What changed in this filing

/stocks — the workspaceLOADING

Item 1. Business

2025-03-20 compared with 2024-03-20 · 70 added, 63 removed, 543 unchanged (20% of the section changed)

84 unchanged sentences

there is a judicial dissolution of the Trust.

Upon dissolution, the Trustee would sell all of the Trust’s assets, either by private sale or public auction, and distribute the net proceeds of the sale to the Trust unitholders.

Upon dissolution prior to the liquidation date, the Trustee would sell all of the Trust’s assets, which are limited to the net profits interest, and do not include the Underlying Properties, either by private sale or public auction, and distribute the net proceeds of the sale to the Trust unitholders.

Computation of Net Proceeds

172 unchanged sentences

Operating Expenses

Non-Producing

(dollars in thousands)

Future Development Costs

10 unchanged sentences

Oil price differentials were not escalated.

Gas price differentials varied by property as provided by VOC Brazos and were also not escalated.

NGL price differentials were applied at 26% of the WTI oil price and not escalated.

Gas and NGL price differentials varied by property as provided by VOC Brazos and were also not escalated.

The base price differentials may include local basis differentials, transportation, gas shrinkage, gas heating value (BTU content) and/or crude quality and gravity corrections.

13 unchanged sentences

Producing Acreage and Well Counts

For the following data, “gross” refers to the total wells or acres in which VOC Brazos owns a working interest and “net” refers to gross wells or acres multiplied by the percentage working interest owned by VOC

Although many of VOC Brazos’ wells produce both oil and natural gas, a well is categorized as an oil well or a natural gas well based upon the ratio of oil to natural gas production.

10 unchanged sentences

Non-productive

In 2021, the former MD Earning Well was completed and one other well was drilled, deemed non-productive and plugged.

Total capital expenditures in 2021 for the former MD Earning Well were $1,695,593.

In 2022, two wells were drilled and completed.

1 unchanged sentence

In 2023, no wells were drilled and completed.

In 2024, no wells were drilled and completed.

VOC Brazos continues to develop further proved undeveloped reserves pursuant to its planned development and workover program.

19 unchanged sentences

This yielded a base price for oil of $75.48 per barrel and a base price for natural gas of $2.13 per MMBtu.

Because the Trust bears no federal tax expense and taxable income is passed through to the Trust unitholders, no provision for federal or state income taxes is included in the summary reserve reports

and therefore the standardized measure of discounted future net cash flows attributable to the Underlying Properties is equal to the pre-tax PV-10 value.

Because the Trust bears no federal tax expense and taxable income is passed through to the Trust unitholders, no provision for federal or state income taxes is included in the summary reserve reports and therefore the standardized measure of discounted future net cash flows attributable to the Underlying Properties is equal to the pre-tax PV-10 value.

PV-10 may not be considered a GAAP financial measure as defined by the SEC and is derived from the standardized measure of discounted future net cash flows, which is the most directly comparable GAAP financial measure.

1 unchanged sentence

As of December 31, 2024, proved reserves attributable to the portion of the Kansas Underlying Properties were approximately 2.3 MMBoe and were located in three primary areas:

Central Kansas Uplift, Western Kansas and South-Central Kansas.

Kansas Uplift, Western Kansas and South-Central Kansas.

As of December 31, 2024, the VOC Operators operated 98.4% of the total proved reserves attributable to the Kansas Underlying Properties based on PV-10 value.

34 unchanged sentences

All natural gas produced by VOC Brazos is marketed and sold to third-party purchasers.

The natural gas is sold on a contract basis and, in all but two cases, the contracts are in their secondary terms and are on a month-to-month basis.

The natural gas is sold on a contract basis and, in all but one case, the contracts are in their secondary terms and are on a month-to-month basis.

In all cases, the contract price is based on a percentage of a published regional index price, after adjustments for Btu content, transportation and related charges.

Vess Oil Corporation has committed to sell all of its natural gas production attributable to the Kurten Woodbine Unit in Texas to ETC Texas Pipeline, Ltd., on a year-to-year basis effective October 1, 2014.

Vess Oil Corporation has also committed to sell to ONEOK Field Services Company, L.L.C.

all of its natural gas production attributable to three wells in Kingman and Barber Counties, Kansas on a month-to-month basis effective as of August 31, 2015.

Vess Oil Corporation currently sells all of its natural gas production attributable to the Kurten Woodbine Unit in Texas to ET Gathering & Processing LLC on a year-to-year basis.

