Denaka Partners, LP, d/b/a Home Rubber Co. (Denaka), manufactures rubber products, such as hoses and belts, at its Trenton, New Jersey, facility. On December 18, 2020, an employee was adjusting blade depth on an operating Slitter mill when he lost his balance, and his shirt sleeve caught in the mill, pulling his arm into the mill, and resulting in its amputation. Denaka notified the Occupational Safety and Health Administration (OSHA) of the accident. OSHA assigned Compliance Safety and Health Officer (CSHO) Tracy Townsend to inspect the worksite and, based on her investigation, issued a Citation and Notification of Penalty (Citation) to Denaka on June 14, 2021, alleging serious and willful violations of the Occupational Safety and Health Act of 1970, 29 U.S.C. §§ 651-678 (Act). Denaka timely contested the Citation on July 2, 2021. The Secretary filed a Complaint on September 2, 2021, and Denaka filed its Answer on September 23, 2021. The Secretary filed an Unopposed Motion to Amend the Complaint and Citation on November 7, 2022, to withdraw Citation 1, Item 1, a serious violation of 29 C.F.R. § 1910.219(c)(2)(i), alleging Denaka did not guard the Slitter mill to protect the operator from being caught in the rotating shaft while utilizing the on/off buttons. (Am. Compl., 6.) The Secretary also amended Citation 2, Item 1, which alleges a willful-serious violation of the machine guarding standard at § 1910.212(a)(1), to include the withdrawn serious allegation. Citation 2, Item 1, also alleges Denaka did not guard the Slitter mill’s rotating parts while employees adjusted material on spools and adjusted the depth of knife blades. In Citation 2, Items 2, and 3, the Secretary alleges Denaka violated § 1910.1030(f)(2)(1), by failing to timely offer the Hepatitis B vaccination series to first aid responders, and § 1910.1030(g)(2)(i), for failing to provide an occupational exposure training program to employees assigned to conduct cleanup operations. In the Amended Complaint, the Secretary proposed a penalty of $247,705 reduced to $236,000 in the post-hearing brief. (Am. Compl., 11; Sec’y Post-Hr’g Br. at 25.)