Customer Service The Tough Issues – Bedbugs in Public Transit

1. Customer Service The Tough Issues – Bedbugs in Public Transit Presented by Julie Schafer, RLS and Associates September 30,2015

2. What are bed bugs? • Wingless insects that feed on blood • Three stages: egg, juvenile, adult • Small but visible at all stages • Usually found in beds • Can be found anywhere in a room • Can not fly or jump • Can run fast and climb

4. Bed bugs don’t play favorites • Anyone can get bed bugs • In most cases, people carry bed bugs into their homes unknowingly – in infested luggage, furniture, bedding, or clothing. Bed bugs may also travel between apartments through small crevices and cracks in walls and floors

5. Most Common Public Locations 1. Hotels/motels: 75 percent2. College dorms: 47 percent3. Nursing homes: 46 percent4. Schools and day care centers: 41 percent5. Office buildings: 36 percent6. Hospitals: 33 percent7. Transportation (train/bus/taxi): 21 percent8. Retail stores: 15 percent9. Libraries: 12 percent10. Movie theaters: 10 percent11. Laundromats: 9 percent12. Restaurants: 7 percent

6. Resources for Information • http://www2.epa.gov/bedbugs/bed-bug-information-clearinghouse • http://extension.entm.purdue.edu/publichealth/insects/bedbug.html - Tim Gibb • http://www2.ca.uky.edu/entomology/entfacts/ef636.asp • https://secure.in.gov/isdh/24955.htm • County Health Department

10. What are the health risks? • Bites - must bite to feed on blood • Reactions to bites vary widely • Most common symptom is itchy welts • Scratching welts may cause infection • Never shown to pass disease to humans • Some experience allergic reactions or severe skin reactions

12. General Travel Protection Tips • Check seat area before sitting • Carry as few extra items with you as possible • Keep personal items in lap • Inspect bags or personal items before taking inside home • Check clothing before entering home • Put belongings in clear plastic bags

13. Protection Tips: Drivers • Use separate clothes and shoes for work • Shake clothes outside before entering car • Change clothes at work • Seal work clothes in clear plastic bag for laundering • Launder work clothes with hot water and high heat dryer • Inspect own living and work space regularly

14. Protection Tips: In the Office • Limit personal belongings permitted in the office • Limit plush furniture • Inspect office regularly • Hire pest control at any sign of bed bugs

15. Protection Tips: On the Vehicle • Teach drivers how to complete bed bug inspection during pre and post trip inspections • Maintain 70% isopropyl alcohol on the vehicle to kill live bugs • Vacuum vehicle frequently • Treat vehicles periodically (monthly) if possible • Steam clean • Pesticides

16. Protection Tips: On the Vehicle • Remove vehicle from service immediately and treat if evidence found

17. Basic Inspection Tips • Check for small stains on seats and walls • Look for shed skins, amber in color • Check crevices • Check screw and nail holes • Check underside of seat • Check seatbelts

19. Bedbugs on Public Transit • New York Subway – 21 bedbug sightings in August with 16 trains involved. • Treated with pesticide spray • Detroit/SMART – ? buses involved • Treated with pesticide spray periodically • Phoenix Metro - ? buses involved • Treated with pesticide spray periodically • Rabbit Transit – York PA, 3 of 87 buses involved • Glue traps on buses • Heat treatments on a regular basis

20. Impact on Public Health • Although bed bugs are not known to transmit disease, they are a pest of significant public health importance. Bed bugs fit into a category of blood-sucking ectoparasites (external parasites) similar to head lice (Pediculushumanuscapitis). Bed bugs, like head lice, feed on the blood of humans but are not believed to transmit disease. Source: EPA

21. Impact on Public Health • Bed bugs are not known to ‘transmit’ disease-causing pathogens through their own feeding but it has been documented that they may harbor many harmful pathogens on or in their bodies.  It seems probable that heavy infestations of bed bugs and their associated fecal matter, might  ‘transfer’ pathogens via open sores, which may lead to further health problems.  Source: Tim Gibb, Purdue University Entomology Dept.