Vess Oil Corporation currently sells all of its natural gas production attributable to wells in Kingman County, Kansas to Durango Midstream and Superior Midstream on a month-to-month basis.

All of the natural gas production in Barber County, Kansas is currently sold to Targa Resources Corp.

on a month-to-month basis.

VOC Brazos does not have any volume commitments or take or pay arrangements.

8 unchanged sentences

Any net sales proceeds paid to the Trust are distributable to Trust unitholders for the quarter in which they are received.

No Underlying Properties were sold, and therefore no net sales proceeds were paid to the Trust for its share of interest in any such Underlying Properties, during 2022 or 2023.

No Underlying Properties were sold, and therefore no

net sales proceeds were paid to the Trust for its share of interest in any such Underlying Properties, during 2023 or 2024.

VOC Brazos has not identified any of the Underlying Properties for sale as of December 31, 2024.

16 unchanged sentences

VOC Brazos and the Trust believe that the recording in the appropriate real property records in Kansas of the net profits interest should constitute the conveyance of a fully vested real property interest, interests in hydrocarbons in place or to be produced or a production payment as such is defined under the United States Bankruptcy Code.

In a bankruptcy of VOC Brazos, creditors of VOC Brazos would be able to

claim the net profits interest as an asset of the bankruptcy estate to satisfy obligations to them if the conveyance of the net profits interest did not constitute the conveyance of a real property interest or interests in hydrocarbons in place or to be produced under applicable state law or a production payment, in which case the Trust would be an unsecured creditor of VOC Brazos at risk of losing the entire value of the net profits interest to senior creditors.

VOC Brazos believes that its title to the Underlying Properties is, and the Trust’s title to the net profits interest is, good and defensible in accordance with standards generally accepted in the oil and gas industry, subject to such exceptions as are not so material to detract substantially from the use or value of such properties or royalty interests.

In a bankruptcy of VOC Brazos, creditors of VOC Brazos would be able to claim the net profits interest as an asset of the bankruptcy estate to satisfy obligations to them if the conveyance of the net profits interest did not constitute the conveyance of a real property interest or interests in hydrocarbons in place or to be produced under applicable state law or a production payment, in which case the Trust would be an unsecured creditor of VOC Brazos at risk of losing the entire value of the net profits interest to senior creditors.

or royalty interests.

Please see “Item 1A.

Risk Factors — The Trust Units may lose value as a result of title deficiencies with respect to the Underlying Properties.”

Risk Factors — Financial Risks — The Trust Units may lose value as a result of title deficiencies with respect to the Underlying Properties.”

Competition and Markets

18 unchanged sentences

In the past, the federal government has regulated the prices at which natural gas could be sold.

While sales by producers of natural gas can currently be made at market prices, Congress could reenact price

controls in the future.

While sales by producers of natural gas can currently be made at market prices, Congress could reenact price controls in the future.

Deregulation of wellhead natural gas sales began with the enactment of the NGPA and culminated in adoption of the Natural Gas Wellhead Decontrol Act which removed all price controls affecting wellhead sales of natural gas effective January 1, 1993.

3 unchanged sentences

The transportation of oil in common carrier pipelines is subject to rate and access regulation.

The FERC regulates interstate oil pipeline transportation rates under the Interstate Commerce Act.

The FERC regulates interstate oil pipeline transportation

rates under the Interstate Commerce Act.

In general, interstate oil pipeline rates must be just and reasonable and may not be unduly discriminatory or confer any undue preference upon any shipper.

18 unchanged sentences

The regulatory burden on the oil and natural gas industry increases the cost of doing business in the industry and consequently affects profitability.

VOC Brazos believes that it is in substantial compliance with all existing environmental laws and regulations applicable to its current

operations and that its continued compliance with existing requirements will not have a material adverse effect on the cash distributions to the Trust unitholders.

VOC Brazos believes that it is in substantial compliance with all existing environmental laws and regulations applicable to its current operations and that its continued compliance with existing requirements will not have a material adverse effect on the cash distributions to the Trust unitholders.

However, the clear trend in environmental regulation is to place more restrictions and limitations on activities that may affect the environment, and thus, any changes in environmental laws and regulations or re-interpretation of enforcement policies that result in more stringent and costly emission or discharge limits or waste handling, disposal or remediation obligations could have a material adverse effect on VOC Brazos’ development expenditures, results of operations and financial position.

