The guidance is voluntary.  However, HUD emphasizes its importance when it states that "pests may adversely impact health and contribute to worsening some diseases, such as allergies and asthma. Therefore, pest control methods are targeted to protecting the health of residents and staff. Even though applying  pesticides may be effective in eliminating pest populations, many of these chemicals may be associated with health and/or environmental risks, and their use should be minimized if alternative methods exist."

HUD observes that "IPM frequently has proven to be more effective in reducing pest populations than depending solely on broadcasting pesticides. Therefore, IPM offers the potential of ensuring efficacy of pest elimination while protecting the health of residents and staff."

HUD goes on to state that "most of the effective methods of pest elimination, including ongoing repairs, erection of barriers, and monitoring, will extend the useful life of the property and, thereby, generate significant savings that offset costs of the pest control operations. Many of these nonapplication methods, including structural maintenance, especially inspecting for and repairing leaking pipes and cracks in roofs, walls, and windows are effective in preventing moisture intrusion and accumulation. Additionally, IPM-conscious HAs assess the need to install physical barriers to both pest entry and pest movement within every structure."

HUD defines the goal of IPM as managing "pest damage by the most economical means, and with the least possible hazard to people, property, and the environment. To undertake IPM, property managers should be committed to ongoing or continuous monitoring and record keeping, education of residents and staff, and

good communication between residents and building managers. IPM methods involve restricted access to food/water, sanitation and waste management, mechanical control, natural control agents, physical barriers, structural maintenance, and, where necessary, conservative application of pesticides."

HUD identifies ten elements of an effective IPM program:

1. Communicate Policies: Communicate property manager’s (PMs) Integrated Pest Management (IPM) policies and procedures to:

   ▪   All building occupants;

   ▪   Administrative staff;

   ▪   Contractors; and

   ▪   Maintenance personnel.

2. Identify Problems:  Identify pests and environmental conditions that limit the spread of pests.

3. Monitor and Track:  Establish an ongoing monitoring and record keeping system for:

   ▪   Regular sampling and assessment of pests; Surveillance techniques;

   ▪   Remedial actions taken; and

   ▪   Assessment of program effectiveness.

4. Set Thresholds for Action:  Determine, with involvement of residents:

   ▪   Pest population levels – by species – that will be tolerated

   ▪   Thresholds at which pest populations warrant action.

5. Improve Non-Pesticide Methods: Improve:

   ▪   Mechanical pest management methods;

   ▪   Sanitation;

   ▪   Waste management; and

   ▪   Natural control agents,

   that have been carefully selected as appropriate in light of allergies or cultural preferences of staff or residents.

6. Prevent Pest Entry and Movement:

   ▪   Monitor and maintain structures and grounds including:

     o     Sealing cracks

     o     Eliminating moisture intrusion and accumulation

   ▪   Add physical barriers to pest entry and movement.

7. Educate Residents and Update Leases

   ▪   Develop an outreach/educational program.

   ▪   Ensure that leases reflect residents’ responsibilities for:

     o    Proper housekeeping; and

     o    Reporting presence of pests, leaks, and mold.

8. Enforce Lease:  Enforce lease provisions regarding resident responsibilities such as:

   ▪   Housekeeping;

   ▪   Sanitation; and

   ▪   Trash removal and storage.

9. Use Pesticides Only When Necessary:  Use pesticides only when necessary, with preference for products that, while producing the desired level of effectiveness, pose the least harm to human health and the environment, and, as appropriate, notifying property manager before application.

10. Post Signs:  Provide and post ‘Pesticide Use Notification’ signs or other warnings.