Docket Order: PHMSA-2005-23776

Violations: Unauthorized packagings (UN standard but not rated for high specific gravity) IMDG and HMR require marking packaging certification >1.2 specific gravity Profita contested the proposed violations on the grounds that was an authorized packaging because: 1) tested to higher specific gravity and just not marked 2) acid specific gravity was <1.2 Certification made after inspection by party-in-interest was not persuasive evidence Shipping paper: no UN id, hazard class or PG and unauthorized emergency response number