NCEHS Calls for More Changes to Revised HUD IPM Guidance.

NCEHS Calls for More Changes to Revised HUD IPM Guidance


On April 26, 2011, HUD issued revised guidance on Integrated Pest Management (IPM) for Public and Indian Housing (PIH). PIH-2011-22 which supersedes PIH 2009-15 “promotes and encourages” IPM, but IPM is still at the discretion of the housing authority. While the recent guidance does include reference to people with chemical sensitivities as recommended by Mary Lamielle, the statement that “Some residents may suffer from Multiple Chemical Sensitivity or other Environmental Illnesses” (4g), stops short of providing sufficient guidance and protections necessary for people disabled by pesticide exposures. As a point of contrast, “IPM in Multifamily Housing” training (www.stoppests.org) funded in part by HUD specifically discusses the health threat and access barrier posed by conventional pesticides. (attached Chapter 3, Slide 18)

When the revised IPM guidance was discussed at the June 29, 2011 HUD Disability Task Force meeting, Mary asked why the PIH did not specifically prohibit the use of lawn care pesticides. In follow-up correspondence she called for immediate promulgation of a policy that would prohibit lawn care and landscaping pesticides. “The PIH should specifically prohibit the use of lawn care pesticides. This should be promulgated immediately. These practices are frivolous, a waste of tax dollars, and a health threat to vulnerable populations including children and the elderly, and a health threat and an access barrier for people with chemical sensitivities. …There is substantial literature available that provides guidance on maintaining lawns and grounds without the use of toxic pesticides.”

The PIH also indicates that “residents should notify PHA [public housing authority] management before pesticides are applied.” (4.k) In correspondence with HUD Mary stated “This is a very dangerous practice in public housing and there have been many instances of the use or misuse of pesticides to the detriment of those who use them and other occupants. Additionally this practice is extremely hazardous for vulnerable populations including those with chemical sensitivities. Residents should not be permitted or encouraged to use conventional pesticides.”

Mary additionally recommended that the Reference Materials include a list of low impact or least toxic pesticides similar to the list issued by New Jersey for the state’s School IPM legislation.

The PIH recommends that PHA’s who use outside pest control contractors use companies that are trained and certified to provide IPM services through Green Shield or Green Pro. It also recommends that the PHA consider training for maintenance, staff, residents, Resident Councils as well as PHA administrative staff. We’d like to hear from you if your housing authority has used pest control contractors certified by Green Shield or Green Pro.

As a special note to those in multifamily housing or housing covered by HUD PIH guidance, IPM in Multifamily Housing training may be available to educate your community in IPM practices. It is protective of vulnerable populations including those with chemical sensitivities. The training that accompanies the slides addresses the health and access barrier posed by pesticides. “Conventional pesticides should not be used in the units occupied by people with chemical sensitivities, or in adjacent or neighboring units, or in common areas such as the halls, lobbies, laundry rooms, elevators, or stairs, or along paths of travel for disability access.” (attached Chapter 3, Slide 18)

If you live in multifamily housing and want your community to receive training, or if your community has received this training, we’d like to hear from you. Contact NCEHS at (856)429-5358 or marylamielle@ncehs.org.

Mary Lamielle, Executive Director, National Center for Environmental Health Strategies, 1100 Rural Avenue. Voorhees , New Jersey 08043 (856)429-5358; (856)816-8820; marylamielle@ncehs.org