BP Products North America, Inc. operates a petroleum refinery in Oregon, Ohio. The refinery is owned by BP-Husky Refining, LLC. As part of its Refinery National Emphasis Program, a team of compliance officers and industrial hygienists from the Occupational Safety and Health Administration inspected the refinery from September 10 through December 18, 2009. On March 8, 2010, OSHA issued three citations to Respondents (referred to collectively as “BP”) under the Occupational Safety and Health Act of 1970, 29 U.S.C. §§ 651-678, two of which were settled in their entirety prior to the hearing in this matter. The proceedings before Administrative Law Judge Sharon D. Calhoun concerned sixty-five items in Willful Citation 2, all of which allege violations of OSHA’s process safety management of highly hazardous chemicals (“PSM”) standard, 29 C.F.R. § 1910.119. This standard “contains requirements for preventing or minimizing the consequences of catastrophic release of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards.” 29 C.F.R. § 1910.119(a).