Following a worker injury, the Occupational Safety and Health Administration (OSHA), commenced investigations of two employers who had been working at a construction site located along Pottstown Pike in West Chester, Pennsylvania. The investigation led to citations being issued to Brubacher Excavating, Inc. (Brubacher) and Traffic Control Services, LLC, which does business as Flagger Force (Flagger Force). (Stip. 6.) Brubacher and Flagger Force both filed timely challenges to the citations with the Occupational Safety and Health Review Commission (Commission). Brubacher’s challenge was assigned docket No. 18-0033 and Flagger Force’s challenge was docketed as No. 18-0019. Because of the similarity of the underlying facts, Brubacher and Flagger Force’s cases were consolidated for review.