On April 13, 2016, Complainant conducted an inspection of Respondent after Compliance Safety and Health Officers (CSHOs) James Messer and Ryan Morton drove by Respondent’s jobsite, located at 304 East Lake Circle, Billings, Montana, and observed four employees engaged in residential roofing activity without the use of fall protection. (Tr. 31; Ex. 3 at 4). As a result of this inspection, Complainant issued a single-item Citation and Notification of Penalty, alleging Respondent failed to use adequate fall protection. Complainant proposed a penalty of $27,436 for the Citation, which was issued on September 16, 2016. Respondent timely contested the Citation.