Implementing Integrated Pest Management
By Carolyn E. Zezima, Esq.
Controlling pests is an essential aspect of maintaining your site in a safe and healthy condition as well as complying with HUD physical inspection standards. Pest infestations create significant health risks for people and can result in a pretty big deduction from your REAC inspection score for a health and safety violation. For example, cockroaches and rodents are considered major public health risks to staff and residents, particularly children and the elderly, causing bacteria, viruses, and other diseases and triggering allergies and asthma.
But sometimes the cure is worse than the disease: Traditional pest management relies heavily on the use of dangerous pesticides inside and outside, and where children and elderly residents live. Pesticides have poisoned many thousands of humans and animals each year and are linked to short- and long-term health problems, like rashes and skin damage, eye irritation, respiratory problems, neurological and hormonal damage, and even cancers and genetic defects. In addition to human health risks, many pesticides harm the environment, contaminating our water and posing risks to beneficial and ecologically important plants and wildlife—including fish, birds, honeybees, and other animals.
This is why HUD encourages sites to use Integrated Pest Management (IPM) instead of spraying dangerous pesticides on a regular basis. IPM is safer because non-chemical methods are the first line of defense, and when chemicals must be used, the least hazardous are chosen.
We’ll give you the basics on IPM and spell out eight steps to implementing a safe and effective IPM program at your site.
IPM is an environmentally friendly approach to controlling pests. IPM is safer than traditional pest control because it focuses on non-pesticide methods, and uses pesticides only as a last line of defense. IPM involves four basic approaches:
• Identifying and monitoring problem pest populations and vulnerable areas at your site over time
• Setting maximum pest thresholds based on each pest type for when their presence becomes a nuisance, health hazard, or economic threat requiring additional action
• Preventing pests from entering or thriving at your site by removing conditions that attract and nurture pests, such as food, water, and shelter
• Controlling pests that exceed thresholds using the most effective, lowest risk method, such as improving sanitation, creating barriers, using traps, or using biological controls, and choosing the least hazardous products if or when pesticide chemicals must be used
HUD rules encourage IPM practices in assisted and public housing sites. Notice PIH 2011-22 spells out the benefits of IPM, guidance for implementation, and training opportunities for PHAs and Section 8 sites. The notice states:
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.
Pesticide extermination methods, besides exposing people and the environment to harm, is effective only as long as the pesticides remain potent and only if the pests actually come in contact with them. IPM is more effective than traditional extermination because it uses a team approach that includes staff and residents to solve pest infestations and prevent future ones, uses inspection and monitoring to identify where the priority areas are, and uses solutions that prevent pest populations from thriving and growing.
IPM will save you money in the long run. Though initially your labor costs and costs of repair may increase, once your pest problems are fixed, your overall site expenses will go down as costs of pest damage and annual pest management costs go down. Also, by making some of the repairs that help keep pests out, like filling holes and cracks, and repairing leaks and moisture problems and such, your energy costs and potential damage costs will also decrease.
Take Eight Steps to Implement IPM Program
Identifying, reporting, treating, and monitoring pest infestations are all critical components of IPM. Here are the eight steps to take to do this properly:
Step #1: Create IPM team. Rather than turn over all pest control to an outside exterminator, IPM uses a team of people with an IPM coordinator as the leader of the team. An IPM team may include any or all of the following:
• IPM coordinator
• Management and administrative staff
• Resident services
• Maintenance staff
• Landscape staff and contractors
• Trash removal companies
• IPM contractors
• Resident leaders
You need someone to oversee and coordinate IPM work. This person should be a site manager or other site-wide staff member with maintenance knowledge, who reports to the site manager. The IPM coordinator is the main contact and liaison between residents, staff, and contractors and:
• Keeps records of all pest sightings by staff or residents and actions taken, including any pesticides used
• Hires and evaluates the work of any outside contractors
• Evaluates how the IPM program is working
• Updates the IPM plan with the help of the team
Everyone on the IPM team should understand IPM basics and get trained on his or her role in IPM. Maintenance staff are particularly key to successful IPM because they keep your site in a healthy condition and must work with an IPM contractor (if you decide to use one) to fix maintenance problems and sources of pests, such as leaks, cracks, and holes in walls, pipes, and structures. Their participation is essential to keeping common areas such as hallways, stairways, basements, landscape, laundry, and trash areas clean, dry, and free of clutter. They can alert IPM contractors to pest problems, help report monitoring results, pest problems, and any actions taken in IPM logs, and follow up any IPM contractor recommendations.
