The Respondent, Outfront Media, Inc. (Outfront), is a corporation in the business of outdoor advertising. One of the thousands of billboards that Outfront owns and maintains nationwide is located on N. Main Street in Waterbury, Connecticut. On October 5, 2017, a compliance safety and health officer (CO) from the Occupational Safety and Health Administration (OSHA) observed Outfront employees working on that billboard while more than four feet above ground level without any means or method of fall protection. (T. 24). An OSHA inspection and investigation ensued that resulted in OSHA issuing to Outfront a serious citation (Citation) that alleged three grouped violations (designated citation items 1a, 1b & 1c) and that proposed a penalty of $12,675.