24 unchanged sentences

Any such discharge of pollutants into regulated waters must be performed in accordance with the terms of the permit issued by the EPA or the applicable state agency or both.

The discharge of wastewater from most onshore oil and gas activities

exploration and production activities is currently prohibited east of the 98 th meridian.

The discharge of wastewater from most onshore oil and gas activities exploration and production activities is currently prohibited east of the 98 th meridian.

Additionally, in June 2016, the EPA issued a final rule implementing wastewater pretreatment standards that prohibit onshore unconventional oil and natural gas extraction facilities from sending wastewater directly to publicly owned treatment works (“POTW”).

1 unchanged sentence

CWT facilities can either discharge treated water directly to surface waters or send it to a POTW.

In 2018, the EPA concluded a study of the treatment and discharge of oil and gas wastewater that could lead to changes in requirements for discharge of produced water under federal regulations, including more stringent requirements or a prohibition on discharge of produced water from CWT facilities.

In 2018, the EPA concluded a study of the treatment and discharge of oil and gas

wastewater that could lead to changes in requirements for discharge of produced water under federal regulations, including more stringent requirements or a prohibition on discharge of produced water from CWT facilities.

Any restriction of disposal options for hydraulic fracturing waste and other changes to CWA discharge requirements may result in increased costs.

7 unchanged sentences

Shortly thereafter, the Supreme Court issued its decision in Sackett II which overturned a substantial portion of the basis for the 2023 rule.

USACE and the EPA subsequently amended the 2023 rule and excluded a number of types of wetlands and streams from CWA jurisdiction, but the rule is subject to litigation regarding the sufficiency of the agencies’ interpretation of the Sackett II decision.

The USACE and the EPA subsequently amended the 2023 rule and excluded a number of types of wetlands and streams from CWA jurisdiction, but the rule is subject to litigation regarding the sufficiency of the agencies’ interpretation of the Sackett II decision.

The 2023 rule is presently in effect in about half of the states while it is enjoined in the other half.

In those states where the rule is enjoined, the EPA and the USACE define WOTUS in accordance with an earlier regulatory definition adjusted in light of the Supreme Court’s Sackett II decision.

VOC Brazos’ regulatory obligations and permitting costs will continue to be subject to remaining uncertainty around the definition of WOTUS and the scope of CWA regulation, given the ongoing litigation.

1 unchanged sentence

Some NWPs are also used to authorize activities that impact traditional navigable waters under the Rivers and Harbors Act.

The current administration has stated an intention to re-visit NWP 12, which is used to authorize regulated impacts related to construction of oil and gas pipelines, through notice and comment rulemaking before its current expiration date of February 2026.

NWP 12 will expire in March 2026 and be replaced with a new version.

In addition, a federal court in Washington, D.C.

is currently hearing a challenge to NWP 12.

Revisions to NWP 12 by USACE or an adverse decision in Washington, D.C.

may restrict or remove the ability to use NWP 12 to permit regulated impacts, resulting in the need to apply for a more time-consuming individual permit.

An adverse decision in the litigation may restrict or remove the ability to use NWP 12 to permit regulated impacts, resulting in the need to apply for a more time-consuming individual permit.

This could result in additional cost and time for permitting projects.

In February 2025, the USACE began implementing emergency permitting procedures as directed by President Trump’s Executive Order Declaring a National Energy Emergency.

This may result in substantially decreased timeframes for receiving Section 404 permits in the case of energy projects subject to the Executive Order.

The Oil Pollution Act of 1990, as amended (“OPA”), which amends the CWA, establishes standards for prevention, containment and cleanup of oil spills into waters of the United States.

7 unchanged sentences

It is customary to recover oil and natural gas from deep shale and tight sand formations through the use of hydraulic fracturing, combined with sophisticated horizontal drilling.

Hydraulic fracturing involves the injection of water, sand and chemical additives under pressure into rock formations to stimulate gas

The federal Energy Policy Act of 2005 amended the Underground Injection Control provisions of the federal Safe Drinking Water Act to exclude certain hydraulic fracturing activities from the definition of “underground injection.” At present, hydraulic fracturing is regulated at the state and local level.

Hydraulic fracturing involves the injection of water, sand and chemical additives under pressure into rock formations to stimulate gas production.

