Respondent was assessed a civil penalty of $16,175 for six violations of the HMR when it offered for transportation in commerce and transported in commerce detonators, a Class 1 (explosive) material in packagings marked as meeting a UN performance standard in the HMR, when the packagings were not closed in accordance with the manufacturer¿s closure instructions, thus voiding the UN certification (violation No. 1), and were not accompanied by a shipping paper describing the material as required (violation No. 3); represented, marked, and certified DOT specification and special permit cylinders has having been successfully retested and requalified for continued service in accordance with the HMR, when it failed to condemn a DOT-SP 10915 cylinder when the elastic expansion exceeded the rejection elastic expansion (REE) marked on the cylinder (violation No. 2), when it failed to notify PHMSA in writing of changes in management and equipment within 20 days of the changes (violation No. 4), and failed to maintain accurate and complete records of cylinder qualification (violation No. 5), and it allowed its employees to perform functions subject to the requirements in the HMR; and when one employee had not received any hazmat employee training and the other employee had not received function-specific or safety training in the functions he performed (violation No. 6).