Like many of its older-built facilities, the United States Postal Service’s (“USPS” or “Respondent”) East Portland Station, located at 1020 SE 7th Avenue, Portland, OR (“EP Station” or “Station”), was constructed using asbestos-containing materials (“ACMs”). (Tr. 96, 570, 614, 785; Exs. C-34, at 11, 20, 24-28; R-24, at 5). Particularly, the original floor planks installed throughout much of the ground floor were confirmed to contain asbestos. (Tr. 349, 538-40, 570, 785, 798; Exs. C-7, at 2; C-34, at 24-26; R-24, at 5). Additionally, some fire and vault doors throughout the Station were made of presumed asbestos-containing materials (“PACMs”). (Tr. 98, 785-86; Ex. C-34, at 5 & 6).

In December of 2022, the United States Occupational Safety Health Administration (“OSHA”) received several asbestos-related complaints for USPS-owned or operated facilities in the Portland, Oregon area, including the EP Station. (Tr. 42-43, 93-94, 179-80; Exs. C-1, C-10, C-12, at 1). As to the EP Station, OSHA received a complaint that the flooring in the facility was not being properly maintained and further that the Station’s employees were not being properly trained on the presence of asbestos or how to mitigate exposure to it. (Tr. 42-43; Exs. C-1, C-12, at 2).