This proceeding is before the Occupational Safety and Health Review Commission (the Commission) pursuant to § 10(c) of the Occupational Safety and Health Act of 1970, 29 U.S.C. § 659(c) (the OSH Act or the Act). The case involves allegations by the Occupational Safety and Health Administration (OSHA) that Respondent, Barry Billcliff, operating in his individual capacity and/or using fifteen “doing business as” [D/B/A or d/b/a] names identified in the above case caption (Respondent or Mr. Billcliff), was the controlling employer at the Devens SpringHill Suites Marriott Hotel (Devens SpringHill Suites or hotel) and Devens Commons Conference Center (Conference Center) at 31 Andrews Parkway, Devens, Massachusetts (job site or Devens Project) where on October 7, 2021: 1) Respondent did not ensure that frequent and regular inspections were performed by a competent person, 2) a worker was not provided a hard hat, 3) roofers were not protected from falling during unloading of materials on a roof from the ladder hoist, 4) roofers on a steep roof were not protected by fall arrest systems, 5) Respondent did not train its supervisor and subcontractor employees at the job site in the recognition of fall hazards, and 6) a portable ladder did not extend at least three feet above the roof’s edge. Mr. Billcliff denies the allegations and asserts that he was not the controlling employer because he was never at the job site, did not assign or direct any supervisor at the job site, did not have any employee(s) at the job site, did not engage any subcontractor to provide roofers, was not involved in any of the work done at the job site, and never received or deposited any payment for the roofing work performed at the job site.