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Proposed Regulations GoverningProposed Regulations GoverningUsed Mattresses, Bedding, andUsed Mattresses, Bedding, and

Upholstered FurnitureUpholstered FurniturePresented byPresented by

Glenn D. Savage, REHSGlenn D. Savage, REHSEnvironmental Health (EH) DirectorEnvironmental Health (EH) Director

andand

Nancy Hall, REHSNancy Hall, REHSSenior EH SpecialistSenior EH Specialist

to theto theSNHD District Board of HealthSNHD District Board of Health

September 27, 2007September 27, 2007

Initial DiscoveriesInitial Discoveries Public Accommodation (PA) FacilitiesPublic Accommodation (PA) Facilities

ACTUAL FINDINGS during inspectionsACTUAL FINDINGS during inspectionsMattresses, Box Springs, Upholstered FurnitureMattresses, Box Springs, Upholstered Furniture BeddingBedding

Stained, torn, dilapidated, broken!Stained, torn, dilapidated, broken!DangerousDangerousHealth risksHealth risksUncomfortable & unpleasantUncomfortable & unpleasantUNACCEPTABLE by any standardsUNACCEPTABLE by any standards……

Stained, torn, dilapidated, broken! Fresh blood on mattress Stained, torn, dilapidated, broken!Stained, torn, dilapidated, broken! FreshFresh bloodblood on mattresson mattress

Mattresses, Box Springs, Upholstered FurnitureMattresses, Box Springs, Upholstered Furniture

Stained, torn, dilapidated, broken!Bodily fluid stains on mattress Stained, torn, dilapidated, broken!Stained, torn, dilapidated, broken! Bodily fluidBodily fluid stains on mattressstains on mattress


Mattresses, Box Springs, Upholstered FurnitureMattresses, Box Springs, Upholstered FurnitureStained, torn, dilapidated, broken!Dangerous wire sticking out of mattress Stained, torn, dilapidated, broken!Stained, torn, dilapidated, broken! Dangerous wire sticking out of mattressDangerous wire sticking out of mattress

Mattresses, Box Springs, Upholstered FurnitureMattresses, Box Springs, Upholstered FurnitureStained, torn, dilapidated, broken! Common practice for mattresses to be slit and drug

paraphernalia placed inside (glass vials, needles,etc.)

Stained, torn, dilapidated, broken!Stained, torn, dilapidated, broken! Common practice for mattresses to be slit and drugCommon practice for mattresses to be slit and drug

paraphernalia placed insideparaphernalia placed inside ((glass vials,glass vials, needles,needles,etc.)etc.)


Stained,torn,dilapidated,broken!

Stained,Stained,torn,torn,dilapidated,dilapidated,broken!broken!

Mattresses, Box Springs, Upholstered FurnitureMattresses, Box Springs, Upholstered FurnitureStained, torn, dilapidated, broken! Stained, torn, dilapidated, broken!Stained, torn, dilapidated, broken!

BeddingBeddingStained with blood and bodily fluids Stained with blood and bodily fluidsStained with blood and bodily fluids

BeddingBeddingStained, torn, dilapidated! Stained, torn, dilapidated!Stained, torn, dilapidated!

TornTorn

BeddingBeddingBlood on pillow from bedbug bite victim BloodBlood on pillow from bedbug bite victimon pillow from bedbug bite victim

BEDBUGS!BEDBUGS!BEDBUGS! Mattresses & boxMattresses & box

springs,springs, Bedding,Bedding, Upholstered furniture,Upholstered furniture, Carpet, walls, & covingCarpet, walls, & coving Behind headboards,Behind headboards, Any other hiding placesAny other hiding places

in a roomin a room

Found locally

All stages of developmentAll stages of development

Live Bedbugs!LiveLive BedbugsBedbugs!!

Especially SeamsEspecially Seams

Bedbug Bites & ReactionsBedbugBedbug Bites & ReactionsBites & Reactions

Delayed ReactionDelayed Reaction>24 hours>24 hours

Regulatory HistoryRegulatory HistoryApril 2006, Board adopted SNHD

Regulations Governing the Sanitation andSafety of Public Accommodation Facilities(PA Regs.)

Until 2006, SNHD used NRS & NAC 447, PublicAccommodations to inspect PA Facilities

PA Regs. & Appendices Developed with PAIndustry in Committee Forum

April 2006, Board adoptedApril 2006, Board adopted SNHDSNHDRegulations Governing the Sanitation andRegulations Governing the Sanitation andSafety of Public Accommodation FacilitiesSafety of Public Accommodation Facilities(PA(PA RegsRegs.).)