The federal Energy Policy Act of 2005 amended the Underground Injection Control provisions

of the federal Safe Drinking Water Act to exclude certain hydraulic fracturing activities from the definition of “underground injection.” At present, hydraulic fracturing is regulated at the state and local level.

Due to public concerns raised regarding potential impacts of hydraulic fracturing on groundwater quality, legislative and regulatory efforts at the federal, state and local level and in some states have been initiated to require or make more stringent the permitting and compliance requirements for hydraulic fracturing operations.

13 unchanged sentences

These NSPS apply to sources that are newly constructed or modified after the rules’ applicability dates.

More recently, in December 2023 the EPA adopted a final rule that will directly regulate volatile organic compound and methane emissions from oil and gas sources constructed or modified after December 2022 and will require reductions in both pollutants through its regulation of flaring, compressors, pumps, storage vessels, process controllers, well completions and liquids unloading, and equipment leaks.

More recently, the EPA adopted a final rule in 2024 that will directly regulate volatile organic compound and methane emissions from oil and gas sources constructed or modified after December 2022 and will require reductions in both pollutants through its regulation of flaring, compressors, pumps, storage vessels, process controllers, well completions and liquids unloading, and equipment leaks.

Additionally, the EPA for the first time adopted emissions guidelines that will apply to existing oil and gas sources and that require reductions in volatile organic compound and methane emissions that are largely equivalent to the requirements for new sources.

6 unchanged sentences

State or federal implementation of the NAAQS could result in stricter permitting or regulatory requirements, delay or prohibit VOC Brazos’ ability to obtain such permits, and result in increased expenditures for pollution control equipment.

Although VOC Brazos may be required to incur certain

capital expenditures during the next few years for air pollution control equipment or other air emissions-related issues, at this time VOC Brazos does not expect that such requirements will have a material adverse effect on its operations.

The 2024 presidential election in the United States may impact the air quality-related requirements that apply to VOC Brazos.

The Trump Administration may adopt a different approach to many actions taken

under the prior presidential administration, including the 2024 revisions to the emissions standards and guidelines for new and existing sources in the oil and gas industry, as well as the 2024 changes to the NAAQS for fine particulate matter.

The outcome of the Trump Administration’s evaluation of the prior administration’s regulatory approach is not certain at this time, but President Trump has made it clear that his energy agenda prioritizes an increase in domestic oil and gas production.

VOC Brazos may be required to incur certain capital expenditures for air pollution control equipment or other air emissions-related issues., VOC Brazos currently does not expect that such requirements will have a material adverse effect on its operations.

Climate Change.

In response to findings that emissions of carbon dioxide, methane and other greenhouse gases (“GHGs”) may present an endangerment to public health and the environment, the EPA has issued regulations to restrict emissions of greenhouse gases under existing provisions of the CAA.

These regulations include limits on tailpipe emissions from motor vehicles, preconstruction and operating permit requirements for certain large stationary sources, and methane emissions standards for certain new, modified and reconstructed oil and gas sources — as well as the EPA’s recently adopted methane emissions guidelines for existing oil and gas sources.

In response to its 2009 finding that emissions of carbon dioxide, methane and other greenhouse gases (“GHGs”) may present an endangerment to public health and the environment, the EPA has issued regulations to restrict emissions of greenhouse gases under existing provisions of the CAA.

These regulations include limits on tailpipe emissions from motor vehicles, preconstruction and operating permit requirements for certain large stationary sources, and methane emissions standards for certain new, modified and reconstructed oil and gas sources — as well as the EPA’s methane emissions guidelines for existing oil and gas sources that were adopted in 2024.

The EPA also has adopted rules requiring the reporting of GHG emissions from specified large greenhouse gas emission sources in the United States, as well as certain onshore oil and natural gas production facilities, on an annual basis.

In addition, the EPA has recently proposed rules to implement the mandatory Waste Emissions Charge set forth in the Inflation Reduction Act of 2022 (the “IRA”), which will charge a fee based on the methane emissions from applicable facilities in the oil and gas sector starting in 2024.

The EPA has established pollution control standards for oil and gas sources under the CAA.

In 2012 and 2016, the EPA adopted federal New Source Performance Standards (“NSPS”) that require the reduction of volatile organic compound and sulfur dioxide emissions from certain fractured and refractured natural gas wells for which well completion operations are conducted and further require that most wells use reduced emission completions, also known as “green completions.” These regulations also establish specific requirements limiting emissions from production-related wet seal and reciprocating compressors, pumps, and from pneumatic controllers and storage vessels, and for equipment leaks.

