On March 15, 2006, the Chief Counsel, issued an Order to Allbrite Car Care Products, Inc. (Petitioner) finding the company had knowingly committed four violations of the Hazardous Materials Regulations (HMR). The Order assessed a $17,075 civil penalty. Respondent had (1) offered a hazardous material for transportation in commerce in unauthorized, nonspecification packagings (plastic pails); (2) offered a hazardous material for transportation in commerce in used, plastic UN-standard drums, which had not been retested as required; (3) failed to properly prepare shipping papers and to properly mark and label non-bulk packagings; and (4) failed to provide general awareness familiarization, function-specific, and safety training to hazmat employees. Petitioner's appeal is granted.