U.S. Department 

of Transportation 

Federal Aviation 

Administration 

nn-AR TMENT OF 

:3P0f 

, ~i^^;i:Q0W?iQf the Regional Counsel 

P.O. Box 20636 

Atlanta, Georgia 30320 

(404) 305-5200 

(404)305-5223 FAX 

MAR 0 9 2011 

CERTIFIED - RETURN RECEIPT REQUESTED 

Hearing Docket Clerk 

FAA, AGC-430, Suite 2W1000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

eiVED 

M A ' 15 2011 

HEARING DOCKET 

Re: In the Matter of Ed Staub Sons Petroleiim, Inc. I 

FAA Case No. 2010SO700080 U(^^ ^ , ^gj ^ Cf P H I ^ ^ If^ ^ ^ ^ H-tj^ M 

Enclosed herewith please find a copy of a request for hearing and the original and one copy of 

the Complaint in the above-referenced proceeding. 

The FAA requests that the hearing in this matter be held in the Louisville, Kentucky area, and 

expects that the hearing will last one day. The Agency's witness and witnesses from UPS reside 

in Kentucky. 

Please address all communications for the FAA to the undersigned, at: 

Federal Aviation Administration 

Office of the Regional Counsel, ASO-7 

Southern Region 

P.O. Box 20636 

Atlanta, Georgia 30320 

Telephone: (404) 305-5200, facsimile (404) 305-5223. 

Sincerely, 

GERALD A. ELLIS 

Attorney 

Office of the Regional Counsel 

Enclosures 
Rusty Rinehart 

Ashley Polston 

RINEHART LAW OFFICES 

Attorneys and Counselors at Lau 

2105 S. Bascom Avenue. Suite 340 

Campbell, California 95008 

Email: rusty@rinehartlaw.com 

Telephone: (408) 871-2696 

Facsimile: (408)871-2757 

Hearing Docket 

FAA 

AGC-400 

Room 214 

600 hidependence Ave., S.W. 

Washington D.C. 20591 

Eddie L. Thomas 

Gerald A. Ellis 

Office of the Regional Counsel 

P.O. Box 20636 

Atlanta, Georgia 30320 

Februar>'23, 20n 

r C T REC'EIVET 

•'soUrHLkN REGION 

RE: Ed Staub & Sons, Inc. 

2010S0700080 

Dear Sir: 

Enclosed is a re-send of a request for hearing in the above referenced matter. The earlier request 

failed to include a signature for the Respondent. 

VentTruly Yo 

RUSTY RINEHART 

RR:km 

CC: Ed Staub & Sons, Inc. 
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U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

ED STAUB & SONS PETROLEUM, INC. 

Respondent. 

FAA Docket No. 

Judge 

JUDGE NOT YET ASSIGNED 

COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice (14 C.F.R. 13.208), and states as follows: 

I. 

1. On February 10, 2011, Respondent, Ed Staub & Sons Petroleum, Inc was advised 

through a Final Notice of Proposed Civil Penalty that the FAA proposed to assess a civil penalty 

in the amount of $91,500. On February 23, 2011, the Agency Attorney received a written 

request for a hearing from the Respondent. 

II. 

2. At all times material herein on or about December 22, 2009, Ed Staub & Sons 

Petroleum, Inc. (Ed Staub) knowingly offered to United Parcel Services (UPS) a one-piece 

shipment consisting of a fiberboard box containing hazardous materials for transportation by air. 

3. The above-mentioned shipment was assigned UPS 3-Day Select tracking 

number/air waybill number IZ 60X 226 12 4554 8216. The shipment was offered by Bob Hays, 

Ed Staub &. Sons Petroleum, Inc., 136350 Highway 97 North Crescent, Oregon 97733, for 

transportation to the consignee, Robert Eacott, Staveley Services, Cleveland, Ohio 44112. 
4. At all times mentioned herein, the above-mentioned shipment was not 

accompanied by a Shipper's Certification or Declaration of Dangerous Goods. 

