On November 13, 2003, U.S. EPA received a request from 3M to enter into a Corporate Auditing Agreement pursuant to U.S. EPA's guidance on Use of Corporate Auditing Agreements for Audit Policy Disclosures, dated May 7, 2001. In its request to enter a Corporate Auditing Agreement, 3M proposed to conduct an assessment of its refrigerant management program at thirty-one 3M facilities located in Alabama, Indiana, Iowa, Kentucky, Massachusetts, Minnesota, Missouri, Nebraska, Ohio, South Carolina, South Dakota, Texas, Utah and Wisconsin. 3M's assessment found Section 608 violations, and 3M has agreed to take actions to come into compliance. To prevent a recurrence of the violations, 3M will take steps such as strengthening its internal auditing of refrigerant management issues and providing additional training on refrigerant management practices. Pursuant to U.S. EPA's Self-Disclosure Policy, penalties have been reduced to $0.