Honestly, the only thing I could say to you would be very anecdotal at the time of 2002.
Because of the timelines associated with the development of risk reduction measures, the fastest and easiest route for the department was to try to get a negotiated voluntary agreement, a non-regulatory measure, in effect, because it takes so long to get regulations through the system that a two-year timetable was a bit of a barrier.
But that's very anecdotal, and we did not do audit-based work that would give us evidence. It's just the things you hear as you're talking to risk managers.