BILL ANALYSIS                                                                                                                                                                                                    







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        |Hearing Date:April 20, 2009    |Bill No:SB                            |
        |                               |427                                   |
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          SENATE COMMITTEE ON BUSINESS, PROFESSIONS AND ECONOMIC DEVELOPMENT
                         Senator Gloria Negrete McLeod, Chair

                      Bill No:        SB 427Author:Negrete McLeod
                        As Amended:April 2, 2009 Fiscal:    Yes

        
        SUBJECT:   Automotive repair: crash parts.
        
        SUMMARY:  Requires an automotive repair dealer performing auto  
        body or collision repair to place a notice on the written estimate  
        and final invoice stating that installing parts, other than those  
        described on the estimate, without the customer's prior approval  
        is unlawful and that the consumer may contact the Bureau of  
        Automotive Repair if fraud is suspected; requires an automotive  
        repair dealer to provide a customer copies of invoices of any  
        airbags that were installed; establishes misdemeanor penalties;  
        defines "crash part" and "aftermarket crash part;" becomes  
        effective January 1, 2011.

         NOTE  :  This measure is before the Committee for reconsideration.   
        This measure failed passage in Committee by a vote of 5-3 on April  
        13, 2009.

        Existing law:

        1)Licenses and regulates more than 35,000 automotive repair  
          dealers (ARDs) under the Automotive Repair Act (Act) by the  
          Bureau of Automotive Repair (BAR) within the Department of  
          Consumer Affairs (DCA).

        2)Requires an ARD to provide a customer with an itemized written  
          estimate for parts and labor before performing any work on the  
          customer's vehicle.

        3)Prohibits an ARD from charging a customer for work done or parts  
          supplied in excess of the written estimate without first  
          obtaining a customer's oral or written authorization.






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        4)Requires an ARD performing auto body or collision repair work to  
          identify whether each part is new, used, rebuilt, or  
          reconditioned on the written estimate.  The written estimate  
          must also identify whether a crash part is an original equipment  
          manufacturer (OEM) or non-original equipment (non-OEM)  
          manufacturer crash part.

        5)Requires the ARD to obtain authorization from the customer  
          before performing work and imposing charges.

        6)Requires all work done by an ARD to be recorded on an itemized  
          invoice that describes all service work done and parts supplied,  
          and requires the invoice to contain specified information.

        7)Establishes a misdemeanor (crime) penalty of up to six months in  
          jail or a $1,000 fine (or both), for any person who fails to  
          comply with the provisions of the Act.

        8)Defines various terms for purposes of the motor vehicle  
          replacement parts provisions of the Business and Professions  
          Code (B&P Code).

        Existing law (Vehicle Code):

        9)Establishes a misdemeanor (crime) penalty of up to one year in  
          jail or a $5,000 fine (or both), for any person who installs or  
          reinstalls for compensation, distributes or sells a previously  
          deployed air bag in a vehicle, if the person knows that the air  
          bag has been previously deployed.

        This bill:

        1)Defines the following terms:  

           a)   "Crash part" to mean any of the non-mechanical sheet metal  
             or plastic parts which generally constitute the exterior of a  
             motor vehicle, including inner and out panels and exterior  
             lighting and includes the airbag in a motor vehicle's  
             inflatable restraint system. 

           b)   "Aftermarket crash part" to mean a replacement for any  
             crash part.

        1)Requires an ARD to provide a customer copies of invoices of any  
          airbags installed as part of an inflatable restraint system.






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        2)Establishes a misdemeanor (crime) penalty of up to one year in  
          jail or a $5,000 fine (or both), for an automotive repair dealer  
          who prepares a written estimate that includes replacement of a  
          deployed airbag and who fails to repair and fully restore the  
          airbag to original operating condition.

        3)Requires the first page of the itemized written estimate and the  
          first page of the final invoice, to contain a statement in at  
          least 12 point bold face type in a box:  

             "INSTALLING A PART, OTHER THAN A PART DESCRIBED ON THE  
             WRITTEN ESTIMATE, WITHOUT PRIOR APPROVAL FROM THE CUSTOMER  
             IS UNLAWFUL.  IF YOU SUSPECT PARTS FRAUD OR ARE CONCERNED  
             ABOUT THE REPAIR OF YOUR VEHICLE BY AN AUTOMOTIVE REPAIR  
             DEALER, CALL THE BUREAU OF AUTOMOTIVE REPAIR IN THE  
             CALIFORNIA DEPARTMENT OF CONSUMER AFFAIRS TOLL FREE AT  
             (800) 952-5210." 

