New Legislation for Housing misses essential evidence on electrical safety
For some time we’ve watched the issues surrounding the Right To Repair, (or Right to Own) which is fast becoming an International issue and not just in the UK, EU and USA. We wrote a previous article some time ago, which you can read HERE.
For the record EEESafe supports everyone’s right to repair of any product they have purchased. This could be a non-powered item, such as furniture, prams or even a four poster bed. It’s vital that any legislation or standards that cover such items like that are observed in repair, and this also includes Electrical items. However, they should not force any citizen to lose the choice of what they wish to do with their purchase. This could be to have a repair by a competent person, a self repair or to sell it so that they can decide what to do with the money, or even to take it’s material structure apart and sell those materials for re-manufacture. All of which should be done providing it doesn’t break any law or endanger the lives of anyone, in the process of exercising those rights and passing items on to someone else.
Electrical Items, (White Goods) are the area of concern and expertise of EEESafe, so we wanted to record a few important points that not only, the Right To Repair Community should take on board, but also anyone supportive of that right, in order that a wider perspective is considered by all consumers and Governmental Departments who have a remit to engage.
Passionate Advocates of Right To Repair seem to miss all aspects of safety. We’ve had dialogue from Right To Repair Europe, who maintain the owner will be the one who decides if it’s safe, and yet there is no method of how they will determine that safety level? It’s somewhat worrying not to see how they plan to prove they are Professional Repairers, which is a requirement from Manufacturers under the new ECO Design Directive, if Right To Repair are campaigning for Tech Manuals.
Where does Right To Repair stand on Market Surveillance, as defined by the EU HERE. Product safety is at the heart of this EU wide problem, and whilst it encompasses Customs, it also covers Product Recalls. In the EU, market surveillance authorities in each country are responsible for controlling products and for taking the appropriate measures. With the potential of countless self-repaired items infiltrating the Second Use market of Electrical Appliances, we would have to ask if R2R have a solution for this, that would be traceable? EEESafe will be able to prevent Product Recalls being passed on, when using our own Appliance Register, so there are options to work with R2R in this respect also, as we all want more Repair.
Repair Cafes
These are worth a mention and do a great job in keeping smaller appliances in working order. From a safety perspective and under their terms, exonerate themselves of all responsibility, should anything go wrong after they’ve assisted you in a repair. As I understand it, a consumer must sign to that effect when bringing a product to be fixed. There will always be a potential for something to go wrong, for which everyone should be aware and accept when undertaking a repair at a Repair Cafe. Admittedly it is likely to be minor in small appliances, but the risk still exists. Furthermore, as there is no regulation to ensure such an appliance that has had a repair, when and if passed on for free or for sale to another owner, will carry the history of repair and by whom. Items that have been self repaired, would have no record that the next user can be sure it’s safe. Without expertise and evidence of that expertise, charity shops or consumers could end up taking in products that have not met conformance safety standards. You’ll read below that A PAT Test doesn’t make an item safe to use, and evidence of someone running the correct Run Tests with evidenced calibrated equipment, could damage trust in Charity Shops who receive donated appliances.
So finding new skills is great in projects that help you fix your appliance, especially because more repair means we’ll help prevent waste. However, these new found skills could lead some owners to make informed decisions to try repairing more things of the same category or other electrical items. Clearly there is potential for someone to move on to a new career which is no bad thing, but until they have attained a qualification, they may be carrying out repairs/refurbishment without any legal warranty or accountability, which would pose risks for the fixer and the “fixee”!
This could create an underground repair economy as there is no accountability required here in Repair Cafes because they help you fix it and hold no liability if anything goes wrong in the future. Potentially those who move on to more repair, could end up working on a cash only basis genuinely believing their doing a good job (and they may well be doing that). This could give the tax man some concerns, not to mention who is going to be responsible, if a repair is conducted and subsequently causes an accident, a fire and hopefully not, a fatality.
