One of Respondent’s employees was seriously injured while cutting a shoulder roast with a Biro meat-cutting band saw. According to the employee, the meat turned while he was cutting it, pulling his hand into the saw and causing a substantial laceration to his hand. The employee told the CSHO he was abiding by Respondent’s so-called “Four-Inch” rule to avoid placing his hand in the zone of danger created by the band saw, which could not otherwise be guarded at the point of operation. The employee, however, was not using the push guard, which is attached to the table, to hold the meat in place while he cut it. Complainant initiated an inspection in response to the incident described above. During its inspection, Complainant discovered Respondent had been previously cited four times for laceration and amputation injuries its employees suffered while using a meat-cutting band saw. Based on its inspection, Complainant issued to Respondent a willful citation under 29 C.F.R. § 1910.212(a)(3)(iii) (”section 212(a)(3)(iii)”), because Respondent failed to provide its employees with proper tools or equipment to prevent their hands from contacting the point of operation or entering the danger zone. Resp’t Motion for Summary Judgment at Ex. A.