Along Interstate 45 in Houston, Texas, at the intersection of the highway and Dixie Farm Road, Respondent, Williams Brothers Construction Co., Inc. (“Williams Brothers”) operates a concrete plant known as the Dixie Farm Cement Plant (“Dixie Plant” or “Plant”). (Exhs. J-4, at 4; J-19, at 5; Tr. 27, 71-72, 105, 137). The Dixie Plant is one of approximately 30 concrete plants located throughout Texas where Williams Brothers mixes concrete for highway construction. (Exhs. J-5, at 1; J-20, at 3; Tr. 105-106, 135). On March 17, 2022, three Williams Brothers employees, a “plant operator,” a “load operator” and a “laborer” were mixing concrete at the Dixie Plant. (Exhs. J-5, at 1; J-21, at 1; Tr. 28, 51, 138). At some point in the day, the employees heard a noise coming from a “bearing” on the Plant’s conveyor. (Exhs. J-5, at 1; J-20, at 1-2; J-21, at 1; Tr. 27, 49, 53, 107, 120-21, 145-46). To investigate the source of the noise, the plant operator and the two other employees traversed the Plant’s sloped conveyor to get onto the platform of a caged ladder attached to the side of the Plant’s dust collector. (Exhs. J-5, at 1; J-10, at 2-5, 8-10; J-12, at 2, 3, 17-19, 21, 33; J-20, at 1-2; Tr. 32, 49, 51, 54-55). Although a portion of the sloped conveyor and the caged ladder’s platform were above six feet from the ground, none of the employees used any form of fall protection while inspecting the bearing. (Exhs. J-5, at 1; J-10, at 1-6; Tr. 31-35, 150).