Dealer Guidance: Regulator Self-Service and Liability

Legal clarity, industry parallels, and practical business considerations
Disclaimer: This document is provided for general informational purposes and reflects our understanding of U.S. product-liability principles based on industry practice and publicly available legal frameworks. It is not legal advice. Readers with specific legal questions should consult qualified legal counsel.
Purpose

This dealer-only brief addresses common concerns about regulator self-service, service kits, and end-user education, and separates legal exposure from business preference.

Legal Reality (U.S.)

Selling parts or providing education does not create liability for improper installation by an independent end user. Liability attaches to the party performing service or making safety representations.

  • Automotive: DIY brake/steering parts are sold daily; installer responsibility is the norm.
  • Aviation: manuals and owner maintenance are common; airworthiness responsibility rests with the person doing the work.
  • Firearms: internal parts and manuals are widely available; liability follows modification and representation.
  • Industrial equipment: components are sold with specs, not workmanship guarantees.
Education vs Commercial Service

Deep6 Equipment Service Clinic: end-user education for equipment owners only. It does not authorize service for others and does not transfer liability to the shop or instructor.

Shop-employed technician training: when staff service customer regulators, the shop assumes commercial service responsibility and must adhere to published specifications.

Where Shops Actually Take on Risk

Risk increases sharply with unauthorized part substitution, fabricated components, deviation from specifications, and representations that equipment is “good to go.”

Business Outcomes (Observed)

End-user education typically does not eliminate service revenue—it reshapes it.

  • A large portion attend to understand how regulators work (not to become DIY technicians).
  • Many gain respect for the precision involved and prefer to pay the shop for service afterward.
  • Some try once and decide it is not for them.
  • Only a minority (often ~25%) become long-term self-service owners—usually technical divers with many regulators who are less likely to purchase scheduled annual service due to cost/volume.
Bottom Line

Liability follows service and representation—not education or access to parts. Shops may decline to sell kits and can refer customers to the manufacturer without increasing liability exposure.

Dealer FAQ – Version 1.0

Below are common dive shop misconceptions and statements, followed by the appropriate response.

1. “Allowing self-service increases our liability.”

Liability does not attach to education or access to parts. It attaches to who performs service and who represents equipment as safe. If a diver services their own regulator, responsibility rests with the individual performing that work.

2. “If we sell a service kit and the customer installs it wrong, we’re liable.”

Selling parts does not create liability for improper installation. That principle applies across automotive, aviation, firearms, and industrial equipment. Liability follows installation and representation, not parts sales.

Follow-up: If you’re uncomfortable selling kits, you’re welcome to refer customers directly to us.

3. “Regulators are life-support equipment — this is different.”

Other industries treat life-critical systems the same way. Aviation allows owner-performed maintenance, firearms manufacturers sell internal components, and CCR maintenance is universally owner responsibility. Regulators are mechanically simpler, not more complex.

4. “Teaching regulator service creates liability for us.”

Education does not transfer responsibility. Teaching procedures is not the same as performing service or authorizing service. Courts clearly distinguish education from commercial service.

5. “We don’t want customers thinking they’re ‘certified’ to service regs.”

That’s exactly why we distinguish between end-user education and commercial service. The Deep6 Equipment Service Clinic is education only and does not authorize service for others.

6. “Our instructors teach the Deep6 Equipment Service Clinic — are we exposed?”

No. Teaching an end-user education course does not create a service relationship or duty for future independent actions. Liability remains with whoever performs the service.

7. “But we also train our staff technicians — that’s different.”

Correct. Training shop-employed technicians who service customer regulators is commercial service. In that case, the shop assumes responsibility for workmanship and adherence to specifications.

8. “We’re worried someone will sue everyone anyway.”

Plaintiffs’ attorneys focus on who touched the equipment last, who charged for service, and who represented it as safe. They do not pursue parties who only provided education or sold parts without involvement in service.

9. “We’ve heard there were lawsuits that changed all this.”

There are no U.S. cases where a manufacturer or shop was found liable solely because a diver serviced their own regulator or purchased a service kit.

10. “Europe may do this, but the U.S. is different.”

U.S. liability law already follows the same principles used in aviation, firearms, automotive, and industrial equipment. This is not a European concept — it’s established U.S. law.

11. “We could lose service revenue if people do their own maintenance.”

In practice, most service-course participants do not become long-term DIY technicians. Many gain respect for the complexity involved and prefer to pay for professional service afterward.

12. “We don’t want to support DIY service.”

That’s entirely your choice. You’re not required to sell kits or teach service. You can simply refer customers to us directly without increasing your liability.

13. “What actually increases our liability?”

Commercial service combined with deviation from specifications — such as non-OEM parts, fabricated components, material substitutions, out-of-spec adjustments, or representing modified equipment as safe.

14. “What’s the simplest safe position for our shop?”

Don’t sell kits if you don’t want to, refer customers to the manufacturer, teach education as education only, and avoid unauthorized modifications or representations.

Single Sentence Summary

Liability follows service and representation — not education or access to parts.

Closing Remarks

“We respect that every shop has its own risk tolerance. Our role is to be clear about where responsibility actually lies so you can make an informed business decision.”

Document Control

Last updated: January 3, 2026

VersionNotes (date)
v1.1Added disclaimer + document control section (January 3, 2026)
v1.0Finalized Dealer FAQ Version 1.0 (January 3, 2026)

Disclaimer: This document is provided for general informational purposes and reflects our understanding of U.S. product-liability principles based on industry practice and publicly available legal frameworks. It is not legal advice. Readers with specific legal questions should consult qualified legal counsel.