Respondent was assessed a civil penalty of $4,685 for three violations of the HMR when it filled metal IBCs meeting the UN31A/Y performance standard in the HMR with nitric acid, a corrosive hazardous material, and offered the filled IBCs for transportation in commerce when it had not performed a periodic inspection of the minimum wall thickness of the IBCs within the past 5 years (violation No. 1); represented, marked, and certified that IBCs had been successfully retested in accordance with the HMR, when it failed to maintain complete records of periodic inspection and retest (violation No. 2); and allowed employees to perform inspections and retesting of IBCs, a function subject to requirements in the HMR, when the employees had not received function-specific training within the past three years (violation No. 3).