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 "There is a risk with unaffiliated and untrained service technicians. Because they have not availed themselves of the available training, this type of service technician may not be familiar with the appliance at hand or the software manufacturers provide for service technicians to repair products correctly and safely. As a result, there could be greater risk of an improper diagnosis, use of incorrect or substandard parts or even, unknowingly, counterfeit parts. The repercussions not only jeopardize the life of the product but may also leave the consumer worse off than before either with a new malfunction or a product rendered unsafe due to a repair conducted improperly or with the wrong parts. For example, a product could experience a major malfunction following the attempted repair causing fire, flooding or other potential hazards (and property damage)."

Safety considerations are a critical part of any discussion about repairs. Concerns about the safety of users, repair personnel and the public, however, should not automatically justify restricting repairs to authorized repair networks without further analysis. Upon closer review, some of the safety considerations cited give pause. First, other than citing to the mobile phone thermal runaway occurring in Australia in 2011, manufacturers provided no data to support their argument that injuries are tied to repairs performed by consumers or independent repair shops. This is so despite the fact that the Call for Empirical Research specifically asked for data concerning “[t]he risks posed by repairs made by consumers or independent repair shops” and several manufacturers and their associations submitted comments and were provided the opportunity to participate in the Workshop. Nor have manufacturers provided factual support for their statements that authorized repair persons are more careful or that individuals or independent repair shops fail to take appropriate safety precautions, or that independent repair workers who enter homes pose more of a safety risk to consumers than authorized repair workers.