On January 18, 2006, the Chief Counsel issued an order to Carbonator Rental Service, Inc. (Respondent) finding Respondent had knowingly committed six violations of the Hazardous Materials Regulations (HMR) and assessing a civil penalty in the amount of $19,210. The Chief Counsel found Respondent - an approved cylinder requalifier -represented, marked and certified cylinders as having been successfully requalified when Respondent: (1) did not test the cylinders, (2) did not verify the accuracy of the testing equipment, (3) failed to maintain current copies of the HMR and applicable CGA pamphlets and failed to notify PHMSA when Respondent changed its testing equipment, (4) failed to maintain its retest records, (5) offered hazardous materials for transportation in commerce accompanied by shipping papers. Respondents appeal was denied.