The Chief Counsel found that Gladstrong Investment Limited committed two violations of the HMR, including offering for transportation in commerce hazardous materials, Lighters, cigarettes, containing flammable gas, UN1057, (1) when Respondent failed to submit the design of the device and the inner packaging for examination and approval; and (2) when Respondent used packagings that had not been subjected to performance testing and were therefore unauthorized for the transportation of hazardous materials. The Order assessed a civil penalty of $12,600 after a reduction for corrective action.