That would be a good question for someone to ask during the plant tour. (My "speciality" is sales and marketing, I'm ignorant regarding SEC matters.)
As posted back in August, in response to a question from a member of this board (NYC, I think) I was told that the SEC was asking RSPG to do 4 things (I think that's correct) regarding BB. Mr. Goldstein said that it's not unusual for the SEC to require much more than that.