5. On or about December 23, 2009, respecfively, the above-mentioned shipments 

were flown on a regularly scheduled UPS cargo flight in air transportation to the UPS sort 

facility in Louisville, Kentucky. 

6. On or about December 23, 2009, ground-handling personnel at the UPS sort 

facility discovered the above-mentioned when the package was retaped. 

7. The above-mentioned fiberboard box contained one 24-ounce metal container of a 

Valvtec Petroleum Products Sample Container (with metal /screw-top lids) containing a 

petroleum product. 

8. (a) The above-described petroleum product is classified as a hazardous 

material under the Department of Transportation Hazardous Materials Regulations (HMR) (49 

C.F.R. §172.101). 

(b) The proper shipping name of the material is Flammable Liquid, n.o.s. 

(petroleum distillates, kerosene). It is in Hazard Class 3 (Flammable Liquid), Packing Group III, 

and has an assigned identification number of UN 1993. The proper label is FLAMMABLE 

LIQUID. 

9. Ed Staub offered the above-described shipment of hazardous material for 

transportation by air without shipping papers that included: 

(a) the assigned identification number prescribed for each hazardous material; 

(b) the proper shipping name prescribed for each hazardous material; 

(c) the hazard class prescribed for each hazardous material; 

(d) the packing group prescribed for each hazardous material; 

(e) the total net mass per package of each hazardous material; and, 

(f) the number and type of packages containing hazardous material. 

10^ EdStaub^ffered the^bove=described^shipment-oFhazardous^material-for 

transportation by air and failed to: 

(a) certify that the materials were in accordance with the HMR (49 C.F.R. §§ 

171, et seq.) by printing on the shipping papers the certification set forth in § 172.204(a)(1), 

172.204(a)(2), or § 172.204(c) of the HMR; 

(b) prepare the required certifications in duplicate; and. 
(c) add to the certification required in this section the following statement: 

"I declare that all of the applicable air transport requirements have 

been met." 

11. Ed Staub offered the above-described shipment of hazardous materials for 

transportation by air when: 

(a) the outer container was not marked with the proper shipping name of each 

hazardous material contained therein; 

(b) the outer container was not marked with the assigned identification 

number of each hazardous material contained therein; 

(c) the outer container was not marked with standard orientation markings (as 

prescribed in 49 C.F.R. §172.312(a)) on two opposite vertical sides of the package with the 

arrows pointing in the correct upright direction; and 

(c) a "FLAMMABLE LIQUID" label was not affixed to the outer container. 

12. Ed Staub offered the above-described shipment of hazardous material for 

transportation by air and failed to make emergency I'esponse information available for use at all 

times the hazardous material was present. 

13. Ed Staub offered the above-described shipment of hazardous material for 

transportation by air and failed to make an emergency response telephone number immediately 

available to the appropriate official person designated to respond to an incident involving a 

hazardous material, or who was conducting an investigation involving a hazardous material. 

14. Ed Staub offered the above-described combination package of hazardous 

materials for transportation by air when the inner packagingswere not packed, secured, and 

cushioned to prevent their breakage or leakage and to control their movement within the outer 

packaging under conditions normally incident to transportation. 

15. Ed Staub offered the above-described shipment of liquid hazardous materials for 

transportation by air and failed to use an authorized combination packaging for its transportation. 

III. 

