Two Keys to Battling Bed Bugs: Prevention and Proving Due Diligence

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NATIONAL REPORT—In the event of a bed bug incident, proving that a hotel has exercised due diligence is all about documentation. For a documentation system to be successful it must be comprehensive, but also easy to use. If a documentation system requires excessive time and effort, hotel staff will likely omit entries or simply not use it at all.

The starting point in creating a due diligence documentation system is employee training. The training should be geared toward housekeeping and maintenance staff and should be conducted by a competent pest management professional (PMP).  Internet research and internal education by site employees are not adequate. Only a trained professional can educate staff on such issues as pest identification, inspection techniques and coordination between hotel staff and the extermination professional.

Documentation systems can be as simple as a notebook with flip charts. The first flip chart should be a site employee training log. This log, as with all logs, must be on a single page and include the date of the training; location of the training; education topics; sponsor or trainer name and contact information; and signatures of attendees.

Once the hotel employees have undergone training, the next step in the due diligence documentation process is to create a log to confirm hotel staff—housekeeping and maintenance—are conducting routine inspections for bed bugs. The manner in which these inspections take place will be determined by the PMP. The room inspections should be a part of housekeeping daily duties when cleaning or preparing a room. Additionally, common area inspections should be routine, but frequency should be determined by the contracted PMP. Inspection flip charts should include such entries as date of inspection; time of inspection; room number or location of common area; name of staff; signature of staff; positive or negative findings; and, the date and time a positive report is made to the PMP.

Once bed bugs are discovered by hotel staff, it is essential that the inspection is followed by an immediate response from the PMP. PMPs will need to conduct their own independent inspections, and these inspections should be documented in both the PMP’s records and in the hotel’s documentation system. The hotel’s documentation flip chart should also include date and time of PMP inspection; room number or location of common area; name of technician; signature of technician; positive or negative findings; name of site employee involved; and signature of site employee.

Where there is a positive finding for bed bugs, a treatment or remediation will be required to be performed in a timely fashion. The PMP will, by law, be required to have their own documentation of all chemicals applied. However, the hotel should also document the treatment or remediation to demonstrate both a timely response and the adequacy of the response. The treatment flip chart should include; date of treatment; time of treatment; name of technician; signature of technician; treatment type; date for the next inspection; site employee involved; and site employee’s signature.

Hotels should adopt the mindset that the report of a bed bug is a gift rather than a curse. When a guest or staff member reports a bed bug, the hotel is best positioned to deal with the issue. While staff should be conducting routine inspections of rooms and common areas, the reality is that many reports of bed bugs will come from guests. It is therefore essential that as part of a due diligence protocol, staff take reports or complaints of bed bugs seriously and develop a protocol for handling guest complaints. At a minimum, a flip chart should be developed that logs in date of complaint; time of complaint; room number or common area; guest’s name; employee recording the complaint; date and time the PMP contacted; and employee’s signature.

Employee education and developing a documentation system that is both comprehensive and easy to employ is the best way to prove a hotel has undergone sufficient due diligence when it comes to bed bugs. But, having a solid, field-proven bed bug prevention program in place can stop a bed bug incident from turning into a full-blown infestation. Such a program can save a great deal of money, preserve brand reputation and reduce legal exposure. A 2017 research report entitled “Behind the Cost of Bed Bugs: Hospitality Industry Report” indicated that hotels spend on average $6,383 per bed bug incident. This cost includes the expense for pest control remediation, the loss of room revenue during the inspection and treatment process, guest compensation and discarding of soft goods. The report continues that over a five-year period, bed bug-related costs to hoteliers could catapult to more than $160,000.

Up until recently, the additional financial impact of bed bugs on hotel brand reputation was considered an unmeasurable metric. However, a University of Kentucky study found that just one negative report of bed bugs on a travelers’ online review site can cost a 300-room hotel catering to business travelers $274,000 per month in revenue. When looking at a similarly sized hotel catering to vacation travelers, the costs approached $166,000 per month.

Consider how much you can save by implementing a prevention strategy in your hotel versus reacting to the problem with this hotel savings calculator.

Jeffrey M. Lipman, Attorney-At-Law and Polk County Magistrate Judge.

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