All-Pro Construction Services, Inc. (All-Pro) performs roofing work on new residences being built by home builders spread over 15 counties in central Florida. On January 31, 2018, and February 2, 2018, the United States Department of Labor’s Occupational Safety and Health Administration (OSHA) initiated inspections of two of All-Pro’s worksites in Odessa, Florida. As a result of the inspections, the Tampa, Florida OSHA Area Director issued two Citations and Notifications of Penalty to All-Pro on April 20, 2018, pursuant to section 9(a) of the Occupational Safety and Health Act of 1970 (the Act), 29 U.S.C. §§ 658(a), 651-678, and the standards promulgated thereunder. Each citation alleged a serious violation of 29 C.F.R. § 1926.501(b)(13) (the Fall Protection standard), and each proposed a penalty of $9,054.