The Chief Counsel assessed a civil penalty of $450 for one violation of the HMR:  performing functions subject to the requirements of the HMR while failing to train hazmat employees in general awareness/familiarization training, function-specific training, or security awareness training, and while failing to maintain accurate records of employee training.  The Chief Counsel dismissed three violations related to the requalification of cylinders.  The company performed inspections of DOT specification cylinders (fire extinguishers) pursuant to OSHA regulations.  These testing and certification activities did not constitute requalification under the HMR.  Therefore, Respondent was not required to be an approved requalification facility.