I skim most enforcement notices. This one I sent to our whole team.

Last month the U.S. Department of Labor settled with Monro, the auto service chain, over an inspection at one of their New York shops. $174,000, seven violations. What stopped me wasn't the number, it was the list.

Spilled engine oil and transmission fluid on a storage room floor. Trash and scrap tires piled up outside. Oily rags left in the open instead of a covered metal can. No eyewash station near where the techs did battery work. Damaged outlets and conduit.

And a four-post lift with a broken safety latch cable, held together with a pair of vice grips.

I've walked a lot of service departments and there's nothing on that list I haven't seen. I'd guess you haven't either.

Worth noting how OSHA cited the lift. There's no single standard that squarely covers "somebody clamped vice grips on a safety latch," so they went to the General Duty Clause — the catch-all that requires every employer to provide a workplace free of recognized hazards likely to cause serious harm. You can't rules-lawyer your way around a defeated latch under a raised vehicle. If it's obviously dangerous, that's enough.

The word that costs the money is "repeat"

Six findings were cited as serious. The lift was cited as a repeat, and that's where the money is. Repeat violations carry a penalty ceiling roughly ten times higher than serious ones, because at that point the regulator has stopped asking whether you have a hazard and started asking whether your safety program functions at all.

Here's the part that should make every multi-store operator sit up.

For a single location, a repeat has to come from that location's own history. For a company with multiple establishments, it doesn't. A violation cited at one location can be used as the basis for a repeat at any other location in the same organization. OSHA's own stated position is that a repeat is simply a violation substantially similar to a prior one by the same employer — the geographic and time limits in its field manual are enforcement discretion, not law. A federal appeals court has since held that OSHA can look back as far as it wants.

So: a hazard cited at your store in Kelowna becomes the predicate for a repeat citation at your store in Kamloops, two years later, under a different manager, at ten times the penalty.

Fixing it where it was found is not fixing it. The correction has to reach every store that runs the same equipment and the same SOPs under the same ownership.

That reframes the whole thing for me. A dealer group's exposure isn't the sum of its stores. It's the worst store, multiplied.

The fine isn't the part I'd study

On top of the money, Monro agreed to stand up a free anonymous hotline so employees at all 1,100 of their locations can report safety concerns straight to corporate.

Not more training. Not a new policy binder. A phone line — because the read was that head office couldn't see what was happening in one shop, and a tech in Norwich had no way around the manager who told him to use the vice grips.

If you run more than a couple of rooftops: would you find out about a defeated lift latch at your smallest store from a report, or from an ambulance?

Canadian dealers, don't file this under "American problem"

I get why you would. Different agency, different acronym, and the fine came out of New York. And technically, a US citation can't be the predicate for a Canadian one — the repeat mechanic above doesn't cross the border.

The problem is that the rule stops at the border and the bad habit doesn't. If your process lets a latch get improvised in Ontario, it's letting it happen in Alberta too, and each province will judge you on its own.

And that judgment is arguably harder here. Provincial regulators lean on due diligence, which means fixing the hazard after the fact doesn't clear you — you have to demonstrate you took every reasonable precaution before anyone got hurt. In Ontario that sits on top of a written health and safety policy, WHMIS training for every chemical on the shelf, a JHSC once you're past 20 workers, and hoist maintenance under Regulation 851.

In practice, due diligence means paper. Inspections with dates and names on them. Training tied to actual employees, not a binder that says everyone was trained. Committee minutes. Corrective actions showing who owned it and when it closed. When an inspector asks what you did about a hazard, they want a record, not a recollection.

Five things I'd check this week

Nothing here is a program overhaul, and every one is on the Monro citation list:

1. Every hoist, every store — latch working, inspection current, nothing improvised. Pull any lift with a compromised latch or cable out of service until it's properly repaired, and write down that you checked.
2. Rag and combustible storage. Covered, self-closing metal cans, emptied on a schedule, in every bay and the detail area. Cheapest fix on this list and still one of the most cited.
3. Eyewash and first aid, unobstructed and in the immediate work area anywhere batteries or corrosives are handled — not across the shop, and not where the floor plan put it in 2019.
4. Electrical. Cracked outlets, frayed conduit, extension cords doing permanent jobs. Tag and repair instead of working around.
5. Your escalation path. If a tech at your smallest store sees something unsafe today, what happens? If the answer is "he tells his manager and hopes," that's the same gap Monro just paid to close.

And then the one that isn't on their list: when you fix something at one store, who checks that it's fixed at the other fourteen?

That last one is the whole ballgame, and it's the reason I'm not going to end this with a printable checklist.

A sheet of paper can prove one walkaround happened at one store on one day. It can't tell you store nine has skipped the hoist check three months running. It won't chase the manager who never handed it back. And it can't push a fix from the rooftop where OSHA found the problem to the fourteen where they haven't looked yet — which, as we just covered, is exactly where the ten-times penalty comes from.

So run the five checks above this week. Then make them something that runs itself: a scheduled inspection, a failed item that becomes an action item with an owner and a due date, reminders that don't stop until it closes, and a view across every store so you can see which one is drifting.

That's what we built in HR4. If you want to look at it against your own stores, here's how it works.