This proceeding is before the Occupational Safety and Health Review Commission (the Commission) pursuant to section 10(c) of the Occupational Safety and Health Act of 1970, 29 U.S.C. § 659(c) (the Act). This decision consolidates Docket Nos. 19-1054, 19-1056, and 19-1905. At a Respondent worksite in Portland, Maine, on December 13, 2018, a crew of eight roofers worked without fall protection at heights up to thirty-four feet on a steep-pitched roof. In the late morning, one of those roofers, A.L., fell to his death. 1 A few days later, on December 18, 2018, in response to a complaint, OSHA found five members of the same Respondent roofing crew working without fall protection at heights up to fifteen feet at a residence in Old Orchard Beach, Maine. A few months later, on May 23, 2019, OSHA received another complaint of Respondent roofers working without fall protection at a residence in Springvale, Maine. The roofers were exposed to falls from heights up to twenty-one feet. OSHA issued citations for these three inspections on June 11, 2019, and November 19, 2019, for several violations, including lack of fall protection for roofers. For several years before the fatal fall at the December 2018 worksite, Respondent had been cited for violations of the Occupational Safety and Health Administration (OSHA) standard that requires the use of fall protection when a worker is exposed to falls greater than six feet.