The Respondent, Elmer W. Davis, Inc. (EWD), is a commercial roofing company based in Rochester, New York. On April 4, 2022, an EWD crew was replacing the flat roof of a four-story municipal building in the Village of Newark, New York. A compliance safety and health officer (CO) for the U.S. Occupational Safety and Health Administration (OSHA) was driving near the municipal building and noticed a worker standing at the edge of its roof without any apparent fall protection and signaling to the operator of a crane that was hoisting materials onto the roof. The CO stopped driving and from a parking lot about 200 feet away he continued observing the worker at the roof’s edge.