As OSHA$$s ergonomic program standard was stuck down through the Congressional Review Act in $2001,$ thus requiring an act of Congress to enable it to promulgate another such standard, how or could OSHA cite an employer for ergonomic hazards in the workplace?

A$.$ OSHA cannot issue ergonomic citations to employers.

B$.$ OSHA would have to use the General Duty Clause of the OSH Act to cite an employer.

C$.$ OSHA would cite the employer for not following guidelines it has published for certain industries on ergonomics.

D$.$ OSHA could cite employers for not following consensus standards related to ergonomics.