Car washes don’t feel like dangerous places. There’s water, some rollers, a conveyor, a few brushes — nothing that looks like a refinery or a steel mill. That’s exactly why the citation OSHA announced on September 23, 2026 is worth reading closely: it’s a reminder that “willful” violations, the most expensive and reputation-damaging category OSHA issues, don’t require exotic hazards. They require ordinary hazards that a company knew about and didn’t fix.

OSHA’s Region 2 office cited ModWash LLC, which operates express car wash locations in Sicklerville, New Jersey, with a combination of willful, repeat, and serious violations across five sites. The total proposed penalty: $446,864.

What OSHA Says Happened

According to OSHA’s citation, ModWash willfully exposed workers to two categories of hazard: hazardous energy and excessive noise.

On the energy side, the agency’s findings describe a company that had equipment maintenance happening without lockout/tagout being performed — meaning machines weren’t de-energized and secured before employees worked on them. That’s on top of two repeat violations covering the paperwork and training side of the same problem: no clear lockout procedures, no documented instructions for controlling specific energy sources, and no employee training on lockout/tagout.

Five additional serious violations round out the citation:

• No noise monitoring program in place
• No baseline audiograms established for employees within six months of noise exposure, as required once exposure crosses the action threshold
• No training provided to employees exposed to noise above 85 decibels
• Lockout/tagout devices not provided
• Devices that were provided not actually attached to machines before servicing

Put simply: this wasn’t one broken guard on one machine. It was a pattern across multiple locations, covering both the physical safeguards and the training and monitoring that are supposed to sit underneath them.

Why “Willful” Is the Word That Matters Here

OSHA doesn’t use “willful” loosely. Under the OSH Act, a violation only earns that label when the agency believes the employer knew about the hazard — or was aware of the requirement — and either intentionally disregarded it or showed plain indifference to worker safety. It’s the difference between “we made a mistake” and “we knew and didn’t act.”

That distinction isn’t just semantic. It’s the difference in penalty structure, too. In 2026, OSHA’s maximum penalty for a serious violation tops out far below what a willful or repeat violation can cost — willful violations can run up to roughly ten times higher per instance. That gap is the whole reason ModWash’s total climbed into the high six figures rather than staying in the tens of thousands: two willful findings, two repeats, and five serious violations stack quickly once the willful multiplier applies. (Current maximum figures are published directly by OSHA at osha.gov/penalties and adjust annually for inflation — always check the current table rather than relying on a fixed number from a news article.)

It’s also worth noting what this citation is not, yet: it’s a proposed penalty. ModWash has 15 business days from the citation to comply, request an informal conference with OSHA’s area director, or contest the findings formally before the independent Occupational Safety and Health Review Commission. Nothing here is finalized law until that process plays out — a distinction worth keeping in mind before repeating a dollar figure as settled fact.

The Two Standards Doing the Work

If you run any facility with conveyors, rollers, brushes, or other mechanized equipment — not just a car wash — these are the two standards this citation turns on, and they’re worth knowing by number:

• 29 CFR 1910.147 — The Control of Hazardous Energy (Lockout/Tagout). This is the standard requiring that machines be de-energized and locked out before anyone services or maintains them, with written procedures specific to each piece of equipment and documented training for every affected employee.
• 29 CFR 1910.212 — General Requirements for All Machines. The baseline machine-guarding standard, requiring that point-of-operation hazards, rotating parts, and other moving-machine dangers be guarded against contact.

Noise adds a third: 29 CFR 1910.95 — Occupational Noise Exposure, which is where the monitoring, audiogram, and training requirements OSHA cited actually come from.

A Ten-Minute Self-Audit

You don’t need to wait for an OSHA visit to find out if you have the same gaps. Walk your facility with this list:

• [ ] Does every piece of powered equipment that requires maintenance have a written, machine-specific lockout/tagout procedure? Not a general policy — one per machine or machine type.
• [ ] Are lockout devices (locks, tags, blocks) actually on-site and accessible, not stored somewhere employees have to go looking for them?
• [ ] When was the last time someone watched a maintenance task happen, rather than just checked that a policy exists on paper?
• [ ] Have all employees who service or work near powered equipment received documented LOTO training, refreshed on a regular schedule?
• [ ] Do you know your actual noise levels at each workstation? If no one’s measured it, you don’t know if you’re above the 85 dB action threshold.
• [ ] If noise levels are elevated, do exposed employees have baseline audiograms on file?
• [ ] Is someone accountable for auditing LOTO compliance periodically, rather than assuming it happens because it’s written down?

The Takeaway

Nothing about hydraulic conveyors or rotating brushes is exotic. That’s the point. Willful citations aren’t reserved for spectacular hazards — they show up wherever a known gap sits unaddressed long enough for OSHA to conclude the company should have known better. The fastest way to make sure your facility isn’t the next case study is to treat “we have a policy” and “we can prove the policy is followed” as two different things — because OSHA does.

Sources

• OSHA News Release, September 23, 2026: US Department of Labor cites New Jersey car wash for willfully exposing workers to safety hazards, proposes more than $446K in fines
• DOL Newsroom mirror: osha20260923-0
• 29 CFR 1910.147 — The Control of Hazardous Energy (Lockout/Tagout)
• 29 CFR 1910.212 — General Requirements for All Machines
• 29 CFR 1910.95 — Occupational Noise Exposure
• OSHA Penalties: osha.gov/penalties
• Patch, Gloucester Township NJ: Safety Risks At Sicklerville Car Washes Lead To Nearly $450K In Fines

Citations described here are proposed penalties as announced by OSHA; the employer retains the right to contest findings before the Occupational Safety and Health Review Commission. This article is not legal advice.