Science Applications International Corporation (“SAIC”) contracts with the U.S. Navy’s Space and Naval Warfare Systems Command (“SPAWAR”) to train marine mammals to detect trespassing swimmers in and around Navy installations. In April 2014, an SAIC employee drowned during a sea lion training exercise in San Diego Bay in Coronado, California. After an inspection, the Occupational Safety and Health Administration issued SAIC a citation alleging a serious violation of the Occupational Safety and Health Act’s general duty clause, 29 U.S.C. § 654(a)(1), for exposing employees to “drowning hazards while swimming during marine mammal training operations.” The Secretary proposed a $5,000 penalty for this citation item. Following a hearing, Administrative Law Judge Patrick B. Augustine affirmed the violation and assessed the proposed penalty. For the following reasons, we affirm.