On July 14, 2011, a voluntary self-disclosure under the Audit Policy was submitted by letter to the Environmental Protection Agency (EPA). It was disclosed that the company had failed to file TRI Form R reports for nickel compounds for calendar years 2008 and 2009 and for lead compounds for calendar years 2005, 2006, 2007, 2008, and 2009. The Form R reports for these two chemicals were submitted on August 16, 2011.