Respondent was assessed a civil penalty of $4,253 for three violations of the HMR, when it represented, marked, and certified steel and plastic drums as having been reconditioned in accordance with the HMR, when the drums had not been leakproofness tested as required (violation No. 1); the drums were not marked as required (violation No. 2); and Respondent¿s employees that performed functions subject to requirements in the HMR had not been trained as required (violation No. 3).