HUD encourages owners and managers to partner with local pest management organizations. Involving your landscape staff and contractors is also important because many pests come from outside. Landscapers can help control pests using landscape IPM practices like proper plant choice, placement, and maintenance, such as watering and fertilizing methods. Avoiding dangerous pesticides and herbicides outside as well as inside protects vulnerable residents such as pregnant women and children from adverse health effects and keeps the soil and environment healthy.
Editor’s Note: For more information on IPM and other green methods in landscaping, see Section 3.5: Using Green Landscaping Practices, in Sustainable Affordable Housing Management: A Money-Saving Guide to Keeping Your Site Green, Healthy & Energy Efficient.
Also, recruit and train a resident leader or other resident IPM champion to promote the program and help educate residents on IPM and encourage their cooperation. Without the support of residents, your IPM program will not be effective.
Hire only certified IPM professionals. IPM requires more skill and knowledge than conventional pest control and many contractors may not be capable of providing quality IPM services. If you hire a pest management professional (PMP) for pest control, it is important to hire a qualified contractor that is trained and certified to provide IPM services. HUD advises sites use companies that are trained and certified either through Green Shield or Quality Pro or in California, EcoWise.
When bidding out for contractors, incorporate your IPM practices into the bid specifications. Other minimum qualifications and requirements to seek include:
• Evidence of skill at providing IPM services, including continuing IPM training and samples of successful IPM programs
• At least five years’ experience providing pest control services
• Certificate of contractor’s general liability insurance
• Certificate of worker’s compensation insurance
• Names of all pesticide applicators and copies of current pesticide applicator licenses
• Sample labels and SDS (safety data sheets) fact sheets about pesticides when requested
• Written IPM work plan
• Positive references from similar sites and good record with state licensing agencies
• Association membership such as the National Pest Management Association or your state’s chapter and any other certifications, such as Associate Certified Entomologist (ACE) or Board Certified Entomologist (BCE).
Editor’s Note: If you do decide to use your own maintenance staff for pest management, proper training in IPM procedures is essential. HUD recommends two sources of IPM training, available at: http://www.stoppests.org/ and http://healthyhousingsolutions.com/training-course/integrated-pest-management-in-multifamily-housing/.
Step #2: Create a written IPM policy. Together as a team, develop a short written IPM policy that:
• Defines IPM
• Says why IPM is important to your site
• Spells out the main responsibilities of site staff and residents
• Gives the main steps for putting IPM in practice at your site
Once you have written and approved the IPM policy, distribute and communicate it to all site staff and residents. Post it in your office and translate it into all major languages used by residents at your site. Hold meetings with site staff and residents to explain why you are establishing an IPM program and get their support and participation. Give a copy of the policy to new residents when they move in and at regular unit pest inspections and have residents certify in writing that they have received it. Include a copy of the policy if you bid out for pest control contractors.
To help you draft your policy, we’ve created a Model IPM Policy (see below) you can adapt and use at your site, based on one recommended by the Boston Health Commission. It spells out the responsibilities of management and residents to help ensure that the IPM program is effective and documented.
Step #3: Create recordkeeping system to monitor and track program. Keeping current and accurate records helps you evaluate and update your IPM plan and pest control procedures and eliminate ineffective and unnecessary treatments. Keep records for focus units you will monitor and document the target pest and quantity, locations, conditions present that contribute to pest infestation; type of prevention or nonchemical pest control method used; name and quantity of pesticide used, if any; site of application; date of application; time of application; name of the applicator; and the application equipment used. Use a separate form for each unit to better track pest trends over time.