Until 2006, SNHD used NRS & NAC 447,Until 2006, SNHD used NRS & NAC 447, PublicPublicAccommodationsAccommodations to inspect PA Facilitiesto inspect PA Facilities

PAPA RegsRegs.. & Appendices Developed with PA& Appendices Developed with PAIndustry in Committee ForumIndustry in Committee Forum

PAPA RegsRegs Appendix JAppendix J Based on existing requirements ofBased on existing requirements of NRSNRS

444.010444.010--444.040,444.040, Used Bedding and MattressesUsed Bedding and Mattresses& NAC 444.001& NAC 444.001--444.006,444.006, Sterilization of UsedSterilization of UsedBeddingBedding

Appendix J,Appendix J, ““Sterilization PlantSterilization PlantReciprocity ApplicationReciprocity Application”” Allowed sanitized & refurbished used mattressesAllowed sanitized & refurbished used mattresses

and bedding in PA Facilities if purchased from anand bedding in PA Facilities if purchased from anapprovedapproved ““Sterilization PlantSterilization Plant””

““Sterilization PlantSterilization Plant””must have completedmust have completed Application processApplication process Plan reviewPlan review Secured a Health Permit or Approval to operateSecured a Health Permit or Approval to operate

PA Facility Inspection FindingsPA Facility Inspection Findings During routine inspections, mattresses &During routine inspections, mattresses &

box springs were found in guest rooms:box springs were found in guest rooms:Without identifying tagsWithout identifying tagsWith improper identifying tagsWith improper identifying tagsWith tags where important information was missingWith tags where important information was missing In unacceptable conditionIn unacceptable condition

Should have been removed from service by PAShould have been removed from service by PAFacility owners/operatorsFacility owners/operators

TraceTrace--back investigation conducted usingback investigation conducted usinginvoices from PA Facility. Records led to:invoices from PA Facility. Records led to: Store where mattress sets were purchasedStore where mattress sets were purchased UnpermittedUnpermitted used mattress renovation &used mattress renovation &

sanitization facilities where mattress sets weresanitization facilities where mattress sets weremade within Clark Countymade within Clark County

Mattress Renovation & Sanitization FacilityMattress Renovation & Sanitization Facility --Oct 3, 2006 Investigation FindingsOct 3, 2006 Investigation Findings

General unsanitary conditions throughout facilityGeneral unsanitary conditions throughout facility Lack of any process for mattress sanitizationLack of any process for mattress sanitization No knowledge by owner or employees ofNo knowledge by owner or employees of

requirements of NV laws and regulationsrequirements of NV laws and regulationsregarding mattress sanitizationregarding mattress sanitization

Business licenses forBusiness licenses for ““ManufacturerManufacturer””&&““Furniture sales/rentalFurniture sales/rental””, not:, not: Secondhand DealerSecondhand Dealer Furniture Repair/RefinishFurniture Repair/Refinish UpholsteryUpholstery Or any otherOr any other potentiallypotentially relevant business licensingrelevant business licensing

CEASE & DESIST ORDER ISSUEDCEASE & DESIST ORDER ISSUED

Trailer of used mattresses from localTrailer of used mattresses from localPA facilities behind warehousePA facilities behind warehouse

““NewNew””springs forsprings for ““newnew””mattressesmattresses

Used mattress stripping areaUsed mattress stripping area

Dumpster with materials stripped fromDumpster with materials stripped fromused mattresses and box springsused mattresses and box springs

Used mattress being strippedUsed mattress being strippedFirst cover is cut and removedFirst cover is cut and removed

Mattress pad storageMattress pad storage Used mattress pad that covered used springs is placedUsed mattress pad that covered used springs is placed

directly next to new mattress padsdirectly next to new mattress pads

Continued stripping of used materialsContinued stripping of used materials

Sanitizing, or lack ofSanitizing, or lack of Used springs are then sprayed with sanitizer inUsed springs are then sprayed with sanitizer in

a pressurized canister (similar to those used fora pressurized canister (similar to those used forpesticides)pesticides) MethodMethod NOTNOT recommended by sanitizer manufacturerrecommended by sanitizer manufacturer Spray canister not on site at time of investigationSpray canister not on site at time of investigation

After mattress springs areAfter mattress springs are ““sanitized,sanitized,””they are covered with new materialsthey are covered with new materials

Clutter of personalitems in work area

New mattress cover storageNew mattress cover storage

More new mattress materialsMore new mattress materials……and personal itemsand personal items

Final stitchingFinal stitching

Secondhand (Used) tag appliedSecondhand (Used) tag applied -- CA formatCA format

““Registry No.Registry No.””shownshownon tag is their C.C.on tag is their C.C.Business LicenseBusiness LicenseNumberNumber--This isThis is NOTNOT aa““NV Registry NumberNV Registry Number””!!

