The Respondent, JK Proctor, LLC, (JKP), is a roofing contractor based in Stanley, New York. On November 9, 2021, a JKP crew started a job to remove and replace the shingles on a single-story house located on U.S. Route 20 in Canandaigua, New York. A Compliance Safety and Health Officer (CO) from the U.S. Occupational Safety and Health Administration (OSHA) was driving to another destination when he noticed the workers on the roof and discerned no fall protection in use. The CO stopped driving and observed the workers from the opposite side of the highway for a while longer before he approached the house and initiated an OSHA inspection and investigation.