Envision Waste Services operates a solid waste facility in Seville, Ohio. On December 6, 2010, following an inspection of the facility, the Occupational Safety and Health Administration issued three citations to Envision under the Occupational Safety and Health Act of 1970, 29 U.S.C. §§ 651-678. The citations, after subsequent amendment, allege a total of ten violations—six repeat-serious, three willful, and one other-than-serious. Administrative Law Judge Keith E. Bell affirmed all but one citation item and assessed each of the Secretary’s proposed penalties, for a total penalty of $224,000. All nine affirmed items are on review before the Commission.