Ruff Hands is in the business of installing windows in houses in Gotham City. He was contacted by the Caped Crusader to install the windows in his mansion that is under construction. Due to the size of the job he asked Bat Girl to help him with the job because of her skill in climbing walls. Ruff offered to pay Bat Girl $500.00 for the work. Ruff and Bat Girl started work on the project the first day at 0800. Bat Girl used her climbing skills and climbed up the outside of the house with a window to be installed on the second floor. About 0830 an OSHA Compliance Officer was out riding his horse and observed Bat Girl on the wall installing the window. The officer issued a citation to Ruff Hands that alleged violation of the General Duty Clause by not providing Bat Girl with scaffolding for the job. Ruff Hands contested the citation on the grounds that he did not qualify as an "employer" under OSHA, i.e., a person "engaged in a business affecting commerce who has employees," He maintained that his business activities do not affect interstate commerce and that Bat Girl is his only employee. If you were the Administrative Law Judge would you uphold the citation? Why or why not?