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Entering ICDS deficiencies for two scenarios under the TSCA lead-based paint program: Sec. 402 Failure to used certified individuals and Section 406.b failure to disclose

Currently there are 12 deficiencies listed in ICIS ICDS deficiency drop-down menu that apply to all of the environmental statutes. They were designed to be multi-media. Since we implemented ICDS in 2002, some regional media programs have asked that media-specific deficiencies and complying actions be included in ICIS instead of these multi-media choices. These proposals have not been implemented yet and are under consideration.

In the meantime the ICIS user should use the following TSCA deficiencies currently in ICIS for reporting TSCA Sec. 402 deficiency (Failure to used certified individuals) -- Select "Potential Failure to Follow or Develop a Required Management Practice or Procedure" and for TSCA Section 406.b (Failure to disclose) -- Select "Potential Failure to Maintain a Record or Failure to Disclose a Document."

OC's Compliance Assessment and Media Programs Division is developing a guide to help the Regions consistently enter deficiencies in ICIS that apply to specific media programs.

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