Respondent was hired by Intermountain Gas Company (IGC), which is owned by Montana Dakota Utilities (MDU). MDU, in turn, hired QCI to supervise the work performed by Respondent to ensure it complies with MDU’s safety and installation requirements. (Tr. 391, 581). According to Gordon, MDU requires QCI to have a representative on site every day to review the work Respondent performs. (Tr. 392). MDU also requires Respondent’s employees to complete training courses known as Operator Qualifications, or OQs. (Tr. 402).