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As of Jan. 1, pest management professionals must now use a new version of the NPMA-33 form for wood-destroying insect (WDI) inspections. The National Pest Management Association form is required for real estate transactions involving HUD/VA loans (except in states that mandate use of their own forms). It’s also typically used when traditional mortgage lenders require a WDI inspection.

The changes to the form were proposed by the NPMA Wood Destroying Organism (WDO) Committee and approved by the NPMA Board of Directors, a process that took more than two years to finalize. NPMA-33 was last updated in 2004.

“It has been years since the form had been updated and there was a need to make changes due to changes in treatment practices,” said Court Parker, chair of the NPMA WDO Committee and COO of Bug Busters in Woodstock, Ga.

The changes aim to limit the liability of inspectors and inspection companies using the form, make it easier for consumers to understand treatment recommendations, and give inspectors more options and flexibility in recommending WDI remediation and treatment. “There aren’t a whole lot of changes made, but the changes that were made are significant,” said Jim Fredericks, NPMA’s vice president of technical and regulatory affairs.


Section I: General Information

The first change you’ll notice is that instead of asking for a company’s business license number, the form now requests a company’s pest control business license number. The original wording consistently raised questions from inspectors; the new, more specific wording intends to clarify this. If a state does not require a business license to perform WDI inspections, put N/A or Not Applicable in this box, said Fredericks.

And while the “Structure(s) Inspected” box did not change, Fredericks urged PMPs to list all structures being inspected to limit liability. “And remember your inspection is limited to visible evidence in, on or under the structure,” he said.


Section II: Inspection Findings

At the request of the National Association of Realtors, the word “defects” — as in the inspection report is not a guarantee or warranty against future infestations or defects — was replaced with “wood-destroying insect damage.” In the real estate industry, “defects” means a wide range of things that could be wrong with a structure. The word was changed to shield PMPs from the responsibility of having to identify such defects, said Fredericks.

PMPs also will notice the entire section on “Evidence of Previous Treatment” was deleted. “It was removed because there were concerns from committee members about the difficulty, oftentimes, in determining whether or not a structure had been treated previously, and also concern about the potential liability regarding the work that was done by other companies,” explained Fredericks. Previously, inspectors had to check a “yes” or “no” box if a structure appeared to have been treated.

Changes to Sections I and II of the NPMA-33 form include a requirement of a company’s pest control business license number; the word “defects” was replaced with “wood-destroying insect damage;” and the entire section on “Evidence of Previous Treatment” was deleted.

Inspectors still can report evidence of previous treatment — such as drill holes in a dirt-filled porch or concrete block foundation wall — in “Section V: Additional Comments and Attachments” of the form if it is important in justifying the treatment recommendation.

“You’re free to record it if you like, if it helps you to make your case in terms of your treatment recommendation. If you’re not interested in recording that, or it’s not necessary as part of your treatment recommendation, then you can simply leave that out,” said Fredericks.

Section III: Recommendations

To give inspectors more options for recommending non-chemical WDI remediation, the wording of the check boxes in this section was expanded to include “action(s) and/or treatment(s)” instead of just treatment(s). This lets an inspector recommend that a single deck board damaged by carpenter bees be replaced instead of treated, for example.

As for subterranean termites, inspectors should not recommend treatment if evidence of the pest does not exist. They should recommend control measures if live termites are found in, on or under the structure; or if evidence of termites (wings, bodies, fecal pellets, kick-out holes, mud tubes, carton nests, staining or damage) is found but no documentation of treatment exists to show the infestation was addressed.

“There are also situations where you need to make a professional judgment in regards to recommendations,” said Fredericks. Unless a structure is under warranty or covered by a service agreement with a licensed pest control company, treatment may be recommended even if a documented treatment occurred in the past. An example is when evidence of termites is found and a bait system is in place or documentation of a previous treatment exists, but no service agreement for ongoing termite protection is evident.

Fredericks urged PMPs to ask for documentation of treatment and protection in advance of the inspection so it can be referenced as needed in the report.

Top: In “Section III: Recommendations,” the wording of the check boxes was expanded to include “action(s) and/or treatment(s)” instead of just treatment(s). In “Section IV: Obstructions and Inaccessible Areas,” two additional items were added to the list of potential obstructions to inspection: spray foam insulation and equipment. Bottom: The second page of the new form was changed to better help consumers understand the inspection process, limitations and treatment recommendations. There were no changes to items 3, 4 or 5.


Section IV: Obstructions and Inaccessible Areas

Two additional items were added to the list of potential obstructions to inspection. The first is spray foam insulation. “We are seeing in more and more structures, especially in the Southeastern United States, the installation of spray foam insulation. When spray foam is present in certain situations it makes it extremely difficult to inspect the sub-structure for termite evidence and also the attic for evidence of wood-destroying insects,” said Fredericks.

The second addition to the list is equipment, which could be anything from commercial kitchen appliances to HVAC equipment. Inspectors also may choose to write out a description of the obstruction and inaccessible areas instead of checking boxes on the list.

Every structure has obstructed and inaccessible areas and these should be recorded, reminded Fredericks. “This is a section that is especially important to protect you as the inspector,” he said.

Signature of Sellers. As before, sellers are required to sign the inspection report, stating they have disclosed all information pertaining to WDI infestation, damage, repair and treatment history of the structure. The real estate industry requested the phrase, “to their knowledge” be added to this statement. Inspectors are not required to collect the sellers’ signatures; that is the responsibility of the real estate agent or lender.


Page 2: Important Consumer Information Regarding the Scope and Limitation of the Inspection

The second page of the form is designed to help consumers understand the inspection process, limitations and treatment recommendations. Toward this end, a sentence was added asking consumers to review instructions for completing the report, which they now can access on NPMA’s website (http://npmatraining.org). “That will provide additional context for not only you, the inspector, but also your client,” said Fredericks.

The second paragraph — Treatment Recommendation Guidelines Regarding Subterranean Termites — was completely rewritten. The earlier version “was wordy, was difficult to understand and used some circular language, double negatives and that sort of thing and we tried to clear that up,” explained Fredericks.

The new language reads: “Treatment or corrective action should be recommended if live termites are found. If no evidence of a previous treatment is documented and evidence of infestation is found, even if no live termites are observed, treatment or corrective action by a licensed pest control company should be recommended. Treatment or corrective action may be recommended if evidence of infestation is observed, and a documented treatment occurred previously, unless the structure is under warranty or covered by a service agreement with a licensed pest control company. For other Wood Destroying Insects, please refer to the suggested guidelines for added guidance on actions and or treatment.”

The new paragraph also eliminated the reference to treatment performed within the previous five years. “That five-year limit has been taken away, allowing for you as the professional to make a professional judgment based on the conditions on the ground as to whether or not that structure should require treatment,” said Fredericks.

In addition, consumers are advised to refer to suggested guidelines for more information about actions and treatment for WDIs other than termites.

More Information. The new NPMA-33 form has a revision date of 7/1/19, which is found at the bottom of page one. The old version will not be accepted after Dec. 31, 2019. Paper and electronic versions of the form can be purchased from the NPMA website. Training on how to complete the form is available online, as well.

The author is a frequent contributor to PCT.