The Des Plaines, Illinois, and Milwaukee, Wisconsin, Area Offices of the Occupational Safety and Health Administration conducted inspections of two ECS worksites in Hoffman Estates, Illinois, and Waukesha, Wisconsin, respectively, in October of 2021. As a result of each inspection, the Secretary issued ECS citations. The Secretary alleged a total of 14 violations of the standards covering construction work at the worksites. 29 C.F.R. § 1926. He characterized one violation as willful, four as repeat, and the remaining violations as serious. The Secretary proposes a total penalty for all the violations of $360,531. On May 2, 2022, ECS, through its attorney, filed timely notices of contest to the citations. The Commission docketed the matters on May 12, 2022, assigning Docket No. 22-0536 to Inspection No. 1559071 and Docket No. 22-0519 to Inspection No. 1560806.