The Chief Counsel assessed a civil penalty of $7,000 for four violations of the HMR. (1) without developing a security plan, in violation of 49 C.F.R. §§ 171.2(a), 172.800, and 172.802; (2) without providing training to its hazmat employees, in violation of 49 C.F.R. §§ 171.2(b), 172.702(a), 172.704(a), and 172.704(c)(1); (3) accompanied by a shipping paper that contained an unauthorized emergency response number, in violation of 49 C.F.R. §§ 171.2(b) & (e), 172.600(c), 172.201(d) and 172.604(b); (4) without signing the required shipper's certification on the shipper paper, in violation of 49 C.F.R.§§ 171.2(a), (b) & (e), and 172.204(a) & (d); and (5) without registering as an offeror of hazardous materials, in violation of 49 C.F.R. §§ 171.2(d), 107.601(a)(6), and 107.608(a)-(b).