INTEGRATED PEST MANAGEMENT POLICY

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HOUSING AUTHORITY OF THE CITY OF EL PASO, TEXAS INTEGRATED PEST MANAGEMENT POLICY PROPERTY MANAGEMENT OPERATIONS September 2015

INTEGRATED PEST MANAGEMENT (IPM) POLICY ------------------------------------------------------------------------------------------------------------ --------- BACKGROUND Structural and landscape pests, as well as the pesticides used to control them, can pose significant hazards to people, property and the environment. It is known that children have a relatively higher risk from exposure to pesticides than do adults exposed at the same levels. Proportionally, they have a higher respiratory rate and eat/drink more than adults. In addition, children have a natural tendency to put objects in their mouth, and spend more time on or near the ground than adults. A child s neurological system is still developing and is more susceptible to chemicals in their environment compared to adults. With these cultural and biological differences, children have a higher potential for pesticide poisoning than adults. The Housing Authority of the City of El Paso, Texas (HACEP) is implementing this IPM program to effectively manage pests, while reducing the chance of accidental exposure of pesticides to children and staff. Over time, this proactive approach will control pests more effectively than just using pesticides alone. POLICY It is the policy of the Housing Authority of the City of El Paso, Texas to utilize Integrated Pest Management (IPM) procedures for control of structural and landscape pests. Furthermore, it is the goal of HACEP to manage pest damage by the most economical means, and with the least possible hazard to people, property, and the environment. To undertake IPM, property managers, resident relation technicians, maintenance supervisors, and maintenance technicians, and all other staff having direct contact with the day-to-day operations of the property will be committed to ongoing or continuous monitoring and record keeping. The Community Services staff, in collaboration with HACEP, and the Jurisdiction Wide Resident Council (JWRC) Leadership, will educate residents and staff to understand their role in managing pests and reporting and increasing communication between residents and property managers. As defined by the Structural Pest Control Act (225 ILCS 235/3.24), IPM is a pest management system that includes the following elements, whenever possible: Communicating policies and procedures to all building occupants, administrative staff, contractors and maintenance personnel; Identifying pests and their natural enemies; Establishing an ongoing monitoring and record keeping system for regular sampling and assessment of pest and natural enemy populations;

Determining the pest population levels that can be tolerated based on aesthetic, economic and health concerns, and setting action thresholds where pest populations or environmental conditions warrant remedial action; Preventing pest problems through improved sanitation, management of waste, addition of physical barriers, and the modification of habitats that attract or harbor pests; Relying to the greatest extent possible on nontoxic, biological, cultural or mechanical pest management methods, or on the use of natural control agents; When necessary, using chemical pesticides, with preference for products that are the least harmful to human health and the environment; Record keeping and reporting of pest populations, surveillance techniques and remedial actions taken; and Lease enforcement regarding resident responsibilities such as housekeeping, sanitation and trash removal and storage. Fundamental Areas of Education Communicating the IPM policies and procedures Identifying pests and immediately reporting their presence Identifying and preventing the environmental conditions that lead to pests Observation, recordkeeping and reporting techniques Education sessions will be provided at a minimum twice in each of the 60 communities. Therefore, the education sessions will be provided in 18 month cycles. Priority and special attention will be given to areas/communities which been identified as being at higher risk for pest infestations. Pests Pests include arthropods (insects, spiders, mites, ticks and related pests), wood-infesting organisms such as fungi, rats, mice, nuisance birds and any other undesirable organisms in, on or under structures, excluding bacteria and other microorganisms on or in humans or other living animals. IPM Coordinator The Director of Property Management, or designee, shall be the IPM Coordinator, who shall have primary responsibility for ensuring that this IPM policy is carried out. The Director of Property Management shall designate an employee at each property to serve as the IPM coordinator for the site. Roles and Responsibilities Specific roles and responsibilities for the development, implementation and maintenance of the IPM program will be established, communicated and enforced by the Director of Property Management to ensure the proper implementation of the IPM program.

Pest Management Objectives The objectives of the IPM program are: Manage pests found on properties to prevent interference with a safe, sanitary, and healthy environment; Prevent injury to staff, residents and the public; Preserve the integrity of buildings or structures; Prevent pests from spreading in the community or to plant and animal populations beyond the site; and Enhance the quality of life for staff, residents and others. POSTING AND NOTIFICATION OF PESTICIDE APPLICATIONS The IPM coordinator at each site will be responsible for notifying residents of planned and emergency applications of pesticides in buildings and grounds. Notifications will include: 1. Posting a pest control information sign in an appropriate area including contact information for additional details with the date, time and location of the application and the product applied. 2. Providing this information to all individuals living and working in the building(s). 3. Providing this information to all residents who have requested notification of individual applications of pesticides. RECORD KEEPING Designated IPM coordinators will maintain records of all Service Provider visits and pest control treatments for at least three (3) years. Information regarding pest management activities will be made available to the public, upon appropriate request, at the HACEP administrative offices. All residents will be informed of their option to receive notification of all pesticide applications at admission and once annually. Requests for notification of pesticide applications may be made to the property manager/ipm coordinator. GENERAL IPM STRATEGIES Pest Management Strategies may include education, exclusion, sanitation, maintenance, biological and mechanical controls, and pre-approved, site-appropriate pesticides. An Integrated Pest Management decision shall consist of the following steps: 1. Identify pest species. 2. Estimate pest populations and compare to established action thresholds. 3. Select the appropriate management tactics based on current on-site information. 4. Assess effectiveness of pest management. 5. Keep appropriate records.

Decisions concerning whether or not pesticides should be applied in a given situation will be based on a review of all available options. Efforts will be made to avoid the use of pesticides by adequate pest proofing of facilities and good sanitation practices. ADDRESSING INFESTATIONS Property Managers will respond with urgency to tenant reports of infestations. Appropriate action will be taken within a reasonable time period, in accordance with procedures for IPM established by HACEP. Tenants will be advised that pest inspections and, if necessary, treatment, may take time to schedule particularly for recently resurgent pest such as bed bugs. Property Managers will assist the IPM Coordinator, Community Services staff, and the JWRC Leadership, in maintaining the IPM program and in developing and delivering materials and programs for staff and residents to educate them about the importance of good sanitation and pest control. Service providers and other IPM experts may be consulted to provide input, including suggesting pest-proofing measures. FOR FURTHER INFORMATION If there are questions regarding this policy, contact the Director of Property Management, or his/her designee, or HACEP s Risk Control Department.