Respondent was assessed a civil penalty of $26,985 for eight violations of the HMR when it offered for transportation in commerce and transported in commerce explosive hazardous materials when (1) it failed to register with PHMSA and pay the registration fee; (2) detonators were not packed in accordance with a method approved by DOT; (3) it failed to develop and adhere to a security plan and its hazmat employees had not received in-depth security training; (4) shipping papers did not contain an emergency response telephone number; (5) its hazmat employees had not received general awareness/familiarization or function-specific training; (6) it failed to retain copies of shipping papers for two years; (7) shipping papers did not indicate the net explosive mass of the explosive materials; and (8) it failed to hold a current copy of a special permit authorizing the packaging in which an explosive material was shipped.