22. Guidance for Public Transit • FTA offers no guidance • EPA has no authority • Indiana does not have any laws or regulations • County health department cited as local authority

23. Denying Service Guidance • Ken Thompson, Easter Seals Consider the FTA, “Final Rule for People with Disabilities,” that adds a definition for “direct threat” to the definitions in 49 C.F.R. § 37.3.  “Direct threat” is defined as “a significant risk to the health or safety of others that cannot be eliminated by a modification of policies, practices or procedures, or by the provision of auxiliary aids or services.” This definition is consistent with the DOJ’s regulations, and focuses solely on whether an individual poses a significant threat to others; it does not include threats to self. • August 14,2015

24. Denying Service Guidance • Ken Thompson, Easter Seals The direct threat definition should be considered in circumstances where you suspend or refuse service to the rider.  Health department responses and support are key for the transit agency. Document efforts where you worked with the person so they could continue to ride such as various ways that the operator communicated with the rider on the bed bug issue, etc. August 14,2015

25. Denying Service Guidance • Ken Thompson, Easter Seals First, you may want to go to your local health department and talk with someone in environmental health. They can help with eradication at the source and can also be back-up for your decision to temporarily suspend service if needed. Always include the limits and conditions of the suspension so that the person understands what needs to be done to resume service. August 14,2015

26. Denying Service/Service Suspension • Denying service to anyone should always be a last resort and must be supported by documentation • Confirm an issue exists: • Are bedbugs present on person or personal items? • Are bedbugs found on the vehicle after the person exits? • Must the vehicle be removed from service to eradicate bedbugs? • Is the presence of bedbugs inhibiting the delivery of public transit service?

27. Denying Service/Service Suspension • Confirm an issue exists: • Discreetly and confidentially address concern with the individual and document • Seek assistance from your county health department

28. Denying Service/Service Suspension • If you determine suspension of service must be implemented make sure: • You have documented the reason for suspension and efforts to resolve the issue • You notify the individual/individuals involved • Notification must include appeal procedure • Conditions of suspension • Resolution required to resume service

29. Service Suspension Example • Dear _________, This letter is to inform you your riding privileges on Chillicothe Transit System (CTS) are suspended effective August 15, 2015. The suspension is a result of multiple confirmed incident reports of bed bug present on your clothing and other items carried onto the bus. Upon your exiting the CTS bus, bedbugs were found present and active on the vehicle requiring the vehicle to be removed from service and treated. Each time the vehicle was out of service for a period of at least two hours for treatment.

30. Service Suspension Example Cont. The Centers for Disease Control and Prevention (CDC) and the U.S. Environmental Protection Agency (EPA) has issued the following guidance: Although bed bugs are not known to transmit disease, they are a pest of significant public health importance. Bed bugs cause a variety of negative physical health, mental health and economic consequences.

31. Service Suspension Example Cont. Given the potential to transfer of invasive pests to others and the hardship caused by removing a CTS vehicle from service for extended periods of time, we ask that you not ride the CTS public transit system until the issue is resolved. If you need assistance resolving a bed bug or other pest issue please contact your local health department at (740) 775-1146. CTS is willing to work with you to determine a reasonable solution to this issue and looks forward to serving you again in the near future.

32. Service Suspension Example Cont • Suspension terms: • Service is suspended effective August 15,2015 and until the risk of exposure and transfer is contained. • Notice: • A rider who is subject to a suspension will be notified by U.S. mail and how to appeal the suspension.

33. Service Suspension Example Cont Appeal of suspensionSuspensions may be appealed in writing or in person by appointment. Appeals shall be overturned only if the information that the suspension is based upon is incorrect. A suspension may not be overturned because it causes a hardship for the passenger. All decisions will be made in writing and a copy placed in the passenger’s file. Individuals wishing to appeal a suspension may contact: Tamra Lowe, City of Chillicothe Civil Rights and EEO Officer 575 East 7th Street Chillicothe, OH (740)773-8033

34. Suspension Example Disclaimer • The example suspension of service letter was issued for an extreme situation and was determined necessary by CTS management. The service suspension was not appealed and therefore has not been scrutinized by any civil rights or legal departments.

