Respondent was assessed a civil penalty of $11,300 for violations of the HMR when it manufactured, marked, and certified steel pails as meeting a UN performance standard in the HMR for use in transportation of hazardous material when design qualification testing of the drum design types had not been performed (violation No. 1), and it marked and certified steel pails as having removable heads and meeting a UN performance standard in the HMR for use in transportation of hazardous material when the pails had non-removable heads.