Respondent was assessed a civil penalty of $8,900 for two violations of the HMR when it represented, marked, certified and sold remanufactured open-head steel drums as meeting the UN1A2 performance standard in the HMR when design qualification testing and production leakproofness testing had not been performed as required (violations Nos. 1 & 2, combined), and it allowed employees to perform functions subject to the HMR when records of hazmat employee training were not created and retained (violation No. 3).