e. U.S. Environmental Protection Agency:
1 General IPM information http://www.epa.gov/opp00001/contolling/index.htm
housing): http://www.epa.gov/pesticides/ipm
2 EPA staff contacts: http://www.epa.gov/pesticides/about/contacts.htm#ipm
3 List of EPA IPM publications and instructions for ordering
documents:
http://www.epa.gov/oppfead1/Publications/catalog/subpage3.htm
Massachusetts Department Agriculture Resources – Building Managers
and Landlords:
http://www.mass.gov/agr/pesticides/docs/CIB_Building_Managers.pdf
f. HUD funded “Healthy Public Housing Project” conducted by the
Harvard School of Public Health In Boston Public Housing,
http://www.hsph.harvard.edu/hphi/
h. Bed Bug Fact Sheets in English and Spanish produced by Dr. Dini
Miller, http://www.vdacs.virginia.gov/pesticides/bedbugs-facts.shtml
12. PHA Case Studies On IPM Application.
5 Cuyahoga Housing Authority:
http://www.healthyhomestraining.org/ipm/Case_Study_Cuyahoga_10-20-
07.pdf
i. Boston Housing Authority:
http://www.http://www.healthyhomestraining.org/ipm/casestudy_holgate
.pdf
ii. New York City Department of Health, Columbia University and the New
York City Housing Authority:
http://www.beyondpesticides.org/dailynewsblog/?p=1604
13. For further information contact Leroy Ferguson at (202) 402-2411 or
email at Leroy.Ferguson@hud.gov or you can contact the nearest HUD Field
Office of Public Housing within your state. Indian tribes and TDHEs should
contact the nearest HUD Office of Native American Programs. Locations of
these offices are available on HUD’s website at
http://www.hud.gov.
_____ /s/
Sandra B. Henriquez, Assistant Secretary
for
Public and Indian Housing
PIH Notice 2011-22 promotes Integrated Pest Management (IPM) as the preferred approach to pest control in federally assisted public housing, superseding earlier HUD notices on the same subject. The notice describes IPM as an ecological strategy that combines monitoring, sanitation, structural maintenance, resident education, and the judicious use of pesticides to reduce pest populations while minimizing health and environmental risks. Under 24 CFR 903.7(e)(2), Public Housing Authorities are required to include pest prevention and eradication measures in their PHA plans, and IPM costs are recognized as eligible maintenance expenses under 24 CFR 990.165.
Plain English — not legal advice.
Property owners and managers operating under PIH Notice 2011-22 generally maintain documented IPM programs that include ongoing pest monitoring, record keeping, and resident outreach in accessible formats for all residents, including those with limited English proficiency or disabilities. Compliant operators typically incorporate their IPM policies into contractor specifications, ensure maintenance staff receive proper IPM training, and post pesticide-use notifications as required. PHAs are also expected to reflect residents' housekeeping and reporting responsibilities in lease agreements, consistent with the fundamentals outlined in Section 4 of the notice.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
PIH Notice 2011-22 recognizes that residents play an active role in IPM programs, including reporting pest sightings promptly, maintaining proper sanitation, and cooperating with PHA-specific requirements such as obtaining management approval before applying any pesticides. Tenants in public housing or HCV-assisted units have an interest in knowing that their PHA is required under 24 CFR 903.7(e)(2) to address pest prevention and eradication in its PHA plan, which can be reviewed or raised as a concern through the PHA's resident council or complaint process. Those seeking additional guidance may contact HUD's nearest Field Office of Public Housing, as referenced in Section 13 of the notice, or reach out to a local tenant-rights organization for information on available options.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
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