Keep records on site in an IPM log, with sections for:
• Site-specific IPM plan
• Unit or other monitoring tracking and inspection logs
• Service schedule
• Service log (containing outside IPM contractor service forms)
• Applicator licenses
• Product labels
• A listing of the pesticide products that are used on the site and a link to, or printed copies of, the labels and Safety Data Sheets (SDS) for each type of pesticide
• Proof of registrations/licensing/insurance
• The IPM contractor service agreement (or pest control crew scope of work)
• Educational materials for staff and residents
Step #4: Identify problem pests. Find out what kind of pests you have at your site and where they are living and hiding. The best way to do this is to lay sticky traps in strategic locations around the site and record the date and location on the trap before placing them with trap numbers so you can keep track.
Some pests like cockroaches run along corners, so be sure to place the traps in the corner of two walls so a cockroach running along the wall will have to go through it. Put the trap in places that hold heat and moisture, in food storage areas, and wherever you see signs of pests, such as feces. Place them in unit kitchens, by the refrigerator, oven, under the sink, and in pantries, and in all bathrooms, behind toilets and under sinks in at least 10 percent of resident units.
Monitor the results with a log by recording the following information:
• Date trap placed
• Trap #
• Location of trap
• Condition when trap checked (pest or no pests)
• Type and number of pests found (e.g., mice, cockroaches)
• Damage or other evidence of pest activities (such as holes, chew marks, or feces)
• Pest management action required (such as sealing pipes, better sanitation, or setting gel baits or mousetraps)
• Notes (any follow up or additional information)
We’ve created a Model Log (see below) you can adapt to keep track of the date, location, and results of your pest monitoring efforts. Include this log with your other records in the main IPM log book.
Step #5: Set maximum action threshold. The action threshold is the maximum number of a particular pest population that you set (based on the type of pest and the harm it can cause, the time of year, and the site location) that you will tolerate without risk of harm to people, the environment, and your site. You and your team, including any outside IPM contractors, should research various common pests and decide on action thresholds for each kind of pest commonly found at your site. One option is to define a high-, medium-, and low-level of infestation. When an action threshold is reached, scale control efforts to the level of infestation.
Step #6: Take action using non-pesticide management methods. All pests look for food, water, and shelter. If you understand what they are coming for, you can take it away. The best way to manage pests is to focus on ways to deny them these three basic needs for survival at your site. To do this:
Improve site management practices including sanitation, waste management, watering, food storage, and other behavior changes. Keep site in a clean and sanitary condition. Regularly remove trash and clean indoor and outdoor trash and compost areas, laundry rooms, and storage areas. Make sure trash cans are large enough and do not overflow, are in good condition with tight lids, and where possible, locate trash areas at least 25 feet from the building.
Use physical barriers and controls to prevent pest entry and movement. Seal entry points such as gaps in walls, pipes, pavement, and other surfaces using caulking, steel wool, or other pest-proof materials. Seal cracks in walls, foundation, and floors, and any exterior holes that are greater than ¼ inch in diameter. Ensure screens and door sweeps are in place on windows and doors and in good condition. Remove any water accumulation and fix leaks. Maintain and trim lawn, trees, bushes, and shrubs so that they are at least 2 feet away from the side of the building.
Choose mechanical pest management methods before sprays. Use traps and baits first, along with less-toxic dusts such as boric acid, and avoid chemical sprays, fogs, and bombs. Put the bait or dust close to the pest’s hiding place and determine the most effective treatment time to use the bait, based on pest biology, weather, resident schedule, and other variables.
Use biological controls (introducing or enhancing pests’ natural enemies). This is a common method of controlling outdoor pests in gardens and landscape areas. It involves introducing, increasing, or conserving other living organisms that serve as natural predators, parasites, or pathogenic microorganisms that kill the pests, lay eggs on or in pests to use as food for larvae, cause diseases, affect their reproductive or other functions, use the pests’ food, or otherwise make it less likely for pests to thrive at your site. These measures include “good” bugs, such as spiders, ladybugs, caterpillars, and some nematodes, or even planting certain flowers to attract beneficial insects or repel the “bad” ones.
Use pesticides only when necessary. Though IPM seeks to reduce and ultimately eliminate use of toxic chemicals, occasional pest problems may still require use of pesticides. Apply pesticides as a last resort measure only when the extent and risk of pest infestation to residents outweighs the risk of harm from pesticide use. Choose products and methods that are effective enough to meet your needs while posing the least risk of harm to human health and the environment. Do not overuse pesticides or use them on a regular calendar schedule. Over time, pests may become tolerant of or learn how to avoid pesticides and the harm to human, animal, and environmental health usually outweighs the benefit.