16. By reason of the above, Ed Staub & Sons Petroleum, Inc. violated the following 

Department of Transportation Hazardous Materials Regulations (Title 49 of the Code of Federal 

Regulations); 

a. Section 171.2(e) in that Ed Staub offered or transported a hazardous material for 

transportation in commerce when the hazardous material was not properly classed, described, 
packaged, marked, labeled, and in condition for shipment as required or authorized by applicable 

requirements of this subchapter, or an exemption, approval, or registrafion issued under this 

subchapter or under subchapter A of this chapter. 

b. Sections 172.200(a) and 172.202(a)(1) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

including the identification number prescribed for the material as shown in Column 4 of the § 

172.101 Table, in the manner required by this subpart. 

c. Sections 172.200(a) and 172.202(a)(2) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

including the proper shipping name prescribed for the material as shovm in Column 2 of the § 

172.101 Table. 

d. Sections 172.200(a) and 172.202(a)(3) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

including the hazard class or division number prescribed for the material as shown in Column 

3 of the § 172.101 Table.. 

e. Sections 172.200(a) and 172.202(a)(4) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

including the packing group in Roman numerals, as designated for the hazardous material in 

Column 5 of the § 172.101 Table. 

f Sections 172.200(a) and 172.202(a)(6) in that Ed Staub offered a hazardous 

material for transportation by aircraft and failed to describe the hazardous material on shipping 

papers showing the total mass per package, unless a gross mass is indicated in Columns (9A) or 

(9B) of the § 172.101 Table in which case the total gross mass per package must be shown; or, 

for Class 7 materials, the quantity of radioactive must be shown by activity. 

g. Sections 172.200(a) and 172.202(a)(7) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

indicating the number and type of packages (for example, "12 drums"). 

h. Sections 172.204(a) or (c)(1) in that Ed Staub offered a hazardous material for 

transportation and failed to certify that the material was offered for transportation in accordance 

with this subchapter by prinfing on the shipping paper containing the required shipping 

description one of the certifications set forth in this part. 

i. Section 172.204(c)(2) in that Ed Staub offered a hazardous material to an aircraft 

operator for transportation by air and failed to provide two copies of the certification required in 

this section. 

j . Section 172.204(c)(3) in that Ed Staub offered for transportation by air a 

hazardous material authorized for air transportation and failed to add to the certification required 

in this section the following statement: 
"I declare that all of the applicable air transport requirements have been met." 

k. Section 172.301(a) in that Ed Staub offered for transportation a hazardous 

material in a non-bulk packaging and failed to mark the package with the proper shipping name 

and identification number (preceded by "UN" or "NA", as appropriate) for the material as shown 

in the §172.101 table. 

1. Secfions 172.300(a) and 172.312(a)(2) in that Ed Staub offered a non-bulk 

combination package having inner packagings containing liquid hazardous material for 

transportation and failed to legibly mark the outer package with package orientation markings 

that conform pictorially to ISO Standard 780-1895, on two opposite vertical sides of the package 

with the arrows pointing in the correct upright direction. 

m. Section 172.400(a) in that Ed Staub offered for transportation a hazardous 

material in one of the packages or containment devices listed in this subpart and failed to label 

the package or containment device with the labels specified for the material in the §172.101 

Table and in this subpart. 

n. Section 172.600(c)(1) in that Ed Staub offered for transportation a hazardous 

material and failed to make the emergency response information conforming to this subpart 

immediately available for use at all times the hazardous material was present. 

0. Section 172.600(c)(2) in that Ed Staub offered for transportation a hazardous 

material and failed to make emergency response information including the emergency response 

telephone number, immediately available to any government agency responding to an incident 

involving hazardous materials or conducting an investigation which involves a hazardous 

material. 

p. Section 173.24a(a)(3) in that Ed Staub failed to ensure that inner packagings of 

combination packagings were sufficiently packed, secured, and cushioned to prevent their 

breakage or leakage and to control their movement within the outer packaging under conditions 

normally incident to transportation. 

q. Section 173.203 in that Ed Staub offered for transportation a package containing 

liquid hazardous material in Packing Group III when §172.101 of this subchapter specified that 

it be packaged under this section and failed to use non-bulk packagings prescribed in this section 

conforming to the general packaging requirements of subpart B of part 173, to the requirements 

"ofpaiTl 78"o^rthis^ubdraptera[t"the~PacMng GroupT^^^^^ 

requirements of the special provisions of Column 7 of the §172.101 Table. 
IV 

1. On or about December 29, 2009, Ed Staub & Sons Petroleum, Inc. (Ed Staub) 

knowingly offered to United Parcel Services (UPS) a one-piece shipment consisting of a 

fiberboard box containing hazardous materials for transportation by air. 

