During his tenure, Commissioner Brooks greatly expanded job training through the apprenticeship program. He implemented annual inspections of all migrant labor camps and chicken processing plants. He adopted a blood-borne pathogens standard—the first in the south—and regulations designed to curb abuses in the temporary employment agency industry. He expanded the Wage and Hour enforcement staff so that there could be prompt response to wage and hour complaints. He insisted that all amusement rides be inspected every time they were reassembled. Brooks also advocated for the protection of workers' benefits and for the state minimum wage to be tied to the federal minimum wage. His tenure included the 1991 fire at a food-processing plant in Hamlet that killed 25 workers. This food processing plant was not registered with the North Carolina Secretary of State's office, as required by law, and thus was not on any state inspection list. Moreover, there had been no complaint about the plant from anyone working there, so the N. C. Department of Labor had no way of knowing that the plant even existed. Brooks fined the plant $808,150, which was the largest such penalty in state history. The major cause of death in the accident was the locked exterior doors which was not covered by an OSHA standard at the time, but by a standard administered by the N. C. Department of Insurance. After the 1991 fire and before the 1992 election, Commissioner Brooks adopted the North Carolina Building Code as an OSHA standard, which would have allowed the citation of locked exterior doors. Nonetheless, despite these facts and their being made public, the Labor Department and Commissioner Brooks were made scapegoats for the event, and his efforts were criticized as insufficient. Brooks lost the 1992 Democratic primary for Commissioner of Labor to Harry Payne. After Payne won the General Election, he rescinded the new standard allowing citation for locked exterior doors.
In 2008, at age 71, Brooks filed as a Democrat to run for Commissioner of Labor again. Brooks placed second in the May 2008 primary, but because no candidate garnered more than 40 percent of the vote, he was allowed to call for a runoff on June 24, with first-place finisher Mary Fant Donnan. On the runoff election day, Brooks lost to Donnan, 68%-32%. Voter turnout was 2%, setting a new record for low turnout in North Carolina.
Brooks ran for Commissioner again in 2012. He won the May 8 Democratic primary but because he failed to garner 40 percent of the vote, he faced a runoff with runner-up Marlowe Foster. In the July 17 runoff, Brooks defeated Foster to win the nomination. Ahead of the general election, the News and Observereditorial board endorsed Brooks, writing: "Brooks is in the unusual position of trying to reclaim a post he filled for 16 years – after being out of office since the beginning of 1993. He’s remained active during that period as an attorney with the N.C. Industrial Commission. In that capacity, he says, he’s seen workplace injuries become more severe – a point he uses against three-term Republican incumbent Cherie Berry....Berry says occupational injuries and illnesses have declined during her time in office, a fact she uses to extol her approach to regulation, which leans toward education and persuasion rather than fines. Brooks counters that changes in the state’s workforce, away from hazardous occupations, also have contributed to progress in the safety arena. He says that with more vigorous enforcement, the state can do even better. North Carolina workers need a determined champion, and Brooks shapes up as a credible alternative to someone who tends to view workplace regulation from an employer’s perspective."
