As he was returning to the Appleton, Wisconsin Area Office on April 4, 2016, Compliance Safety and Health Officer (CSHO) Ryan Cooney saw a stainless steel pipe staged at the corner of East Glendale Avenue and Sandra Street in Appleton, Wisconsin. (Tr. 39). According to CSHO Cooney, the Occupational Safety and Health Review Commission has a national emphasis program for hexavalent chromium, which is a highly toxic chemical produced when welding certain types of stainless steel. (Tr. 39). No one was working at the time, so Cooney made a note of the location and returned to the office.