Under an audit agreement with EPA, Invista completed 45 audits of environmental practices at 12 facilities it acquired in 2004. The results reportedly led to disclosure and settlement of more than 680 violations of air, water, hazardous waste, pesticides and emergency planning requirements. The settlement, which includes $1.75 million in civil penalties and an estimated $500 million in costs to correct the self-reported violations, is the largest settlement announced under EPA's audit policy. The agency drew from its experience with Invista's audits to develop an interim new owner audit policy in August 2008. The policy is intended to encourage companies to establish a "clean start" at their recently-acquired facilities.