Equipment Trade Services

Decision paragraph 1Docket Order: PHMSA-2013-0189Respondent was assessed a civil penalty of $18,825 for seven violations of the HMR when it offered for transportation in commerce and transported in commerce corrosive liquid hazardous materials, in UN intermediate bulk containers (IBCs) and discharged the material from the IBCs without offloading the IBCs from the transport vehicle, when its authority to perform this activity under DOT-SP 12412 had expired (violation No. 1); in UN performance standard IBCs which it filled, offered for transportation in commerce, and transported in commerce, when the prescribed periodic tests and inspections were past due (violation No. 3); in plastic tanks which were not authorized for these materials because the tanks were not marked as meeting an authorized UN performance standard in the HMR (violation No. 4), and which were not marked with the proper shipping name and identification number for these materials and to which hazard warning labels were not affixed (violation No. 8); in combination packagings marked as meeting the UN4G performance standard in the HMR, when the inner containers were not closed in accordance with the packaging manufacturers closure instructions, thus voiding the UN certification (violation No. 5); it failed to retain copies of shipping papers for two years (violation No. 7); and it allowed employees to perform function subject to requirements in the HMR when the employees had not received the required hazmat employee training (violation No. 6).#