Docket Order: PHMSA-2011-0207

Respondent was assessed a civil penalty of $15,925 for five violations of the HMR when it represented, marked, certified, and offered steel drums marked "UN1A1/Y1.2/ 100/USA/M5283/06/08/RL" as having been reconditioned in accordance with the HMR, when the drums had not been cleaned to the base metal (violation No. 1); represented, marked, and certified polyethylene drums marked, in part, "UN1H1" as qualified for reuse in accordance with the HMR, when the drums were not marked with their minimum thickness (violation No. 2); represented, marked, and certified IBCs marked, in part, "UN31HA1" as qualified for reuse in accordance with the HMR, when (1) the leakproofness test was not performed as required, (2) it failed to repair structural damage to one IBC, (3) the IBCs were not marked as required, and (4) it failed to maintain accurate and complete records of inspection and testing (violation No. 3); represented and sold steel and polyethylene drums and IBCs marked as meeting the UN performance standards in the HMR without retaining copies of its written notification to its customers of all requirements in the HMR that were not met at the time of transfer of the packagings (violation No. 4); and allowed employees to perform functions subject to requirements in the HMR, when the employees had not received security awareness training and records of general awareness/familiarization and function-specific training were not created and retained (violation No. 5).