Refurbished mattress storageRefurbished mattress storage

Box spring refurbishment areaBox spring refurbishment area

Overall facilityOverall facility

Used mattresses & box springsUsed mattresses & box springsrefurbished at facility withrefurbished at facility with ““newnew””materials, marked withmaterials, marked with ““newnew””tagtag

Work waiting to be doneWork waiting to be done……

Meeting held with facilityMeeting held with facility A meeting & reinspection was held Oct 10, 2006A meeting & reinspection was held Oct 10, 2006

at the local facility with owner from CAat the local facility with owner from CA EH staff explained:EH staff explained:

Chemical sanitation process as implemented was notChemical sanitation process as implemented was notapproved in Clark County or State of NVapproved in Clark County or State of NV

How to obtain proper approvals from State of NV & SNHDHow to obtain proper approvals from State of NV & SNHDfor sale of refurbished & sanitized product in Clark Countyfor sale of refurbished & sanitized product in Clark County

CA owner and local operator did not contactCA owner and local operator did not contactSNHD or State at any time following meetingSNHD or State at any time following meeting SNHD sent 3 Notices for the Public Workshops & HearingsSNHD sent 3 Notices for the Public Workshops & Hearings

by postal mail to local & CA addressesby postal mail to local & CA addresses——NO RESPONSENO RESPONSE Later searches of business licensing recordsLater searches of business licensing records

indicated the local company forfeit theirindicated the local company forfeit their““manufacturingmanufacturing””license Oct 15, 2006 & theirlicense Oct 15, 2006 & their““furniture sales/rentalfurniture sales/rental””license Nov 08, 2006license Nov 08, 2006

State of NV Variance HearingState of NV Variance Hearing A Variance Request was made at the State of NVA Variance Request was made at the State of NV

Board of Health Public Hearing October 13, 2006Board of Health Public Hearing October 13, 2006by Hotel Furniture Sales, who wished toby Hotel Furniture Sales, who wished tochemically sanitize used mattress sets from localchemically sanitize used mattress sets from localhotels for sale to the publichotels for sale to the public At the variance hearing, SNHD EH staff presentedAt the variance hearing, SNHD EH staff presented

information to the State of NV on the concernsinformation to the State of NV on the concernsencountered at the aforementioned facility, which wasencountered at the aforementioned facility, which wasgiven thegiven the Cease & Desist OrderCease & Desist Order onon Oct 3, 2006Oct 3, 2006

SNHD EH staff reviewed the variance request prior to theSNHD EH staff reviewed the variance request prior to theState of NV hearingState of NV hearing

Based on the information provided, SNHD EH staffBased on the information provided, SNHD EH staffrecommended to the State Board of Health that therecommended to the State Board of Health that thevariance be tabled until certain questions could bevariance be tabled until certain questions could beanswered & deficiencies in the applicantanswered & deficiencies in the applicant’’s operationals operationalprocedures could be worked outprocedures could be worked out

Variance request resultsVariance request results State granted variance and directedState granted variance and directed

SNHD EH staff to work with theSNHD EH staff to work with theapplicant to resolve issuesapplicant to resolve issues

California Bureau of Home Furnishings andCalifornia Bureau of Home Furnishings andThermal Insulation had already been contactedThermal Insulation had already been contactedprior to the heaprior to the hearing of the variance requestring of the variance request

They were unable to answer EH staffThey were unable to answer EH staff’’ssquestions regarding chemical sanitation and didquestions regarding chemical sanitation and didnot get back to them with the promisednot get back to them with the promisedinformationinformation

Variance requestVariance request Concerns could not be resolved and aConcerns could not be resolved and a

CEASE & DESIST ORDERCEASE & DESIST ORDER was issuedwas issuedto Hotel Furniture Sales by SNHDto Hotel Furniture Sales by SNHD