These NSPS apply to sources that are newly constructed or modified after the rules’ applicability dates.

More recently, in December 2023 the EPA adopted a final rule that will directly regulate volatile organic compound and methane emissions from new oil and gas sources and will require further reductions in emissions through its regulation of flaring, compressors, pumps, storage vessels, process controllers, well completions and liquids unloading, and equipment leaks.

On January 20, 2025, President Trump announced the withdrawal of the United States from the Paris Climate Agreement.

President Trump also issued an executive order directing the EPA to review the legality and continuing applicability of its 2009 GHG endangerment finding.

The outcome of that review is not currently known;

however, it has the potential to eliminate the basis for the EPA’s regulation of GHGs under the CAA.

The EPA has established GHG standards for oil and gas sources based on the GHG endangerment finding.

In 2024, the EPA adopted a final rule that will directly regulate volatile organic compound and methane emissions from new oil and gas sources and will require reductions in GHG and volatile organic compound emissions through its regulation of flaring, compressors, pumps, storage vessels, process controllers, well completions and liquids unloading, and equipment leaks.

At the same time, the EPA adopted emissions guidelines that will apply to existing oil and gas sources and that require reductions in volatile organic compound and methane emissions that are largely equivalent to the requirements for new sources.

The existing source emissions guidelines are to be implemented through state plans, with expected compliance dates for existing sources arriving in 2029.

The IRA included new Clean Air Act section 136(c) directing the EPA to collect the Waste Emissions Charge from facilities in the oil and gas sector that report more than 25,000 tons of carbon dioxide equivalent emissions in a calendar year.

The Inflation Reduction Act of 2002 (the “IRA”) included new Clean Air Act section 136(c) directing the EPA to collect the Waste Emissions Charge (“WEC”) from facilities in the oil and gas sector that report more than 25,000 tons of carbon dioxide equivalent emissions in a calendar year.

The charge will first apply to methane emissions from calendar year 2024.

2 unchanged sentences

The program includes key exemptions, most notably a regulatory compliance exemption that applies to and exempts the emissions from facilities that are subject to and in complete compliance with EPA’s new or existing source methane requirements.

The EPA proposed new rules to implement the Waste Emissions Charge program in January 2024.

Additionally, more than one third of the states have begun taking actions to control and/or reduce emissions of GHGs, primarily through the planned development of GHG emission inventories and/or regional GHG cap and trade programs.

Although most of the state level initiatives have to date focused on large sources of GHG emissions, such as coal fired electric plants, it is possible that smaller sources of emissions could become subject to GHG emission limitations or allowance purchase requirements in the future.

In addition, from time to time Congress has considered adopting legislation to reduce emissions of greenhouse gases.

The EPA adopted new rules to implement the WEC program in November 2024;

however, the fate of the WEC and the EPA rules implementing the WEC is unclear.

In February 2025, the United States House of Representatives and Senate both passed resolutions to repeal the EPA’s 2024 WEC rules under the Congressional Review Act (“CRA”), and on March 14, 2025 President Trump signed the resolution repealing those rules under the CRA.

In addition, the United States House of Representatives and Senate may be considering amendment or repeal of certain portions of the IRA, including the statutory provisions establishing the WEC.

In addition to the federal actions, more than one third of the states have begun taking actions to control and/or reduce emissions of GHGs, primarily through the planned development of GHG emission inventories and/or regional GHG cap and trade programs.

Although most of the state level initiatives to date have focused on large sources of GHG emissions, such as coal fired electric plants, it is possible that smaller sources of emissions could become subject to GHG emission limitations or allowance purchase requirements in the future.

For example, the states of Colorado and New Mexico have adopted rules

regulating GHGs from the oil and gas industry that are based on the federal standards.

Congress may in the future consider adopting other legislation to reduce emissions of greenhouse gases.

Any one of these climate change regulatory and legislative initiatives could have a material adverse effect on VOC Brazos’ business, capital expenditures, financial condition and results of operations .

The adoption and implementation of regulations imposing reporting obligations on, or limiting emissions of GHGs from, VOC Brazos’ equipment and operations could require VOC Brazos to incur costs to reduce emissions of GHGs associated with its operations or could adversely affect demand for the oil and natural gas it produces.

