Respondent submitted a voluntary disclosure under EPAÂs Audit Policy discussing possible violations of Section 8 of the Toxic Substances Control Act. EPA uncovered a violation that was not included in the disclosure. The discovered violation was RespondentÂs submission of a Notice of Commencement (NOC) of Import for the initial commercial import of a new chemical substance when the Respondent was not the importer of the shipment listed in the notice. A penalty was collected to resolve the case.