2. The above-mentioned shipment was assigned UPS 3-Day Select tracking 

number/air waybill number IZ 60X 226 12 4476 5313. The shipment was offered by Bob Hays, 

Ed Staub & Sons Petroleum, Inc., 136350 Highway 97 North Crescent, Oregon 97733, for 

transportation to the consignee, Robert Eacott, Staveley Services, Cleveland, Ohio 44112. 

3. At all times mentioned herein, the above-mentioned shipment was not 

accompanied by a Shipper's Certification or Declaration of Dangerous Goods. 

4. On or about December 30, 2009, the above-mentioned shipment was flown on a 

regularly scheduled UPS cargo flight in air transportation to the UPS sort facility in Louisville, 

Kentucky. 

5. On or about December 30, 2010, ground-handling personnel at the UPS sort 

facility discovered the above-mentioned shipment leaking, exhibiting a stain, and giving off a 

strong odor. 

6. The above-mentioned fiberboard box contained one 24-ounce metal container of a 

Valvtec Petroleum Products Sample Container (with metal /screw-top lids) containing a 

petroleum product. 

7. Further investigation showed that approximately 4 ounces of the above-described 

material had leaked into and through the fiberboard container. 

8. (a) The above-described petroleum product is classified as a hazardous 

material under the Department of Transportation Hazardous Materials Regulations (HMR) (49 

C.F.R. § 172.101). 

(b) The proper shipping name of the material is Flammable Liquid, n.o.s. (petroleum 

distillates, kerosene). It is in Hazard Class 3 (Flammable Liquid), Packing Group III, and has an 

assigned identification number of UN 1993. The proper label is FLAMMABLE LIQUID. 

9. EdStaub offeredlhe^bov^RJescribed shipmentrofiiazardous materiaLfor 

transportation by air without shipping papers that included: 

(a) the assigned identification number prescribed for each hazardous material; 

(b) the proper shipping name prescribed for each hazardous material; 

(c) the hazard class prescribed for each hazardous material; 
(d) the packing group prescribed for each hazardous material; 

(e) the total net mass per package of each hazardous material; and, 

(f) the number and type of packages containing hazardous material. 

10. Ed Staub offered the above-described shipment of hazardous material for 

transportation by air and failed to: 

(a) certify that the materials were in accordance with the HMR (49 C.F.R. §§ 

171, et seq.) by printing on the shipping papers the certification set forth in § 172.204(a)(1), 

172.204(a)(2), or § 172.204(c) of the HMR; 

(b) prepare the required certifications in duplicate; and, 

(c) add to the certification required in this section the following statement: 

"I declare that all of the applicable air transport requirements have 

been met." 

11. Ed Staub offered the above-described shipment of hazardous materials for 

transportation by air when: 

(a) the outer container was not marked with the proper shipping name of each 

hazardous material contained therein; 

(b) the outer container was not marked with the assigned identification 

number of each hazardous material contained therein; 

(c) the outer container was not marked with standard orientation markings (as 

prescribed in 49 C.F.R. §172.312(a)) on two opposite vertical sides of the package with the 

arrows pointing in the correct upright direction; and 

(d) a "FLAMMABLE LIQUID" label was not affixed to the outer container. 

12. Ed Staub offered the above-described shipment of hazardous material for 

transportation by air and failed to make emergency response information available for use at all 

times the hazardous material was present. 

