Respondent was assessed a civil penalty of $11,850 for three violations of the HMR when it offered for transportation in commerce and transported in commerce a large bulk quantity of petroleum gases, liquefied, a Division 2.1 (Flammable Gas) hazardous material, when it had not developed and adhered to a security plan (violation No. 1), it failed to describe the material on a shipping paper as required (violation No. 2), and it allowed employees to perform a function subject to requirements in the HMR when the employees had not received hazardous material employee training (violation No. 3).