When your minimum action thresholds indicate that pesticide use is appropriate, follow these guidelines:
• Choose the appropriate and least harmful pesticide for the targeted pest
• Read the label and follow instructions for use, storage, and disposal, and keep all SDS on file
• Notify residents as required by state or local law
• Minimize the extent of application to limit risk of exposure and harm
• Follow up to make sure the treatment worked
Here are three basic types of pesticides in ascending order of risk:
1. Baits and “botanicals.” These are generally the safest types of pesticides. Baits come in several forms, including gel, granular, and liquid and are the most effective method for eliminating cockroaches, and are helpful in controlling ants, rodents, and other pests. “Botanical” or organic products are safer but are often exempt from EPA efficacy testing, so research their effectiveness before you use them.
2. Insecticidal dusts. Diatomaceous earth (DE) and boric acid are the least toxic types of dusts. Dusts last a long time and work to create a coating or barrier between the pests and the targeted area you want to protect. Use these as necessary when baits and botanicals don’t work or aren’t appropriate.
3. Sprays, foggers, and bombs. As a rule, do not use any pesticide sprays, foggers, bombs, except when absolutely necessary. Fogs and sprays don’t reach the majority of pests hiding deep in walls and floors and usually don’t kill eggs in pregnant pests. They also can render baits ineffective so that the target pest will not take the bait. Discourage residents from storing or using pesticides in their units without your permission. Avoid chemical flushing. Do not use pesticides containing organophosphate or chlorinated hydrocarbon pesticides. These pesticides repel or kill pests on contact and can be very dangerous.
Step #7: Educate residents on proper unit sanitation and enforce lease provisions. Include in your IPM program outreach and educational materials on how residents can help prevent and control pests with proper unit housekeeping and sanitation. Instruct residents to promptly report any pests and to get management permission before using any pesticides in their units. Tell them to promptly report maintenance and plumbing problems, such as water leaks, mold, large cracks and holes, or other ways for pests to enter the unit. Instruct residents and to keep common areas clean of rubbish, food, and beverages, and their units free of trash, clutter, dust, sitting water, food, and crumbs. Offer them the following housekeeping guidelines:
• Trash, compost, and garbage: The trash bag should never overflow in the unit. Cans, jars, and bottles must be rinsed if they are to be stored. Cardboard and paper are not to be stored on property for extended periods.
• Refrigerator: Must be clean, including the space behind, floor underneath, and surface on top of the refrigerator.
• Sink: Dirty dishes must be washed and put away nightly.
• Windows: Screens should be in place and free from holes.
• Cabinets: Put food in tightly sealed containers. Throw out expired food.
• Tub and shower: Should be clean and free of any mildew and mold.
We’ve included these instructions in the Model IPM Policy.
Give instructions some bite. Almost all HUD-approved standard leases have a section requiring residents to maintain their units in a safe and sanitary manner and to immediately report maintenance problems like leaks and pests. A violation of this requirement is a breach of the lease and can be grounds for eviction if it goes uncorrected. If your staff discovers an unsafe or unsanitary condition or unreported pest problem in a resident’s unit, send the resident a letter informing her that she’s keeping her unit in an unsafe or unsanitary manner or failing to properly notify management of problems in her unit. Remind her that the lease violations that affect residents’ health or safety or that interfere with proper management can be grounds for terminating the lease. And warn her that if she fails to correct the conditions by a specified date or fails to report maintenance problems in the future, she may be evicted. Be sure to follow up by sending maintenance staff to ensure unsanitary conditions are fixed or to make any necessary repair, and conduct periodic inspections of your unit to check for additional unsanitary conditions or unreported maintenance problems.
Step #8: Evaluate effectiveness. Follow up with inspections and interviews with residents to find out if your control efforts worked. Once you have fixed the problems that attracted the pests to begin with and the infestation is gone, you can return to the regular inspection and monitoring schedule.
