Typically, the facility address is the physical location where the violation(s) occurred. For violations that occur outside of a facility (e.g., oil spills, pipeline leaks), the address is the mailing address of the violator/respondent/defendant. For example, the mailing address can be the defendant/respondent's address used for correspondence in the enforcement document.
Under the TSCA lead-based paint program the majority of the EPA Regional enforcement activities are 1018 disclosure rule violations. The individuals who must comply with the Disclosure Rule are sellers, lessors, and agents who are involved in the selling or leasing of target housing. In most cases the "physical location where the violations occurred" is the real estate office or the property management or rental office, not the actual residence of a tenant or buyer. The facility in ICIS for an enforcement action is the violator's address or in other words the lessor, real estate office, property management company etc. The various residential addresses should not become the Facility Addresses. If there is a training/certification violation, the facility is the company that conducted the inadequate training. If the is a pre-renovation education rule violation, the facility is the remodeler.