The Chief Counsel found that Price Research Ltd committed four violations of the HMR, including offering a hazardous material (Hydrochloric Acid Solution, 8, UN 1789, PG 11) for transportation in commerce, (1) when it packaged the materials in non-bulk combination packaging that had not been subjected to UN qualification testing and certification, and were therefore not authorized for the shipment of hazardous materials; (2) when it packaged the materials in 55-gallon drums and failed to close the drums in accordance with the manufacturer’s closure instructions; (3) when the hazardous materials employees had not received recurrent general awareness, function-specific, and safety training; and (4) when it failed to sign the shipper's certification. The Order assessed a civil penalty of $6,900 after reductions for corrective actions and the company's status as a small business entity.