Bedbugs—A Special Problem
Essentially a nonexistent issue since they were eradicated after World War II, bedbugs are back—in a big way. As a result, as of Sept. 13, 2010, inspectors in the Uniform Physical Conditions Standards (UPCS) program are required to report the presence of bedbugs at any site they inspect. And as the number of bedbug infestations rise throughout the country, HUD is in the process of revising rules for the unit inspection process as well as developing the tools to identify, treat, and monitor the effectiveness of bedbug treatments. Identifying, reporting, treating, and monitoring pest infestations are all critical components of IPM and are effective in addressing the bedbug problem. Ultimately, HUD encourages owners and managers to have an IPM plan in place for controlling the spread of the infestation, inspection by a pest professional, and treatment, including:
• Inspecting infested areas, plus surrounding living spaces
• Advising residents to check for bedbugs on luggage and clothes when returning home from a trip and look for bedbugs or signs of infestation on secondhand items before bringing items home
• Correctly identifying the pest
• Keeping records—including dates when, and locations where, pests are found
• Cleaning all items within a bedbug-infested living area
• Reducing clutter where bedbugs can hide
• Eliminating bedbug habitats
• Physically removing bedbugs through cleaning
• Using pesticides carefully according to the label directions
• Following up on inspections and possible treatments.
The most critical safeguard against a bedbug infestation is education. Owners and managers should educate both staff and residents on how to identify bedbugs, basic prevention techniques, and the protocol for notifying management when they suspect the presence of bedbugs. Don’t charge a resident to cover the cost of bedbug treatment. Costs should be covered by the owner from project funds authorized by HUD.
The presence of bedbugs is not associated with poor housekeeping or lack of cleanliness—they can emerge anywhere. Therefore, residents who suspect that they have a bedbug infestation should not be made to feel embarrassed or ashamed or reluctant to report them to management. Also, bedbugs may often go undetected and unreported because they are active at night, and residents may not be aware of their presence. Owners may wish to hold workshops for residents to learn to identify bedbugs, to create unfriendly environments for pests, and to report suspicions of bedbugs as soon as possible. You can also send residents a notice like the one on the following page adapted from the HUD Healthy Home Guide to inform them about how to prevent bedbugs and deal with a bedbug infestation.
Boston Public Health Commission Integrated Pest Management (IPM), A Guide for Managers and Owners of Affordable Housing: http://www.bphc.org/whatwedo/healthy-homes-environment/healthy-prest-free-housing/Pages/IPM-and-Policy.aspx
Environmental Protection Agency (EPA):
General IPM information:
For seven pest control tips for housing managers: http://www.epa.gov/safepestcontrol/pest-control-resources-housing-managers
EPA Staff contacts: http://www.epa.gov/pesticide-contacts
Massachusetts Department Agriculture Resources — Building Managers and Landlords: http://www.mass.gov/agr/pesticides/docs/CIB_Building_Managers.pdf
National Center for Healthy Housing, Bed Bugs: “What’s Working for Bed Bug Control in Multi-family Housing”: http://www.nchh.org/Portals/0/Contents/bedbug_report.pdf
National Center for Healthy Housing, Integrated Pest Management: A Guide for Affordable Housing: http://www.nchh.org/Portals/0/Contents/IPM-Guide-for-Affordable-Housing.pdf
National Center for Healthy Housing Training: http://healthyhousingsolutions.com/hhtc/
National Pesticide Information Center: http://www.npic.orst.edu/
Pest, bedbugs and other insect information, University of Kentucky Insect Advice: http://www.ca.uky.edu/entomology/entfacts/ef636.asp
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This article was adapted from Section 3.4 of Sustainable Affordable Housing Management: A Money-Saving Guide to Keeping Your Site Green, Healthy & Energy Efficient, by Carolyn E. Zezima, Esq. Zezima is the president of NYC Foodscape (http://www.nycfoodscape.com/) and a consultant with a track record of grass-rooting and managing organizations in the nonprofit sector. She has worked with food and farming enterprises and food policy organizations in Chicago and New York to promote healthy sustainable food systems, urban agriculture, and regional farming, including founding The Talking Farm, “The Farm with Something to Say,” an urban farming and educational enterprise in Evanston, Ill. She can be reached at email@example.com or (847) 507-1785.