According to the FAA, Dover allegedly offered the material even though it was not packaged, marked, classed, described, labeled or in condition for shipment as required by regulations. UPS workers at the carriers sorting hub in Louisville, Ky., discovered the shipment because it had leaked.

According to Dover, sulfur monochloride is a raw material used by the company in low volume in a few metalworking fluids, which comprise a small component of its lubricants product line.

Dover said it is currently in discussions with the FAA regarding the incident. The company has investigated this incident internally and has put actions in place to improve processes to prevent a re-occurrence, the company told Lube Report. The corrective actions include, but are not limited to: Mandatory retraining so employees fully understand Department of Transportation requirements for shipping hazardous materials, additional procedures to ensure new employees are fully trained before taking on any assignment that involves shipping hazardous materials, procedures for identifying hazardous materials, and procedures for packaging and documenting sample-sized containers.

The company requested an informal conference to discuss the case, FAA spokeswoman Kathleen Bergen confirmed to Lube Report, adding that the case is still pending.

When the FAA proposes a civil penalty, Bergen said, the normal process is for the company to request an informal conference to discuss the case and provide any clarifying information. Sometimes cases are settled at the conference. If not, FAA attorneys review the information provided by the company, then issue a final Notice Assessing Civil Penalty. The company can appeal the final notice to the Department of Transportation. A DOT administrative law judge would then hear the appeal.