Respondent MPS Products Corp. (Respondent or MPS) is a business engaged in steel erection construction. In response to a complaint, the Occupational Safety and Health Administration (OSHA) inspected Respondent’s steel erection worksite in Rockland, Massachusetts. Following inspection, OSHA issued to Respondent a two-item serious citation and a notification of penalty alleging employee exposure to fall hazards, in violation of steel erection standard 29 C.F.R. § 1926.760(a)(1) and in violation of section 5(a)(1) of the Occupational Safety and Health Act of 1970 (the Act), 29 U.S.C. § 654(a)(1). The Secretary proposed a total penalty of $10,140.00 for the citation. Respondent MPS timely contested the citation, bringing the matter before the Occupational Safety and Health Review Commission (Commission) pursuant to section 10(c) of the Act, 29 U.S.C. § 659(c). A hearing was held in Boston, MA on February 23, and March 15, 2018. Both parties were represented by counsel at the hearing. Both parties filed post-hearing briefs. Respondent filed a reply brief.