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 individuals who have been subject to appropriate background checks. In a separate comment, CompTIA stated that: "Affiliated repair networks guarantee that repairs meet OEM standards. Repair personnel must undergo rigorous training, resulting in a professional who is technically proficient and repairs that meet strict quality control measures."

In addition, Sarah Faye Pierce from AHAM stated that unauthorized repair personnel may be untrained and uncertified and thus “may not understand how to properly repair the product to ensure it continues to meet or exceed the safety standards, particularly, a connected product, which then raises cybersecurity issues. All of this puts consumers in jeopardy. A product that once was safe could be rendered unsafe by an improper repair or unintentional use of a counterfeit part.”

Similarly, Microsoft stated in its comment that when repairing devices, Microsoft or its authorized repair providers, “use replacement batteries that meet Microsoft specifications to avoid problems caused by subpar or counterfeit replacement batteries, they meet strict quality and safety standards to ensure proper repair, and they follow specific repair procedures to avoid creating potential safety risks caused by damaged batteries or improperly installed batteries.” Microsoft, without citing specific examples or numbers, stated that it frequently received devices returned due to failures caused by third-party repairs. Microsoft also noted that off-specification power supply units, which do not meet Microsoft’s quality standards, caused at least 12 “serious overheating incidents” resulting in device damage.

Two submitters provided information they stated showed the superior service provided by authorized repairers. First, the PRBA cited the 2011 incident mentioned above, in which a loose screw inside a phone damaged the phone’s battery, which resulted in a thermal runaway. The Australian Transport Safety Bureau issued a report following the incident and noted that the screw was probably misplaced when the phone was previously repaired, and that the repair was not conducted by an authorized service provider.

Second, a 2019 survey of equipment dealers conducted by the Equipment Dealers Association (“EDA”) and Association of Equipment Manufacturers (“AEM”) showed that of responding dealers who had modified equipment come into their dealership for service in the prior 24 months, 45% reported that the modifications included those “which removed, impaired