Bed Bug Resources
At NAA/NMHC's Urging, HUD Issues Revised Bed Bug Guidance
On April 23, 2012 at the urging of NAA/NMHC, HUD issued new bed bug guidance (Notice
H-2012-5) to replace the troublesome notice (H-2011-20) issued last summer.
In letters and meetings with senior HUD staff, an NAA/NMHC-led coalition objected
to the original guidance, noting that it created confusion about best management
practices, hamstrung the efforts of owners and property managers to prevent infestations
and failed to meaningfully address the financial issues to the owner and resident
related to recurrent infestations. We also objected to the expansive scope,
which included FHA-insured properties.
The new notice addresses many of our concerns and emphasizes the shared responsibilities between property management
staff and residents to prevent or eliminate infestations. Importantly, it
allows owners to conduct voluntary inspections and to treat resident's possessions
as part of an Integrated Pest Management Program (IPM). Treatment costs
may be partially recovered in conformance with HUD's model lease.
This revised Guidance applies to properties receiving HUD assistance (e.g.,
project-based Section 8); it does not apply to properties taking Section 8 vouchers.
While the new Guidance still applies to FHA-insured properties, it explicitly
notes that it does not supersede state and local tenant laws, which dramatically reduces its scope.
In separate action, on February 28, HUD's Office of Public and Indian
Housing issued a notice (PIH-2012-17)
that applies to public housing and project-based Section 8 properties and, in
HUD's words, may be of interest to "owners/agents providing assisted
housing through the Housing Choice Voucher (HCV) Program." The Notice
"encourages" properties to develop IPM programs that include a resident
and staff education component; it did not address any financing issues.
NAA/NMHC met with HUD Deputy Assistant Secretary Marie Head last Friday
to discuss the Notices. We voiced concern that there are two separate notices
on the same subject matter, although HUD maintains this will not be problematic.
We also reiterated our contention that many properties do not have the financial
resources to deal with a recurrent or large scale infestations and suggested that
HUD needs to work closely with owners to identify sufficient resources without
compromising other aspects of the property.
We will continue to
work with the administration to refine guidance and efforts to effectively and
responsibly respond to infestation issues.
Overview of Bed Bugs
Bed Bug infestation is a growing problem around the country, but also here in Michigan. The Michigan Department of Community Health has pulled together a work group to address concerns and provide information to the public relating to this issue. Our first meeting was held on 1/14/08 in Lansing. MDCH asked that PMAM send a representative from the organization to represent the interests of multifamily housing.
The work group consisted of members from the Michigan Department of Health,
Michigan Department of Agriculture, Michigan State University, Michigan Environmental Health Association, Michigan Pest Control Association, Wayne County Health Department, and the PMAM, representing the property management industry. Everyone felt that there is little information available from within Michigan and that this work group could possibly take the lead in providing information to Michigan residents concerning this growing problem.
Eric Foster, with MDCH, let the initial workgroup meeting and hosted the meeting as well. The meeting lasted four hours and resulted in four subcommittees being formed. Gary Offenbacher represented PMAM and the housing industry for the initial meeting. It was suggested that the Motel/Hotel industry also be invited to participate and possibly the College housing industry.
Issues addressed by the group:
1. Quality of Life Issues.
2. Anxiety issues surrounding infestations.
3. Difficulty in control and management.
4. Public Education and Communication.
5. Residents with Special Needs.
6. Workforce training issues.
7. Toxicity of Pesticides and health risks.
8. Legal and enforcement issues.
9. Tracking of complaints.
10. Legal and Legislative concerns.
11. Cost and available resources.
The Committees formed picked some areas to target information on:
Scientific-Basic Biology, History of problem in Michigan, Resistance to treatments and pesticides.
Treatment Guidelines/ Safe Pesticides Use-research Cornell paper on homeless shelter infestations, Fact sheet and MDA Brochure, Inspect-Identify-IPM-Control Practices-Monitoring., Chemical vs. Non Chemical, Registered Pesticide List, Immediate Solutions.
Laws and Regulations-Matrix of Relevant laws, Definition from regulatory standpoint, Case Law and financial responsibility, Advocacy, Local health department jurisdictional issues.
Education/Training and Communication.-Licensed pest management company link, local jurisdiction contact list, training powerpoint, stigma and psychology.
It was agreed that the four groups would try to assemble a basic body of knowledge by and the subgroups would meet by phone or in person before the next work group meeting. The end product may be a binder with information about what is working in Michigan to combat bed bugs and numerous references of places to get further information and resources.
The following links and forms are provided as a resource as a result of the efforts of the caolition mentioned above.
Please Note Terms and Conditions of Use: The intent for the data on this website is for informational purposes for PMAM and Affiliate members only, and does not constitute professional advice or even purport to amount to opinion. Since every legal issue is different, suitable legal counsel should be consulted to advise on and resolve specific matters. The documents on this website are made available as guides only and you use them at your risk. This means that you accept that PMAM or any of itsí affiliations will not be liable in any respect concerning wording of the documents, or their interpretation, or any disputes which may arise from their use.
All legal documents should be reviewed by an attorney before utilization.
Bed Bug Addendum
Bed Bug Infestation - Manager Response
Bed Bug Treatment Plan Phase 2
Bed Bug Free Certification for Move In
Bed Bug Treatment Agreement Sample
Bed Bug Treatment Agreement Sample 2
Links and Additional Resources
Download and Print the Bed Bug Brochure (English)
Download and Print the Bed Bug Brochure (Spanish)
Download and Print the Bed Bug Brochure (Arabic)
Michigan Department of Community Health (MDCH) Bed Bug Resources
Bed Bug Mattress Encasements
What Other Advocacy Groups are Saying About Michigan's Bed Bug Work Group
Bed Bug Advocacy Group Blogs
Michigan Bed Bug Workgroup Updates
Bed Bug Workgroup Update 7/09
Bed Bug Workgroup Update 3/09
More details - Volunteers welcome!