ON AUG. 8, 2000, OLAY DISCLOSED TO EPA THAT SUBSEQUENT TO A CORPORATE AUDIT CONDUCTED AT ITS FACILITY ON JUNE 26-28, 2000 IT DISCOVERED THAT IT HAD FAILED TO FILE FORM R REPORTS FOR BENZOYL PEROXIDE FOR THE YEAR 1998 AND FOR ZINC COMPOUNDS FOR 1999. THE FACILITY ALSO DISCLOSED THAT IT FAILED TO FILE TIER II CHEMICAL INVENTORY FORMS FOR BENZOYL PEROXIDE FOR 1998 AND 1999 AS REQUIRED UNDER SECTION 311 AND 312. *