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It’s important to think of the problems that arise in bed bug control — as it is actually practiced every day in this city — honestly, without idealism and without any unwarranted do this, do that, success! affect.

Not everything is as simple as the dog decisions above. The thornier problems (what can you do when HPD doesn’t write a violation because there were no bed bugs on your mattress?) yield pretty complex decision paths: all the choices are grim.

All of which is to say, a follow-up on this soon.

In the meantime, some links.

–This article in The Villager, “NYCHA officials say 6 percent of units hit by bedbugs,” about the two-evening bed bug forum that took place on January 18 and 19 (briefly noted) is important among other reasons because it reveals an essential problem with our current conception of bed bug education:

The councilmember [Council Member Rosie Mendez] said that while she was “very happy” with the city’s participation in both forums, it was unfortunate there wasn’t a greater showing by residents.

Emphasis added. I’ll try to gather my thoughts about this subject in another post.

–The Associated Press reported that the NYC Council sent a letter to EPA and HUD asking for assistance. The internet is not obliging with the text of this letter; do you have better luck?

–Journalist Theresa Braine has been writing an excellent series about her personal bed bug experience at BrickUnderground. I’m sorry I have missed it until now. It’s a great personal story, entertainingly delivered and packed with instructive episodes. This is the first installment.

–NPMA released bed bug management best practices. The presentation of these guidelines may be a bit confusing. Go directly to this link for the full guidelines in the form of an outline.

–And finally for a tiny bit of fun on an icy day, the tale of a bed bug gadget inventor, via. (No, no clue about how this could possibly work. My bet would be no, but really, what do I know? Made a cursory search for relevant research; here’s a 2005 technical publication if you are really interested. Think of the “debates” on verifying electronic alerts, à la canine scent detection!)

I don’t see anyone live-blogging the summit this year — here is M&M’s Natalie Raben’s take on the first day and a release about ESA participants at the summit: ESA members take part in National Bed Bug Summit.

Organized by Sam Bryks, speakers include Allison Taisey, Changlu Wang, Clive Boase, and local experts in housing, pest management and law.

Also check out this primer on bed bug management (PDF) on the IPM Consultancy (Sam Bryks’) site.

The workshop sounds very useful. Especially promising is something that is sometimes missing from this type of program, the participation of tenant advocates and housing law experts. Speakers here include Harry Fine, a former adjudicator with the Ontario Rental Tribunal, and Kenneth Hale, Director of Advocacy and Legal Services, Advocacy Centre for Tenants, Ontario.

I look forward to hearing about it.

Previous interview with Sam Bryks here.

As a follow up to the letter to building management discussed recently:

Here is a bed bug information sheet to leave with neighbors (PDF) as you go knocking on doors and inviting them to a tenants meeting to hash out the bed bug situation in your building.

The sheet says “bed bugs have been spreading in our building” and is meant to help you figure out what to say in your own building. Free to use as is or adapt to your (non-commercial) needs.

When you knock on doors, be ready to write down names and phone numbers and email addresses as well as make notes about what is discussed. This is a simple thing but easy to forget. (The building discussed in the previous post used a simple ruled list: apartment number, tenant name, email address, cell phone, and one-letter abbreviations to be circled as appropriate for willingness to join tenants association, attend the tenants meeting, and of course bed bugs: A – M – B.) It can be a very short conversation if you get contact information to follow-up.

If this is useful, other possible versions of this flyer to follow, as well as what to be sure to discuss in tenant meetings and some of the questions that may be asked.

Remember that you can download many advanced guides and resources, call 311 to order copies of the health department’s bed bug guide (the English-language version; other languages available only as downloads), and ask HPD to come speak to your tenants association meeting.

Last night the Museum of the City of New York hosted a bed bug program. I’m very grateful to the museum and especially its director of public programs, Ryan J. Carey, for thinking of this problem and asking us to participate in discussing it. But unlike last year’s lecture at the NY Entomological Society, I don’t think I can offer a good recap (participation not being a good vantage point for observation). What I remember distinctly is that Lou talked about the hunger folds of bed bugs (conveniently expandable for taking in lots of blood), and that a certain gentleman from London said something terrible: that “whoever brought them in” should be responsible for eradicating them.

For the record, the landlord is legally responsible in New York City for the eradication of bed bugs. One can go on at length about all the ways that landlords need help in fulfilling this responsibility, and how there is no hope of success when the tenant is not cooperative (or when the pest management professional is not diligent) but, as far as the law, it’s difficult to conceive of the wholesale disaster that bed bugs would be in this city if it were otherwise.

Update: I just recalled that there were some questions in the audience about basic resources — a collection here, but some basic ones specific to the city:

• a NYC Health Department guide on how to select a pest control company (PDF) — see also
• also from DOHMH, a basic bed bug guide, in English and 6 other languages
• and, because the above guide does not include photographs, Lou’s photographs of bed bugs

Update 2: I should say that I like and respect David a lot (exhibit A, B, C, and D), but we have our disagreements like to argue from time to time. He never forgets to remind me that we only became friends after a strong initial disagreement, about something or other long forgotten.

