In letters dated january 13, 2005, and June 8, 2008, a representative of Roland DGA admitted violations of sections 12(b) and section 4(a) of TSCA. Specifically, Roland DGA failed to notify EPA in writing of its intent to export a chemical substance subject to section 4 of TSCA and filed to comply with the test rule exemption requirements in effect under 40 CFR section 799.5115 by failing to file an application for approval with EPA.