These concerns included:These concerns included: Vague ProceduresVague Procedures No detail onNo detail on ““sanitation roomsanitation room””designdesign No detail on visual inspection process that was goingNo detail on visual inspection process that was going

to be performed by Hotel Furniture Sales staffto be performed by Hotel Furniture Sales staff No procedure for disposition of mattresses withNo procedure for disposition of mattresses with

adulterants presentadulterants present OpenOpen--ended phrase,ended phrase, ““or comparable productor comparable product””leftleft

room for blanket approval of any chemical treatmentroom for blanket approval of any chemical treatment ““Thoroughly treatedThoroughly treated””not definednot defined Insufficient, improper application ofInsufficient, improper application of SteriSteri--FabFab wouldwould

likely not eliminate bedbugs, including ovalikely not eliminate bedbugs, including ova

Used comfortersUsed comforters --unknown sanitation statusunknown sanitation status

More Mattresses discovered inMore Mattresses discovered inPA FacilitiesPA Facilities--December 2006December 2006

More mattresses bought from renovator givenMore mattresses bought from renovator giventhe firstthe first CEASE & DESIST ORDERCEASE & DESIST ORDER discovereddiscoveredduring a Dec 2006 PA facility inspectionduring a Dec 2006 PA facility inspection

Trace back found:Trace back found: The business had been soldThe business had been sold The new owner was unaware of theThe new owner was unaware of the CEASE &CEASE &

DESIST ORDERDESIST ORDER issued to previous ownerissued to previous owner Similar conditions still existed at facilitySimilar conditions still existed at facility New owner did not have a business licenseNew owner did not have a business license

AA newnew CEASE & DESIST ORDERCEASE & DESIST ORDER was issued forwas issued forrefurbishment of used articlesrefurbishment of used articles

Reinspection on January 3, 2007 forReinspection on January 3, 2007 for ““newnewarticle manufacturing onlyarticle manufacturing only””resulted inresulted insatisfactory improvements to conduct businesssatisfactory improvements to conduct business

Facility in same unacceptableFacility in same unacceptablecondition in Deccondition in Dec ‘‘0606

Equipment in unacceptable conditionEquipment in unacceptable conditionDecDec ‘‘0606

Awaiting rebuilds (sold as new?)Awaiting rebuilds (sold as new?)--DecDec ‘‘0606

Labeling ColorsLabeling Colors

“New”=white“Secondhand (Used)”= red“SANITIZED”= yellow

Are these mattressesNew?Used?Sanitized?

““NewNew””=white=white““Secondhand (Used)Secondhand (Used)””== redred““SANITIZEDSANITIZED””== yellowyellow

Are these mattressesAre these mattressesNew?New?Used?Used?Sanitized?Sanitized?

““NewNew””labeling, but islabeling, but isitit reallyreally new?new?

MysteryMystery ““newnew””tags withtags withdifferent CA Registry #different CA Registry #’’ss

Secondhand label obscuredSecondhand label obscured

Blank Secondhand (Used) LabelsBlank Secondhand (Used) Labels

Sanitized in CASanitized in CA-- not approvednot approvedfor sale in NVfor sale in NV

DecDec ‘‘0606

Properly filled out tags from CAProperly filled out tags from CA

New?New?

Used springsUsed springs--Being rebuilt or soldBeing rebuilt or soldasas ““newnew””??

New or Used?New or Used?

NewNew

OROR

Used?Used?

New or used?New or used?

Facility conditions out of controlFacility conditions out of control--DecDec ‘‘0606

Still using old business licenseStill using old business license-- DecDec ‘‘0606

New businessNew businessinvoiceinvoice--DecDec ‘‘0606

OldOld ““rebuildrebuild””pricing listpricing list--

not supposed tonot supposed tobe rebuildingbe rebuilding

DecDec ‘‘0606

Old business name cut off of pricing listOld business name cut off of pricing list

Investigative Trip to CaliforniaInvestigative Trip to California An SNHD EH investigative team traveledAn SNHD EH investigative team traveled

to So. California Feb 13to So. California Feb 13thth & 14& 14thth 2007 to2007 toview facilities approved to sanitize andview facilities approved to sanitize andrefurbish used mattresses and bedding inrefurbish used mattresses and bedding inthat statethat state

Five distinct facilities were surveyedFive distinct facilities were surveyed Objective evidence in the form ofObjective evidence in the form of

photographs, video, and notations wasphotographs, video, and notations wasgathered and reviewed upon return togathered and reviewed upon return toClark CountyClark County

Purpose: determining reciprocityPurpose: determining reciprocityrequirementsrequirements--What worksWhat works--what doesnwhat doesn’’t?t?

