Revision of Director’s Rules and Regulations for the Prevention and Control of Bed Bugs June 5th, 2012 1
DPH regulatory milestones Ongoing: Complaint response enforcement of Health Code nuisance standard; routine inspection of limited shelters and SROs 2 0 0 3 : Developed Bed Bug Management Protocol for all Shelter Directors 2 0 0 6 : Issued first Director’s Rules and Regulations for Bed Bug Control 2 0 1 0 : Bed bugs explicitly named as a Article 11 health nuisance 2 0 1 1 : Began stakeholder process for updating rules and regulations 2
DPH 2010 Bed Bug Caseload 3
Owner concerns expressed Questioned their responsibility for tenant-mediated infestations Unclear about the extent of their responsibilities Opposed fines and penalties 4
Pest Control Operators concerns Owners unwilling to pay for true costs of effective abatement Tenants inadequately preparing rooms for treatment Some PCOs doing less than best practices 5
Tenant advocate concerns Frustration with perceived lack of firm and timely code enforcement; new DPH fine authority not utilized Too few Hotel Program inspectors Owners and PCOs not communicating well with tenants in advance of treatment, so treatments are ineffective Owners wanting to spend the minimum possible to prevent and treat bed bugs 6
Comparison with other US cities 7
Internal review process Regulatory practices in other cities Pest control industry best management practices DPH enforcement case records Input of experienced inspectors/ managers Draft revised rules for public hearing Consideration of spoken and written comments City Attorney review 8
External outreach process Stakeholder workshops (PCOs, tenants, landlords, apartment and hotel managers) Presentations of revision-in-progress to: Bed Bug Working Group SRO Task Force Professional Property Management Association Public Hearing on proposed revision Spoken comments (47) Written comments (14) Health Commission review and testimony 9
Substantive changes in rule Increased requirements for prevention: training, written plans, monitoring, encasements, educational info to tenants Provision of DPH templates and resources, e.g. Complaint Response Log Explicit limitation of inspection and treatment to licensed pest control operators (PCOs) Accountability of PCOs to use best practices or be subject to notice of violation Definition of complaint closure process with six week monitoring period 10
Outcomes of outreach process Expertise gained from multiple perspectives Stakeholders engaged and partnerships formed to address bed bug control New focus on the need to ensure PCO best practices 11
Community resource requests Significant investment in public, tenant and manager education. Greater code enforcement resources, particularly proactive inspection of all SRO units, not just master lease or family-occupied. More resources for the reasonable accommodation (e.g., laundry subsidy needs and anti-cluttering help for the incapacitated and low- income population most affected by bed bugs). 12
Next steps for DPH Revision effective July 1 st: Notification to regulated community Website updated Coordination with Recology re. disposal Continued community education provided Stakeholder-specific workshops Enhanced website and educational resources (e.g. video, online tutorial) 1: 1 support for monitoring and control plans in higher risk environments Consider additional resource requests 13
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