And here’s commentary about the evening from BrickUnderground. Please note, however, that I am not aware of any new law requiring inspection of adjoining apartments. There is only a stated intention from the Health Department, announced in the summer when the bed bug advisory report was released, to hold landlords (and tenants) to “enhanced expectations” that would specifically involve additional inspections. There have been no further details about the development of such a policy. But we should all be on the lookout for news on that front (and dare we hope, actually press the city about it), as it is very promising.

Update 3: Here is another writeup from Woman Around Town.

I am not personally as excited about a second national bed bug summit as I was about the first one in 2009 (when giddy would have been an appropriate description), but obviously (or perhaps not so obviously) I think a meeting like this can only be good, and do some good. Sharon Heath is again presenting for the NYC Department of Health and again I want to mention how great we think she is. The education and communication section seems promising, among others.

There is definitely a need to move swiftly beyond strategizing into action, but that is, you know, quite the commonplace thought. Doesn’t make it less true.

The way the photographs are composed gives you a real sense of size and the features involved. Some are especially graphic, so skip if you would.

About the website, I like the easy navigation, links to more developed Toronto Public Health resources, to local public health units, the tenant information sheet and, above all, the speedy début. By contrast, the “identify” section needs some work, or maybe a lot of work, and photographs.

This seems like such swift action. I am impressed. It should not be hard, or not too hard, to set up an educational website. But, as we know, what looks simple and straightforward is not really, or everyone would have done it already. On the NYC situation what needs to be said? I hope we’ll have a bed bug portal here, eventually, and I hope it measures up?

The Environmental Control Board, an administrative tribunal, will handle hearings for pest violations. I came across this proposed rule to set fines (PDF). This is interesting and a bit puzzling in places.

This is from the statement of purpose:

To better protect the public health, ECB is adding penalties for violations under Article 151. The separate charges will help inform the public of what needs to be done to prevent pests and other rodents. These violations include:

• Failure to comply with DOHMH orders
• Maintaining or failing to correct nuisances
• Violations relating to rodents, bed bugs and other pests
• Maintaining conditions conducive to pest harborage
• Failure to develop and maintain pest management plans

Here are some of the proposed fines:

NYC Health Code 151.02(a)
Failure to properly and thoroughly eliminate conditions conducive to pests and to the presence of pests other than rodents or mosquitoes.
Penalty: $300
Default: $600

NYC Health Code 151.02(c)
Failure to comply with Department or Commissioner’s Order; pest management plan not complied with; no inspections and/or exterminator visits documented.
Penalty: $1000
Default: $2000

NYC Health Code 151.02(c)
Failure to comply with Department or Commissioner’s Order; pest management plan not complied with; no notice to tenants posted or provided.
Penalty: $1000
Default: $2000

NYC Health Code 151.02(c)
Failure to comply with Department or Commissioner’s Order; pest management plan not complied with; pests and/or conditions conducive to pests, access and harborage not eliminated.
Penalty: $2000
Default: $2000

NYC Health Code 151.02(e)
Using pesticides alone in the management of pest infestations.
Penalty: $300
Default: $600

I am told, by someone knowledgeable about the new policy, that the proposed fines are approved, though the final rule is not available so it’s not clear if any changes were made after comments were received. And, yes, this will be used as a potential tool to correct bed bug violations.

This confirms two things: one, that the New York City Department of Health, however reluctantly and sparingly perhaps, intends to use Article 151 for bed bugs, and two, that there may be something after all (however tenuous for the moment) to their expressed intention, announced last summer, to hold property owners to “enhanced expectations.”

The Health Department hopes to increase efficiency with Environmental Control Board hearings, which is good, but when I asked about the proposed fine for “using pesticides alone” the response is that they will not fine people for using pesticides alone but that the goal is to have a comprehensive approach for managing pests and reduce and eliminate the use of pesticides when possible. And yet there it is, a proposed fine for using pesticides alone! Perhaps it has been deleted, or else it is a tool to be held in reserve. I am frankly amazed by it.

Anything can be done badly, but we have strongly advocated the use of Article 151. I hope it makes a difference, where and when it is used.

Obviously, in order for HPD and the Health Department to identify a property as a candidate for the supervisory tools of Article 151, they have to become aware of its problems. But I would not expect the Health Department to become involved with bed bug-distressed buildings except in severe cases, due to resource constraints. To underscore, it seems likely that a building would not come under the elevated scrutiny of the Health Department via the authority of the NYC Health Code unless and until a significant number of residents report bed bugs in that building. In what numbers? No thresholds of number of complaints for a property to be so identified have been announced, and so this tool remains something apparently to be used at their discretion, but the frequent problem of residents who are reluctant to file formal complaints — something that is often a significant obstacle for other tenants in the building — seems an obvious challenge here.

What role ECB hearings could have in alleviating the pressures on housing court then seems a premature question.

This could be a step forward nonetheless.