13. Ed Staub offered the above-described shipment of hazardous material for 

transportation by air and failed to make an emergency response telephone number immediately 

available to the appropriate official person designated to respond to an incident involving a 

hazardous material, or who was conducting an investigation involving a hazardous material. 
14. Ed Staub offered the above-described shipment of hazardous material for 

transportation by air when the packaging was not designed, constructed, maintained, filled, its 

contents so limited, and closed, so that under conditions normally incident to transportation, 

there would be no identifiable release of hazardous material to the environment. 

15. Ed Staub offered the above-described combination package of hazardous 

materials for transportation by air when the inner packagings were not packed, secured, and 

cushioned to prevent their breakage or leakage and to control their movement within the outer 

packaging under conditions normally incident to transportation. 

16. Ed Staub offered the above-described shipment of liquid hazardous materials for 

transportation by air and failed to use an authorized combination packaging for its transportation. 

V. 

17. By reason of the above, Ed Staub violated the following Department of 

Transportation Hazardous Materials Regulations (Title 49 of the Code of Federal Regulations): 

a. Section 171.2(e) in that Ed Staub offered or transported a hazardous material for 

transportafion in commerce when the hazardous material was not properly classed, described, 

packaged, marked, labeled, and in condition for shipment as required or authorized by applicable 

requirements of this subchapter, or an exemption, approval, or registration issued under this 

subchapter or under subchapter A of this chapter. 

b. Sections 172.200(a) and 172.202(a)(1) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

including the identification number prescribed for the material as shown in Column 4 of the § 

172.101 Table, in the manner required by this subpart. 

c. Sections 172.200(a) and 172.202(a)(2) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

including the proper shipping name prescribed for the material as shown in Column 2 of the § 

172.101 Table. 

c. Sections 172.200(a) and 172.202(a)(3) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

including the hazard class or division number prescribed for the material as shown in Column 

3 of the § 172.101 Table.. 

d. Sections 172.200(a) and 172.202(a)(4) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

including the packing group in Roman numerals, as designated for the hazardous material in 

Column 5 of the § 172.101 Table. 

e. Sections 172.200(a) and 172.202(a)(6) in that Ed Staub offered a hazardous 

material for transportation by aircraft and failed to describe the hazardous material on shipping 
papers showing the total mass per package, unless a gross mass is indicated in Columns (9A) or 

(9B) of the § 172.101 Table in which case the total gross mass per package must be shown; or , 

for Class 7 materials, the quantity of radioactive must be shown by activity. 

f Sections 172.200(a) and 172.202(a)(7) in that Ed Staub offered a hazardous 

material for transportation and failed to describe the hazardous material on shipping papers 

indicating the number and type of packages (for example, "12 drums"). 

g. Sections 172.204(a) or (c)(1) in that Ed Staub offered a hazardous material for 

transportation and failed to certify that the material was offered for transportation in accordance 

with this subchapter by printing on the shipping paper containing the required shipping 

description one of the certifications set forth in this part. 

h. Section 172.204(c)(2) in that Ed Staub offered a hazardous material to an aircraft 

operator for transportation by air and failed to provide two copies of the certification required in 

this section. 

i. Section 172.204(c)(3) in that Ed Staub offered for transportation by air a 

hazardous material authorized for air transportation and failed to add to the certification required 

in this section the following statement: 

"I declare that all of the applicable air transport requirements have been met." 

j . Section 172.301(a) in that Ed Staub offered for transportation a hazardous 

material in a non-bulk packaging and failed to mark the package with the proper shipping name 

and identification number (preceded by "UN" or "NA", as appropriate) for the material as shown 

in the §172.101 table. 

k. Sections 172.300(a) and 172.312(a)(2) in that Ed Staub offered a non-bulk 

combination package having inner packagings containing liquid hazardous material for 

transportation and failed to legibly mark the outer package with package orientation markings 

that conform pictorially to ISO Standard 780-1895, on two opposite vertical sides of the package 

with the arrows pointing in the correct upright direction. 

