On August 25, 2004, the Office of Chief Counsel issued an (Order) to Aldrich Chemical Company, Inc., (Respondent) finding Respondent had knowingly committed two violations of the Hazardous Materials Regulations (HMR), and assessing a civil penalty in the amount of $12,190. Respondent offered a hazardous material (packing group I, inhalation hazard, zone B) for transportation in commerce in packaging which did not meet the requirements for transporting a toxic by inhalation, hazard zone B material, failed to properly describe the material on its shipping papers, and failed to properly mark and label the packages. Respondent's appeal is denied.