35. Suspension Example Situation • Bedbugs were falling off of the individual and the individual’s wheelchair • Bedbugs were present and alive on a reduced fare application submitted by the individual • The vehicle was immediately removed from service for cleaning and over 30 bedbugs were present on the vehicle • The health department and housing authority confirmed a home infestation

36. Cautions and Considerations • Bed bugs are not known to transmit disease • Exposure to bedbugs is more likely at: • Hotels • College dorms • Nursing homes • Schools and Daycare centers • Offices • Hospitals • Service cannot be denied or suspended because of a nuisance or inconvenience • Rumor is not evidence

37. Cautions and Considerations • The bedbug problem is expected to get worse over the next couple of years before getting better • Proper investigation, attempted resolution and documentation will help to protect you in a civil rights lawsuit • Education and prevention measures may be your best defense

38. Public Transit Brochure and Best Practices Presented by Julie Schafer, RLS & Associates, Inc.

39. Brochure Purpose • The five W’s and one H • Who • What • Where • When • Why • How The system brochure is the primary marketing and service communication tool for most of Indiana’s rural transit systems

40. Brochure Purpose • Section 5311 requires services be advertised and open to the public • Effective communication of ADA compliance • Effective communication of Title VI and Civil rights compliance • SYSTEM MARKETING • COMMUNITY EDUCATION • COMMUNITY AWARENESS

41. Section 5311 • Market service as “open to the public” Your brochure must include a statement or information that clearly defines your service as public transit Public Transit Public Transportation Community Transit Area Transit County Transit

42. Title VI • Public Transit must comply with Title VI and Civil Rights non-discrimination laws and regulations • Title VI compliance statement • Non-discrimination statement • Compliant contact method

43. ADA • Demand responsive service shall be deemed to provide equalivant service for individuals with disabilities including individuals who use wheelchairs. Service equivalence characteristics include: • Response time • Fares • Geographic service area • Hours and days of service • Restrictions or trip priorities • Availability of information and reservation capability • Capacity constraints and service availability

44. ADA Brochure Information • Response time • Include information on how to schedule a trip • Scheduling hours • Scheduling window • Advance notice required • Same day or will call service • Pick up window • Wait time • Curb or curb • Door to door • Waiting lists

45. ADA Brochure information • Geographic service area • Define service area • Within Paradise County • Within Oceanview City limits • Providing service throughout Blue, Green, Yellow, and Pink Counties • Service also available to Indianapolis on Wednesdays • Out of county service within a 50 mile range Ocean City

46. ADA Brochure Information • Hours and days of service • Include service hours • Transportation service is available weekdays 6am to 6pm. • ABC transit is closed on the following holidays; • New Years day • Good Friday • Memorial Day • ABC transit operates limited service 9am to 2pm on Thanksgiving Friday and Christmas Eve

47. ADA Brochure Information • Restrictions or priorities based on trip purpose. • ABS Public Transit schedules all trips on a first come, first served basis. Trip requests are scheduled on a time and space availability basis. • Caution: INDOT prohibits charter service. Some group trips, after hours trips, etc. could be considered charter. Seek advise from INDOT before providing these services.

48. ADA and Civil Rights Brochure Information • Availability of information • Brail • Large Print • Audio • Electronic files • Spanish • Interpreter service • LEP requires alternate language information to be available for populations of 5% or 1000 individuals in service area

49. ADA and Civil Rights Brochure Information • Availability of information • Access to communication • Telephone number • Website and email • Address • TTY/TDD/Relay services • Interpreter services • Online booking

50. ADA Brochure Information • Capacity Constraints and service availability • Accessible vehicles • Transport of mobility devices • Transport of escorts or personal care attendants • Transport of service animals • Transport of portable oxygen and respirators • Reasonable accommodations/service modification requests Driver training should include use of accessibility equipment and priority seating