The Chief Counsel assessed a total civil penalty of $16,685 for six violations of the HMR. Violation 2 Respondent admitted the truck transported hazardous materials when the IBCs were not marked with the identification number for the chemical contents. The 3rd violation is for failure to label or placard the IBCs. Violation 4 Respondent failed to have the product labels in compliance with the HMR. Violation 5 & 6 in compliance with an exception to the requirement to leak test prior to refilling (49 C.F.R. § 173.28(b)(7)) and 49 C.F.R. § 173.28(b)(7)(iii). The inspector observed a jerrican manufactured in 1996, which did not have any markings to indicate the packaging had been leak tested.