On July 30, 2018, DeNucci Constructors LLC (“DeNucci” or “Respondent”) performed work at a jobsite located at 500 Sabine Street in Austin, Texas (“Worksite”). (Ex. J-1 Stip. No. 5). On said date, two of Respondent’s employees, Daniel Ponce (“Ponce”) and Ramiro Vasquez Paz (“Paz”), entered a trench on the Worksite in order to locate and uncover existing piping. (Ex. J-1 Stip. No. 10). At approximately 10:20 a.m., an Occupational Safety and Health Administration (“OSHA”) Compliance Assistance Specialist (“CAS”), Joann Natarajan happened to walk by the Worksite. (Tr. 39, 42-43). As CAS Natarajan walked past the Worksite, she observed two employees digging under and around four exposed pipes in the bottom of the trench. (Tr. 39, 42-43, 47-48, 50, 65-66). Based on her visual observations of the trench depth, angle, sides, and sloughing of soil into the trench, she determined the trench was unsafe. (Tr. 51-56).