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Entering a TSCA lead-based paint inspection involving a property owner/manager with multiple properties


When doing an inspection for TSCA lead-based paint, the inspector is supposed to first go to the property management office, or the property owner's office (where ever the records are kept).  If the property owner/manager leases 100 properties at different location, and the inspector finds lead-based paint violations at 10 locations how will this be entered in ICIS?


The basic rule for all programs is that every time the inspector must exercise the statutory requirements (give notice, show credentials) it counts as an inspection.  For this example, regarding an inspection, if the inspector went to one location to review the records and only gave notice of an inspection once then the inspection should be entered in ICIS once involving 10 properties/facilities.  The caveat is whether the inspector must go to different locations to review the records and more to the point, whether the inspector must give notice of an inspection at each of those locations.


Regarding an enforcement action, the answer is if the properties all have unique, discrete addresses, then you will enter once enforcement action, list of all the violations, and link each facility with a discrete address to the single enforcement action.  The action will receive multi-facility credit.


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