The Chief Counsel assessed a civil penalty amount of $6,170 for the five 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 registering as an offeror of hazardous materials, in violation of 49 C.F.R. §§ 171.2(a), 107.601 (a)(6), and 107.608(a)-(b); (3) accompanied by a shipping paper that contained an unauthorized emergency response number, in violation of 49 C.F.R. §§ 171.2(a) and 172.604(b); and without retaining a copy of the hazardous materials shipping papers, in violation of 49 C.F.R. §§ 171.2(a) and 172.201(e). Respondent also allowed employees to perform functions subject to the HMR when the employees were not trained and records of training were not created or retained, in violation of 49 C.F.R. §§ 171.2(a), 172.702(b), 172.704(a)(1)-(4), and 172.704(d).