CACA--Findings from InvestigationFindings from InvestigationChemical SanitizersChemical Sanitizers

Inadequately trained staffInadequately trained staff Staff relying on realStaff relying on real--time advice from State oftime advice from State of

CA inspectors to apply sanitizerCA inspectors to apply sanitizer Still did not apply properlyStill did not apply properly

Incorrect application of sanitizer,Incorrect application of sanitizer,preventing proper saturation of allpreventing proper saturation of allparts of article, such as coils & bindingparts of article, such as coils & binding

CACA--Findings from InvestigationFindings from InvestigationChemical SanitizersChemical Sanitizers

Method of application preventedMethod of application preventedfluorescing detection crystals fromfluorescing detection crystals fromremaining in suspension long enoughremaining in suspension long enoughto be applied to the articleto be applied to the article

Method of detection subjectiveMethod of detection subjective(magnified UV light)(magnified UV light)

Facilities were crossFacilities were cross--contaminatingcontaminatingmattresses that had receivedmattresses that had receivedsanitizer treatment with ones thatsanitizer treatment with ones thathad nothad not

CA parent company ofCA parent company offirst facility with a Ceasefirst facility with a Cease

& Desist Order& Desist Order--Chemical SprayChemical Spray

“Sanitized”areas damp,the rest is not…

CA parentCA parentcompanycompany--

SimilarSimilarconditions toconditions to

LV facilityLV facility

CACA--Findings from InvestigationFindings from InvestigationDry Heat SanitizationDry Heat Sanitization

Two facilities employed dry heatTwo facilities employed dry heatsanitizationsanitization

Provided objective evidence thatProvided objective evidence thatarticles achieved sanitizationarticles achieved sanitizationtemperatures in the form oftemperatures in the form oftemperature data logger recordstemperature data logger records

Process demonstrated was consistentlyProcess demonstrated was consistentlyrepeatablerepeatable

All parts of the mattress, includingAll parts of the mattress, includinginternal coils, received sufficient heatinternal coils, received sufficient heatto destroy pathogens and insectsto destroy pathogens and insects

CACA--Gateway MattressGateway Mattress--new materials properly storednew materials properly stored

CACA--Fabric Covering ProcessFabric Covering Process

CACA--Dry Heat Sanitization OvensDry Heat Sanitization Ovens& Data Logger& Data Logger

CACA--Melrose MattressMelrose Mattress--Dry Heat OvenDry Heat Oven

CA InvestigationCA InvestigationConclusions based on findingsConclusions based on findings

Based on these findings, SNHD staffBased on these findings, SNHD staffdetermined:determined: Chemical sanitizer is used inappropriately at theChemical sanitizer is used inappropriately at the

facilities assessedfacilities assessedObservation of fluorescent crystals underObservation of fluorescent crystals under

magnification too subjective to be consistentlymagnification too subjective to be consistentlyreliable detection methodreliable detection method

Dry heat sanitization is a consistently reliableDry heat sanitization is a consistently reliablemethod of sanitizationmethod of sanitization

Dry heat sanitization resulted in a written,Dry heat sanitization resulted in a written,objective record of processes used to disinfect theobjective record of processes used to disinfect themattressesmattresses

What it can look like hereWhat it can look like here……

January 2007 reinspection ofJanuary 2007 reinspection offacility under new ownershipfacility under new ownership

JanJan ’’0707-- Some springs still obviouslySome springs still obviouslyusedused--however conditions improvedhowever conditions improved……

Improved facility conditionsImproved facility conditions--JanJan ‘‘0707

Better materials storageBetter materials storage

Improved equipment & work areaImproved equipment & work area

Regulation DevelopmentRegulation Development Posted and mailed Public Notices onPosted and mailed Public Notices on

three (3) separate datesthree (3) separate dates First Public Notice gave informationFirst Public Notice gave information

regarding three (3) Public Workshopsregarding three (3) Public WorkshopsheldheldMesquiteMesquite LaughlinLaughlin Las VegasLas Vegas

Solicited Industry participation bySolicited Industry participation bytelephonetelephone

Took and addressed public commentsTook and addressed public comments Wrote Business Impact StatementWrote Business Impact Statement

Proposed RegulationsProposed Regulations

WhereasWhereas

Intent & ScopeIntent & Scope

Table of ContentsTable of Contents

Section 1: Definitions specific toSection 1: Definitions specific tothese Regulationsthese Regulations

