Respondent was assessed a civil penalty of $15,500 for three violations of the HMR when it offered for transportation in commerce compressed gas cylinders containing a Division 2.2 nonflammable gas, a hazardous material, having an aggregate gross weight greater than 1,001 pounds, and it was required to affix placards to its vehicle, when it had not registered with PHMSA and paid the registration fee (violation No. 1); when the cylinders were not marked or labeled as containing a hazardous material, were not accompanied by a shipping paper describing a hazardous material, and Respondent's vehicle was not placarded to indicate the presence of a hazardous material, making this a shipment of an undeclared hazardous material (violation No. 2); and when it represented and certified that a compressed gas cylinder had been retested and requalified for continued service when it failed to maintain an accurate record of the pressure at which the cylinder was retested (violation No. 3).