Revision of Directors Rules and Regulations for the Prevention and - - PowerPoint PPT Presentation

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Revision of Director’s Rules and Regulations for the Prevention and Control of Bed Bugs June 5th, 2012

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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

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DPH 2010 Bed Bug Caseload

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Owner concerns expressed

 Questioned their responsibility for

tenant-mediated infestations

 Unclear about the extent of their

responsibilities

 Opposed fines and penalties

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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

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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

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Comparison with other US cities

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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

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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

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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

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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

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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).

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Next steps for DPH

 Revision effective July 1st:

 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