BeddingBedding Bedding renovation facilityBedding renovation facility Letter of Approval for ReciprocityLetter of Approval for Reciprocity ManufacturerManufacturer RefurbishRefurbish Sanitization FacilitySanitization Facility Secondhand & UsedSecondhand & Used

Section 2: Risks to Public Health,Section 2: Risks to Public Health,Safety, and the EnvironmentSafety, and the Environment

VerminVermin Toxic materials and gasesToxic materials and gases Unsanitary articlesUnsanitary articles

Section 3: Approvals forSection 3: Approvals forOperationOperation

Ensure clear guidance on requirements,Ensure clear guidance on requirements,timelines, and process for obtaining a:timelines, and process for obtaining a:

Health Permit to operate in Southern NevadaHealth Permit to operate in Southern Nevadaoror Letter of Approval for Reciprocity if planning toLetter of Approval for Reciprocity if planning to

export to Southern Nevada from another stateexport to Southern Nevada from another state

Exemption for Charitable OrganizationsExemption for Charitable Organizationswith proper documentationwith proper documentation

Section 4: Application for Permit toSection 4: Application for Permit toOperate or Letter of Approval forOperate or Letter of Approval for

ReciprocityReciprocity StepStep--byby--step, detailed requirementsstep, detailed requirements

for applying for Permit or Letterfor applying for Permit or Letter

Applicants know what to expect outApplicants know what to expect outof process for evaluation andof process for evaluation andapproval or denial of applicationapproval or denial of application

Requirements for issuance,Requirements for issuance,revocation, suspension, and newrevocation, suspension, and newownershipownership

Section 5: Facility Design andSection 5: Facility Design andOperationOperation

Requirements for and documentation of:Requirements for and documentation of: Exterior areasExterior areas Facility layoutFacility layout Floors, walls, ceilings, closuresFloors, walls, ceilings, closuresWork surfacesWork surfacesWater, plumbing, lighting & ventilation, includingWater, plumbing, lighting & ventilation, including

smoke alarmssmoke alarms Chemical and Electrical SafetyChemical and Electrical Safety RestroomsRestrooms Storage and transportation of articlesStorage and transportation of articles Pest control, solid waste disposalPest control, solid waste disposalOperational records/logbooksOperational records/logbooks

Section 6: Methods and RequirementsSection 6: Methods and Requirementsfor Sanitization and Refurbishmentfor Sanitization and Refurbishment

Methods of sanitizationMethods of sanitization--prohibitions,prohibitions,assessment of emerging methods, andassessment of emerging methods, andmethods specifically permittedmethods specifically permitted

Requirements for dry heat sanitizationRequirements for dry heat sanitization

Lots, materials, labeling, andLots, materials, labeling, andprotection from contaminationprotection from contamination Specific Label requirements also given inSpecific Label requirements also given in

ARTICLE 1ARTICLE 1

Section 7: Inspections andSection 7: Inspections andEnforcementEnforcement

Clear guidance on what is expectedClear guidance on what is expectedduring an inspectionduring an inspection

Remedies for enforcement for both theRemedies for enforcement for both theSNHD and the facility owner/operatorSNHD and the facility owner/operator

Section 8: MiscellaneousSection 8: Miscellaneous

Severability clauseSeverability clause Effective DateEffective Date

Attachments to RegulationsAttachments to Regulations ARTICLE 1: Label requirementsARTICLE 1: Label requirements

Appendix A: Contact Information forAppendix A: Contact Information forthe Health Authoritythe Health Authority

Appendix B:Appendix B: Application(sApplication(s) for a) for aHealth Permit or Letter of ApprovalHealth Permit or Letter of Approvalfor Reciprocity for Used Beddingfor Reciprocity for Used BeddingRenovation or Sanitization FacilitiesRenovation or Sanitization Facilities

RecommendationsRecommendations StateState’’s amendments to NAC 444.002s amendments to NAC 444.002

Less stringent than proposed RegulationsLess stringent than proposed RegulationsDo not provide detailed guidanceDo not provide detailed guidance Not suitable to fully address needs of SouthernNot suitable to fully address needs of Southern

NevadaNevada

Propose adoption ofPropose adoption of RegulationsRegulationsGoverning the Sanitation and Safety ofGoverning the Sanitation and Safety ofUsed Mattresses, Bedding, andUsed Mattresses, Bedding, andUpholstered FurnitureUpholstered Furniture as submitted oras submitted orwith modifications as directed by thewith modifications as directed by theBoardBoard

QUESTIONS ORQUESTIONS ORCOMMENTS?COMMENTS?

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