The Chief Counsel found that Gladstrong Investment (USA) Corp. committed six violations of the HMR, including offering for transportation in commerce hazardous materials, Lighters, cigarettes, containing flammable gas, UN1057, (1) when Respondent failed to notify a shipper of the applicable requirements of the HMR; (2) when Respondent executed shipping papers that did not contain the DOT approval number; (3) when Respondent listed an emergency response number on its shipping paper, but failed to register with the company who offered the telephone service; (4) when Respondent did not provide its hazardous materials employees with general awareness, function-specific, or safety, hazardous materials training and testing and records were not created and maintained; (5) when Respondent used unauthorized outer packagings; and (6) when Respondent failed to submit the design of the device and the inner packaging for examination and approval. The order withdrew one proposed violation dealing with offering more than 1,001 pounds of the hazardous material and failing register as a hazardous materials shipper due to lack of evidence to support the violation. The Order assessed a civil penalty of $18,965.