Respondent was assessed a civil penalty of $16,350 for two violations of the HMR, when it offered lithium batteries, a Class 9 hazardous material, for transportation in commerce when the batteries were not declared as a hazardous material, because the outer packaging was not marked or labeled to indicate the presence of a hazardous material, and the batteries were not described as a hazardous material on a shipping paper, and it allowed its employee to perform a function subject to the requirements in the HMR, when the employee had not received hazmat employee training.