1. Section 172.400(a) in that Ed Staub offered for transportation a hazardous 

material in one of the packages or containment devices listed in this subpart and failed to label 

the package or containment device with the labels specified for the material in the §172.101 

Table and in this subpart. 

m. Section 172.600(c)(1) in that Ed Staub offered for transportation a hazardous 

material and failed to make the emergency response information conforming to this subpart 

immediately available for use at all times the hazardous material was present. 

10 
n. Section 172.600(c)(2) in that Ed Staub offered for transportation a hazardous 

material and failed to make emergency response information including the emergency response 

telephone number, immediately available to any government agency responding to an incident 

involving hazardous materials or conducting an investigation which involves a hazardous 

material. 

0. Section 173.24(b)(1) in that Ed Staub failed to use a package which was designed, 

constructed, maintained, filled, its contents so limited, and closed, so that under conditions 

normally incident to transportation, there would be no identifiable (without the use of 

instruments) release of hazardous material to the environment. 

p. Section 173.24a(a)(3) in that Ed Staub failed to ensure that inner packagings of 

combination packagings were sufficiently packed, secured, and cushioned to prevent their 

breakage or leakage and to control their movement within the outer packaging under conditions 

normally incident to transportation. 

q. Section 173.27(d) in that Ed Staub offered a package for transportation by air 

failed to ensure stoppers, corks or other such friction-type closures were held securely, tightly 

and effectively in place by positive means, and that each screw-type closure on any packaging 

was secured to prevent closure from loosening due to vibration or substantial change in 

temperature. 

r. Section 173.203 in that Ed Staub offered for transportation a package containing 

liquid hazardous material in Packing Group III when §172.101 of this subchapter specified that it 

be packaged under this section and failed to use non-bulk packagings prescribed in this section 

conforming to the general packaging requirements of subpart B of part 173, to the requirements 

of part 178 of this subchapter at the Packing Group I, II or III performance level, and to the 

requirements of the special provisions of Column 7 of the §172.101 Table. 

18. Pursuant to 49 U.S.C. Section 5123(a), Respondent is subject to a civil penalty 

not lower than $250 ($450 for training-related violations), nor greater than $50,000 ($100,000 if 

death, serious illness, severe injury, or substantial property damage results), for each violation of 

the Department of Transportation Hazardous Materials Regulations. 

19. Under the facts and circumstances of this case, a civil penalty of $91,500 is 

appropriate. The reduced amount includes consideration of all the information presented to the 

FAA and any corrective action implemented as a result of the above allegations. 

11 
WHEREFORE, the Agency, by counsel respectfully requests that the Administrative Law Judge 

enter an order that Respondent be assessed a civil penalty in the amount of $91,500 . 

Respectfully submitted this day of March, 2011. 

GERALD A. ELLIS 

Attorney 

Office of the Regional Counsel 

PLEASE NOTE; 

Pursuant to Title 14 CFR Section 13.209(a), you are required to file a written answer to this 

Complaint, or a written Motion to Dismiss if appropriate, not later than 30 days after the date 

shown on the Certificate of Service which follows. 

12 
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Complaint has been mailed this date by Certified 

Mail, Return Receipt Requested, to the following: 

David Staub 

Ed Staub 8L Sons Petroleum 

1440 N. 4'''Street 

Lakeview, OR 97630 

Ed Staub & Sons Petroleum 

136350 Highway 97 North 

Crescent, OR 97733 

Rusty Rinehart, Esq. 

Rinehart Law Offices 

2150 S. Bascom Avenue 

Suite 340 

Campbell, CA 95008 

ADDRESS IF SENDING BY US MAIL 

Hearing Docket Clerk (original + 1 copy) 

FAA, AGC-430, Suite 2W1000 

Wilbur Wright Building 

800 Independence Avenue, SW 

Washington, DC 20591 

TiFFANj M] MCDOWEL L 

LegJi|^^^*i!sistaritl 

Office of the Regional Counsel 

MAR 0 8 20JJ 

Dated 

13