On July 23, 2015, Respondent’s mobile well-servicing rig tipped over while its employees were attempting to remove a piece of pipe that had become stuck in an oil well thousands of feet underground. Two employees were seriously injured and another, who was positioned 60 feet up in the derrick, was killed. Complainant assigned Compliance Safety and Health Officer (“CSHO”) Wayne Eyerly and James Nelson, a technical analyst from the OSHA Salt Lake City Technical Center, to perform an inspection of the worksite. CSHO Eyerly and Mr. Nelson arrived at the worksite a week-and-a-half after the accident occurred. Based on CSHO Eyerly’s and Mr. Nelson’s observations and recommendations, Complainant issued a Citation and Notification of Penalty, alleging that Respondent committed a serious violation of 29 U.S.C. § 654(a)(1), also referred to as the general duty clause, with a proposed penalty of $7,000. Respondent timely contested the Citation, which brought the matter before the Occupational Safety and Health Review Commission pursuant to Section 10(c) of the OSH Act.