On October 9, 2019, the Occupational Safety & Health Agency (OSHA) Pittsburgh Area Office received a complaint of roofers working without fall protection in Gibsonia, Pennsylvania. That same day an OSHA compliance officer (CO) inspected the two worksites that are the subject of the contested citations at issue here. (Tr. 362; RX-4; RX-8).1 Ireland Contracting, LLC (Ireland Contracting or Respondent) contracted with two homeowners for roof replacement at 4108 Fairway Drive and 4115 Fairway Drive in Gibsonia, Pennsylvania.2 (JX-1, Stip. 7, 13). Ireland Contracting hired two roofing subcontractors to perform the roofing work.