The Passing on of Electrical Self Repaired Items could create a lot of mistrust in the repair community and confidence in Reuse. We’ve considerable experience of this in the White Goods Reuse/Repair sector. Why Mistrust, I hear you say, because the nature of a Repair Cafe, could be that it doesn’t have traceability of who repaired an item, but in any event, if they declare no accountability, then that would be pointless unless that could be changed.
Volunteers are interviewed to supervise/conduct repairs. What we don’t know is who is making the decision to use that Volunteer in the role and on what basis is the decision made. i.e. How do they measure the depth of that persons knowledge and match it to the item being repaired.
Who then is responsible for the costs of an accident or fire, or a possible fatality from a self-repaired item? Is there a standard by which they are required to adhere to, and if using the EU/UK Reuse Protocol PAS141 (Preparing for Reuse PFR), which is itself flawed, as we reported in a consultative exercise with British Standards Institute. See this Article. So Is that item “safely” repaired? The risks being if more items are repaired and the repair doesn’t last very long, (potentially because of a lack of depth of knowledge), leading consumers to think “that’s the last time I buy a used electrical product”! We know the standards of the “PFR” when adhered to, has a huge potential to build that mistrust, so whilst it’s great to fix things which we fully support, there are considerations all stakeholders should keep in mind.
We think those who do attempt self repair and learn, could over time, resort to charging their friends, family and the wider community to provide them with a private income and thereby providing consumers with unregulated repairs, which is a risky situation for many safety and legislative reasons. We support the Right To Repair movement that is on the increase around the world, but electrical repairs from people with no independent evidence of any depth of knowledge runs the risks of many products infiltrating homes, through the second-hand market.
The Videos and Online Self repair guide sites, and those who use them, should also come under the same scrutiny and we feel consumers, whether a friend or family member, should be aware of these risks. The same accountability applies as above and the same consequences of people believing they’ve competently learnt an unproven skill and are accountable to no one.
If you’re a Landlord and such a product enters your property, where do you stand on this if one or more of these products enter your premises. They must be viewed as a risk to your property, as well as those of neighbouring properties and their occupants, not to mention if your insurance company will pay out.
Brand Damage is something that does and should concern the Manufacturers of these products. There’s a certain empathy we have with Manufacturers, from where they stand on self repair. They understandably would like to know who’s doing what to their appliances, which is why many of them have authorised routes for repair. We do have to differ with them though on the fact that they and the Government want to run a single Appliance Register, which gives them full control of solely determining, controlling and influencing what is happening on Recycled Spares (which they don’t want), and when to recall appliances. Research shows that consumers don’t trust them, and this article illustrates one reason why, with the other being their Register feeds into Warranty Sales Companies and cold calls, which does potentially breach GDPR regulations and includes Government Support. EEESafe already runs an Independent Appliance Register, but are launching their new one soon, and this will be free from any links to Warranty Companies, but also has many new features.
The Right To Repair community seem to focus mainly on Apple products, and they’ll be excited to read that Apple have recently relented on their previous position, preventing small outlets conducting these repairs. However, we have no information on where they, and their supporters (including Apple), stand on using Recycled Components. This would be interesting as surely it’s widely known now, that Reuse and Waste Prevention is better for the Environment, therefore using tested functional spares and cosmetic spares will also help prevent waste. This is something that the EEESafe Register will influence, through it’s links with their local community LocalitEEE Platform.
