EXHIBIT 2.pdf

CP-2026-AH685-0026 ADOSH · Arizona Division of Occupational Safety and Health · 2026-08-04

EHS INSIDERS Mukesh Kataria, MPH | Principal Consultant | 925-203-0964 | [email redacted]

July 14, 2026 Sent via email (with confirmed receipt) and Certified U.S. mail

Director Arizona Division of Occupational Safety and Health Industrial Commission of Arizona 800 W Washington St, Room 203 Phoenix, AZ 85007 (Copy: P.O. Box 19070, Phoenix, AZ 85005-9070)

Re: Contest of Citation and Notification of Penalty Inspection No.: CP-2026-AH685-0026 Employer: Heath's European Auto Repair LLC dba Tech Plus Automotive Site: 7333 East Butherus Drive, Suite B-200, Scottsdale, AZ 85260 Citation issued July 2, 2026; received July 7, 2026 Dear Director: I am the EHS consultant for Heath's European Auto Repair LLC dba Tech Plus Automotive (“TPA”), and TPA has authorized me and EHS Insiders to act as its representative in this matter. I am writing on the company's behalf to formally contest the citation referenced above. This letter is submitted within the 15-working-day period (TPA received the citation on July 7, 2026) and preserves the company's right to contest the violations, their “Serious” classification, the proposed penalties, and the abatement dates (A.R.S. § 23-417). Contesting these items doesn't mean the company is standing still. As the enclosed exhibits show, TPA moved quickly after the January 29, 2026 inspection to address the concerns raised. We are contesting to make sure the classifications, penalties, and deadlines are fair and accurate — not to avoid responsibility. Correcting these items is not an admission that the violations occurred as alleged. What we are contesting TPA contests each of the following, including the alleged violation, its “Serious” classification, the penalty, and the abatement date: • Citation 1, Item 1 — A.R.S. § 23-403.A (vehicle lift) • Citation 1, Item 2 — 29 C.F.R. § 1910.28(b)(1)(i) (fall protection – mezzanine) • Citation 1, Item 3 — 29 C.F.R. § 1910.30(a)(1) (fall protection training – mezzanine) • Citation 1, Item 4 — 29 C.F.R. § 1910.1200(e)(1) (written hazard communication program) • Citation 1, Item 5 — 29 C.F.R. § 1910.1200(g)(8) (safety data sheet access) • Citation 2, Item 1 — 29 C.F.R. § 1904.29(a) (injury and illness recordkeeping); TPA contests that it is subject to this requirement, as explained below What TPA has done (with exhibits) The corrective actions below were completed or are underway following the January 29, 2026 inspection, and are offered to show the company's prompt, good-faith response: • Lift (Item 1): The lift (Model TP10A HD, Serial No. 5128026) was inspected by a qualified lift inspector to the ANSI/ALI ALOIM:2020 standard on April 15, 2026 (Exhibit A). • Mezzanine (Items 2 & 3): As an initial matter, the mezzanine inspected by ADOSH is not part of TPA — specifically, it is not within Suite B-200. Because it is not part of TPA, it should not have been included in this inspection or citation, and we ask that these items be vacated. In the alternative, and in any event, Heath's Auto Management — which is independent from TPA — has corrected the condition: the previously open edge has been enclosed with a solid, full-height barrier, and access up the fixed ladder is restricted to authorized personnel (posted signage). A photograph of the completed correction is enclosed (Exhibit G). Employees who access elevated areas have also received documented fall-protection and ladder-safety training, including a session on January 5, 2026 before the inspection and a dedicated toolbox talk on June 4, 2026 (Exhibits B and G). • Written HazCom (Item 4): TPA has put a written Hazard Communication Program in place; the relevant program is enclosed (Exhibit C). • SDS access (Item 5): TPA maintains an electronic Safety Data Sheet system (sdsmanager.com) that employees can reach from the shop floor through posted QR codes; the subscription, invoice, and posted QR code are enclosed (Exhibit D). • Recordkeeping (Citation 2, Item 1): TPA had ten or fewer employees at all relevant times, so it is partially exempt from the OSHA 300/300A/301 recordkeeping requirement under 29 C.F.R. § 1904.1. Payroll documentation is enclosed (Exhibit E). • Fire extinguishers & emergency lighting (Citation 2): Portable fire extinguishers and emergency/exit lighting have been professionally inspected and serviced (Exhibit F). What we are asking ADOSH to consider • Drop Citation 2, Item 1 — TPA had ten or fewer employees and is partially exempt from this recordkeeping requirement under 29 C.F.R. § 1904.1. • Vacate Citation 1, Items 2 and 3 — the mezzanine is not part of TPA (Suite B-200) and should not have been included in this inspection or citation. In the alternative, treat the condition as corrected (Exhibit G) and the two items as a single grouped item. • Combine the two hazard-communication items (Items 4 and 5) into one, since they come from a single condition. • Treat the hazard-communication items as Other-than-Serious rather than Serious. • Take a fresh look at the lift item (Item 1) in light of the completed qualified inspection. • Apply the penalty reductions TPA qualifies for — the small-employer size reduction, the history reduction (no prior violations), and a good-faith reduction for the safety program now in place. • Work with us toward a fair overall resolution. TPA has posted the citation as required and is continuing to address the items raised while this is resolved. We welcome the chance to talk through these items and reach a fair outcome, and I'm glad to provide anything further you need. Enclosures Exhibit A — Qualified-inspector vehicle lift inspection report (Model TP10A HD, Serial No. 5128026), April 15, 2026. Exhibit B — Safety-meeting sign-in and training records addressing ladder use and elevated access (including a session dated January 5, 2026). Exhibit C — Written Hazard Communication Program (relevant excerpt). Exhibit D — Safety Data Sheet system subscription, invoice, and posted QR code (sdsmanager.com). Exhibit E — Establishment payroll / employee-count documentation. Exhibit F — Fire extinguisher and emergency-lighting inspection and service report, April 30 – May 1, 2026. Exhibit G — Corrective actions with photographs: mezzanine open edge enclosed with a solid full-height barrier and ladder access restricted (Items 2 & 3); post-inspection fall-protection toolbox talk (mezzanine, ladder & shop areas) with sign-in, June 4, 2026; repair of the shop-floor drainage hole; posted OSHA/GHS Hazard Communication reference chart; and the establishment self-inspection/maintenance log.

Sincerely,

Mukesh Kataria, MPH Principal Consultant, EHS Insiders 925-203-0964 | [email redacted] Authorized representative of Heath's European Auto Repair LLC dba Tech Plus Automotive

cc: Tobey Harris, Owner — Heath's Auto Management Jodi R. Bohr, Milligan Lawless, P.C.