Legislation or regulations that may be adopted to address climate change could

also affect the markets for VOC Brazos’ products by making its products more or less desirable than competing sources of energy.

Legislation or regulations that may be adopted to address climate change could also affect the markets for VOC Brazos’ products by making its products more or less desirable than competing sources of energy.

To the extent that its products are competing with higher GHG-emitting energy sources, VOC Brazos’ products may become more desirable in the market with more stringent limitations on GHG emissions.

12 unchanged sentences

Fish and Wildlife Service published a final rule adopting several changes to the federal regulations that implement the ESA, including changes to the procedures and criteria for listing or removing species from the Lists of Endangered and Threatened Wildlife and Plants and for designating critical habitat.

In January 2021, President Biden issued an Executive Order announcing that the new administration would initiate a review of the 2019 amendments to the ESA rules.

The Biden Administration has rescinded one of the rules adopted by the prior administration, dealing with critical habitat, and has issued a proposed rule that would make significant changes to the federal consultation process.

That rule is expected to be finalized by the Biden Administration.

Changes to these rules could make a federal review process occasioned by the application for permits, rights of way, or leases more complex.

The Biden Administration rescinded one of the rules adopted by the prior administration, dealing with critical habitat, and issued a revised rule making changes to the federal consultation process.

These changes could make a federal review process occasioned by the application for permits, rights of way, or leases more complex in certain circumstances.

In addition, designation of new species as threatened or endangered could cause VOC Brazos to incur additional costs arising from species protection measures, could result in limitations on activities, and could require a more complex regulatory compliance process.

In January 2025, the Trump Administration directed the use of the emergency consultation procedures for permitting for energy projects in the Declaring a National Energy Emergency Executive Order.

National Environmental Policy Act.

The National Environmental Policy Act (“NEPA”) requires the federal government to undertake an environmental review prior to making a decision on most proposed federal actions — such as permits, leases, and rights-of-way.

The Trump Administration significantly revised the regulations implementing NEPA in 2020 in an effort to make the review process more efficient and more narrowly tailored to the agency’s specific action.

The Biden Administration undertook an initial revision to the NEPA regulations which were finalized in 2022, essentially reverting to the pre-2020 rule language for a few elements of the rules.

In 2023, the Biden Administration issued a second proposed rule that would make significant changes to the Trump Administration regulations.

The proposed rule is expected to be finalized in April 2024.

In addition, in early 2023 the White House Council on Environmental Quality issued Guidance to the federal agencies on how agencies should consider greenhouse gas emissions and climate impacts in the course of their reviews under NEPA.

Although the Trump Administration regulations were never fully implemented, the Biden Administration changes may have a meaningful impact on federal reviews related to VOC Brazos, especially as those reviews relate to climate and environmental justice.

Until 2025, agencies undertook NEPA reviews pursuant to binding regulations issued by the White House Council on Environmental Quality (“CEQ”) as well as pursuant to the federal agency’s own NEPA procedures.

CEQ issued its rules after being directed to do so by an Executive Order issued in the Carter Administration.

After two federal courts held that CEQ did not have authority to issue binding regulations, the Trump Administration revoked the Carter Administration Executive Order and directed CEQ to withdraw the regulations.

In their place, agencies are directed to develop procedures that hew to the statutory text over the course of 2025 with the goal of having them finalized in early 2026.

In the meantime, agencies will continue to use their own NEPA procedures and may

continue to follow the CEQ regulations, using them as guidance.

This may result in delays and uncertainty in permitting reviews as agencies adjust to a new NEPA approach.

Employee Health and Safety.

The operations of VOC Brazos are subject to a number of federal and state laws and regulations, including the federal Occupational Safety and Health Act, or “OSHA,” and comparable state statutes, whose purpose is to protect the health and safety of workers.

circumstances that information be maintained concerning hazardous materials used or produced in VOC Brazos’ operations and that this information be provided to employees, state and local government authorities and citizens.

In addition, the OSHA hazard communication standard, the EPA community right-to-know regulations under Title III of the federal Superfund Amendment and Reauthorization Act and comparable state statutes require in certain circumstances that information be maintained concerning hazardous materials used or produced in VOC Brazos’ operations and that this information be provided to employees, state and local government authorities and citizens.

VOC Brazos believes that it is in substantial compliance with all applicable laws and regulations relating to worker health and safety.

1 unchanged sentence

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1. Business