INSPECTED BY: BIONETICS INSPECTION REASON: DETERGENT AUDIT INSPECTION DATE: 3/03/99 NO. OF VIOLATIONS: FFIF# 1066282 DETERGENT AUDIT FOUND SEVERAL VAR & RECORD VIOLATIONS. -- THIS IS A CASE INVOLVING 19 VIOLATIONS OF THE DETERGENT PROG RAM REGULATIONS (BOTH VAR AND RECORDKEEPING VIOALTIONS), ALL OF WHICHOCCURRED IN 1995-96. DUE TO STATUTE OF LIMITATIONS TIMING CONCERNS, THE PENALTY WAS ONLY BASED ON 3 OF THESE V IOLATIONS. RESPONDENT AGREED TO PAY 70% OF ITS PROPOSED NOV PENALTY, WHICH MORE THAN COMPENSATED FOR THE ECONOMIC BENEF IT ATTAINED THROUGH THE VIOLATIONS. AS PART OF THE SETTLEME NT PROCESS, RESPONDENT ORDED PERIODIC AUDITS OF ALL ITS TERM INALS' VAR DOCUMENTATION, AND ALSO ORDERED ITS TERMINALS TO OVER-ADDITIZE ENOUGH TO ACCOUNT FOR ANY UNINTENTIONAL MISADD ITIVATION THAT MAY OCCUR.