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Appendix C Relationship between the OSWER Soil Lead Directive and TSCA Section 403 Guidance Since lead exposures occur through all media, a variety of Agency programs address lead under a number of statutes. Lead in soil is addressed under TSCA Section 403, the RCRA Corrective Action program, and CERCLA, eaeh of which differs somewhat in the types of sites that apply and the types of standards that are used. These differences are primarily due to differences in the purposes of the programs and the authority granted by the statutes under which they are developed. Section 403 soil standards will apply only to residential soil and the current TSCA guidance is generic in nature, with the same standards applying on a nationwide basis. Given the wide applicability of Section 4.03, generic standards are used in the current guidance in order to reduce resource requirements, as compared to site- specific decisions which can involve expensive and time-consuming analyses. Required RCRA and CERCLA activities are determined on a site-specific basis. The agency's recommendations for evaluating RCRA Corrective Action and CERCLA sites are contained in the OSWER Interim Soil Lead Directive. In 111 three of these programs, the Agency's approach is to consider soil lead in the context of other lead sources that may be present and contribute to the total risk. For example, TSCA Section 403 specifically requires the Agency to consider the hazards posed by lead-Lased paint and lead-contaminated interior dust, as well as lead-contaminated soil. Likewise, the OSWER Soil Directive includes evaluation of other lead sources at a site as part of site assessment/investigation procedures. In addition, the primary focus of the three programs is primary prevention -- the prevention of future exposures from the source(s) being remediated. The fundamental difference between the relatively new TSCA Section 403 program and the RCRA Corrective Action and CERCLA cleanup programs is that, under current guidance the Section 403 program seeks to establish national standards to prioritize responses to lead hazards whereas the other two programs usually develop site-specific cleanup requirements. This is because TSCA Section 403 deals with a potentially huge number of sites, and resources for the investigation needed to accurately identify their risks are typically very limited. Therefore most decisions under Section 403 will be made with little or no regulatory oversight and clear generic guidelines will be more effective. The more established RCRA and CERCLA programs, on the other hand, deal with a much smaller number of sites, at which extensive site characterization will have been performed before cleanup decisions are made. In addition, these programs have well- established funding mechanisms. C-1 4