The car industry has been through a lot to legitimately sell used parts, often because there is a shortage of spares and many new spares are just too costly. This is a good Link and guide to help illustrate where it stands now. EEESafe seeks to do the same in White Goods Spares. The cost of repair with new spares, definitely prohibits the take up of sales of reused items and bringing in an authorised repair person. We have 50+ years experience of this, in training and helping tackle poverty through waste prevention and the facts speak for themselves from working alongside consumers and engaging with them. At EEESafe, we are providing routes for Training and Waste Prevention, including Certification and Training to reduce the risks and increase evidence of Competence. These routes will definitely involve local communities and safe dismantling to help them supply and sell locally, to Registered EEESafe Domestic Appliance Technicians. Central to that strategy is our own Appliance Safety Register. (RYA-Register Your Appliance)
So whats to stop people dismantling parts and selling them, including Counterfeit parts. Nothing, and it goes on right now, but many models have revisions of the original one, and they pose a safety risk to consumers if you don’t supply the correct part. Unregulated Recycled Spares sellers, won’t really care or don’t have accountability built in to their processes, except self-regulation, which kind of defeats the object of building trust with consumers. We aim to deliver a route for safety at a very local level, by installing Community Repairers known as DATs (Domestic Appliance Technicians) The new EEESafe Site is under development and through this, the RYA and LocalitEEE, the complete solution will roll out, eventually giving Local Communities approximately 60% potential ownership of the platform and it’s revenue streams. The scope to create many more local used Spares (Recycling), and influence Responsible Consumption, is huge.
EEESafe deals in White Goods Waste Prevention through consumer engagement and using Certified and Qualified skills. It’s about providing consumers a Brand, that is able to provide consumer Trust, that someone knows what they are doing, particularly in White Goods. Equally important EEESafe has the potential to independently regulate to a safer standard than the minimum requirement in UK Law. Through the solutions on offer it provides answers to the “accountability question” and skills recognition, which includes Recycled Appliance Spares. Particularly when it comes to local independent local repair and refurbishment of other Electrical Streams, such you can see in the Repair Cafe Model (with no accountability). This is the remedial strategy of the EEESafe plan which we hope to expand, once we’ve launched and tested the current model, focusing on it’s Independent Appliance Safety Register. By installing and linking local Certified Repairers of all material streams to the Register, we can evidence the reduction of waste and Carbon emissions, whilst giving local Fixers a local revenue stream in a sustainable model. Manufacturers have regularly never made enough spares for their Large Domestic Appliances, most likely because they want to sell new items. We believe and always have, that the only way to build trust is to recognise a Trusted Standard, such as the EEESafe Standard in White Goods. Covering the other Electrical Streams and supporting Right to Repair we hope will help assist those advocates with their objectives.
We’ve been in touch with Amdea, (Trade Association for Domestic Appliances) who operate the only Appliance Register currently directed by Government, and sought clarity on an article, in which they responded to questions on their obligations of the Eco Design Directive. We asked them, what was the definition of a Professional Repairer? The answer from the CEO was that this would likely be Qualifications.
The EU is also dealing with Right To Repair as reported by EEB. (Who incidentally appear to mention nothing of Safety when supporting Right To Repair). We read in the EU documents that the Commission indicate that repair should be conducted by Professional Repairers. This is why we have developed a Training Programme and Training Materials, linked to our Appliance Register and Model, that we are in a leading position to help deliver this in local communities in the UK. There is potential of course to lead the EU and beyond, once we get past the Brexit issues and for anyone looking for more detail, including Pathways to Qualifications in Training for White Goods Community Repairers, you’ll find them linked at this Page.
We are currently engaged in discussions with a Large Corporate on helping to deliver a Training trial with a community, and become the Primary Training Centre for UK and issue the Qualifications Certificates. Anyone else interested in being a Training Centre to help work and deliver local trusted Repairers, is welcome to contact us here.
EEESafe is currently engaged with the Office for Product Safety Standards, on the role it could play at Government Level and is seeking Parliamentary Debate with the support of a Group of MP’s on the matters of safety, such as the misleading guidance issued by Government and Stakeholders, that needs clarity showing PAT Testing, does not make an item safe to use. Also that Electricians are not the Go To place for safe repair/reuse/refurbished large domestic appliances.
So we welcome Right To Repair and we support their ethos, but it’s vital to put the right safety structure in place and we believe we’re doing that for all the right reasons and incentives afforded by our full model. A partnership model between Manufacturers and the Community, together with our Charitable Giving Standard, we hope will fully in engage everyone in the long term.
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