Every year, OSHA regional offices identify certain kinds of worksites that pose a high hazard to employees and then conduct regional emphasis inspections at those types of worksites. (Tr. 205-06). Worksites in Saipan fall within OSHA’s Region 9, which identified construction work as a high hazard and included construction projects in its regional emphasis program. (Tr. 205-06, 287). The regional office therefore identified active construction sites in Saipan and scheduled planned program inspections of those worksites. (Tr. 205-06). These consolidated cases concern inspections of two construction sites—the Capitol Hill worksite and the COTA Building worksite—and the Citations issued as a result. A. The Capitol Hill Worksite Inspection