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. 145 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 2011,146 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”147 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. 148
145 By not making parts and manuals available to individuals and independent repair shops, and not including information in these manuals about the dangers of particular repairs, manufacturers may be exacerbating the very safety concerns they have raised.
Second, according to Vermont State Senator Pearson, manufacturers’ safety arguments are difficult to square with the experience of repair in the automotive sector:-FTC study weighing manufacturers' bullshit anti-repair claims like "safety" and "security" against the facts. [bold added] https://www.techdirt.com/2021/05/13/bipartisan-ftc-study-confirms-everything-right-to-repair-advocates-have-been-saying-years/The security and safety issues we heard earlier today were similar to what we heard during the [Vermont legislative] task force. And to me, the arguments are largely bogus, and they fall apart. When we think about motor vehicles,I think we would all agree an automobile is one of the more dangerous products that we own and we control. To say that consumers should not be permitted to take electronics to a repair shop is basically insisting that our cars have to be repaired at the dealer. We’ve rejected this argument as a society, and this has to do with a ton of steel that we’re hurtling down the road, you know. We’d be wise to do the same when it comes to lightweight electronics, heavy washing machines, everything in between.149 Gay Gordon-Byrne of the Repair Association also noted that, “taking an alternator out of a car and putting it up on a hoist and dropping it on my foot is pretty dangerous” compared to opening up the back of a computer and putting in a new motherboard or replacing a screen. 150 The automotive sector demonstrates that consumers and independent repair shops are able to repair cars every day even though cars are a diverse group of complex machines that contain gasoline and battery acid and have hundreds of moving parts. With appropriate parts, repair information, and training, consumers and independent repair shops would similarly be capable of safely repairing other products. Third, manufacturers can choose to make products safer to repair when considering a product’s design.151 For instance, making lithium ion cellular pouches easily replaceable would decrease the likelihood of puncture during replacement and thus thermal runaways. As Theresa McDonough explained: [T]his is an issue that companies have created themselves. If you don’t want us being injured by repairing the battery, which is going to go, then why glue them in? Why not have them easily removable like they used to be?152Similarly, by refusing to supply replacement parts outside of their authorized repair networks, right to repair advocates assert that manufacturers increase the dangers associated with independent repair. According to Gordon-Byrne, consumers often want original parts but cannot get them and therefore turn to substitutes where the quality is variable.153 Furthermore, manufacturers could control the risks associated with repairs by including warnings in their repair manuals about ways to mitigate the dangers of particular repairs and making the manuals available to individuals and independent repair shops. The failure to label 18650 cells serves as a prime example of a manufacturer practice that increases the safety risks of independent repair. As noted in Section IV.C., all 18650 cells have the same dimensions, but they can have different chemistries. Replacing one 18650 with another cell of the same size but different chemistry could result in a thermal runaway event. This risk could be significantly reduced if the chemistry of an 18650 appeared on its label and manufacturers identified the particular 18650 chemistries used in their devices. 154 Indeed, such disclosure would impose an arguably minimal burden on manufacturers and would likely serve a valuable purpose. **The record contains no empirical evidence to suggest that independent repair shops are more or less likely than authorized repair shops to compromise or misuse customer data. ** Furthermore, although access to certain embedded software could introduce new security risks, repair advocates note that they only seek diagnostics and firmware patches.165 Furthermore, according to Gay Gordon-Byrne, replacing a part on a device with an identical OEM part or functionally equivalent aftermarket part is unlikely to create a cybersecurity risk.166 Providing individuals and independent repair shops with the diagnostic software to fix devices and with firmware patches is fully consistent with Commission staff’s 2015 Internet of Things report and its subsequent Start with Security guidance. Manufacturers can provide others with access to the same parts and tools that they provide to their authorized service providers. And, by providing such access to individuals and independent repair shops, manufacturers would have greater confidence in the repair activities that occur outside of their authorized networks. As noted above in connection with safety concerns, with appropriate parts and repair information, the record supports arguments that consumers and independent repair shops would be equally capable of minimizing cybersecurity risks, as are authorized repairers.
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Anonymous Chickenshit^ classic projection
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So you admit you have nothing to show.
You prove my point.
your mental illness[AC Projects facts not in evidence]
[AC projects facts not in evidence]
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...hallucinated nobody mentally competent, ever.
you argue with illusory versions of me who say what you want them to say so that you can win arguments with yourself...hallucinated nobody mentally competent, ever.
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...hallucinated nobody mentally competent, ever.
...lied no human, ever.
You spelled "comservatives" wrong.
Translation: Hyman hates free speech.
...said no human, ever.