The Chief Counsel assessed a civil penalty of $11,300 for two violations of the HMR, including: (1) representing, marking, certifying and selling reconditioned UN standard 1A1 steel drums as meeting the requirements of the HMR, when the packagings were not capable of passing the leakproofness and hydrostatic pressure tests; and (2) representing, certifying and offering reconditioned steel drums marked to the UN 1A1 standard, as meeting the requirements of the HMR, while failing to notify in writing each person to whom that packaging is transferred, of the correct type and dimensions of any closures, including gaskets, needed to satisfy performance test requirements.  The Order details how the Respondent repeatedly provided incorrect closure instructions and how Respondent's packagings failed testing.