        4)Becomes operative on January 1, 2011.

        5)Deletes reference to a repealed provision of law and makes  
          conforming and technical changes.


        FISCAL EFFECT:  Unknown.  This bill has been keyed "fiscal" by  
        Legislative Counsel.


        COMMENTS:
        
        1.Purpose.  This bill is sponsored by  Center for Auto Safety   
          (Sponsor) to provide the automotive repair consumer with notice  
          that auto repair collision parts switching - a common activity  
          in some body shops in California and nationally - is fraud and  
          against the law.  The Author states that the bill will also  
          provide the consumer with remedy by providing information on how  
          to contact the California Bureau of Automotive Repair (BAR) if  
          fraud is suspected.  This measure is intended to deter parts  
          switching fraud by involving the repair facility in the  
          consumer's education and notice.  The bill will further ensure  
          the consumer, the consumer's insurance carrier, as well as BAR,  
          that the air bag restraint system was installed with an air bag  
          in working order, according to the Author.

        2.Background.  "Crash parts," or "body parts," are parts generally  
          made of sheet metal, plastic, or glass that constitute the  





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          exterior of a motor vehicle and tend to serve a cosmetic  
          function.  Examples of crash parts include bumper reinforcements  
          and absorbers, hoods, fenders, door shells, rear outer panels,  
          deck and trunk lids, quarter panels, truck beds and box sides,  
          body side panels, tailgates, and lift gates.  OEM crash parts  
          are made by the manufacturer of a given motor vehicle for use on  
          that vehicle (e.g., a hood made by Ford for a Ford vehicle).   
          Non-OEM parts, on the other hand, are imitation auto parts made  
          by an independent manufacturer that is generally not affiliated  
          with the manufacturer of the motor vehicle for which the part is  
          intended.  Non-OEM manufacturers must "reverse-engineer" the  
          replacement parts because they do not have access to the OEM  
          manufacturer's specifications for a given part (because this  
          information is proprietary).  Non-OEM crash parts typically cost  
          20% to 65% less than OEM crash parts.

        3.Reestablishment of the BAR Autobody Inspection Program.  The  
          Department of Consumer Affairs' 2006-07 Annual Report states  
          that the BAR reestablished the Auto Body Inspection Program in  
          January 2007.  This program allows qualified consumers to  
          receive free inspections to verify the collision repair work  
          done on their cars.  During the 2006-07 fiscal year, the BAR's  
          Auto Body Inspection Program completed 232 inspections, of which  
          81 (35 %) uncovered poor workmanship and/or billing for parts  
          and services not performed.  A total of 86 complaints were  
          opened as a result.

        4.Related Legislation.   AB 2825  (Carter, 2008) would have  
          authorized a customer to receive copies of invoices from the  
          distributor, dealer or manufacturer for all crash parts  
          installed in excess of $50; required the written estimate and  
          the final invoice to include a notice stating that installing  
          parts other than those described on the estimate without the  
          customer's prior approval is unlawful; and required copies of  
          crash part invoices, if requested by the consumer, to be  
          attached to the final invoice.  That bill was vetoed by the  
          Governor, citing that the bill was duplicative of existing law  
          and therefore unnecessary. 

         AB 1483  (Carter, 2007) would have required an ARD, once repairs  
          are completed, to provide a written affirmation to the customer  
          on the first page of the final invoice that the parts identified  
          on the estimate are the parts that were installed on the vehicle  
          during repair.  That bill was vetoed by the Governor, citing  
          that it was duplicative of existing law and therefore  
          unnecessary, and that the provisions may lead to increased  





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          expenses and decreased efficiency at automotive repair dealers.

        5.Arguments in Support.  The  Center for Auto Safety  (CAS) states:   
          "While the majority of autobody repair shops comply with the  
          law, the problem of "parts switching" - or billing the consumer  
          for a more expensive OEM part, but installing a less-expensive  
          aftermarket part - remains a common area of fraud in the  
          autobody repair industry."  CAS indicates that each year auto  
          crash repair fraud victimizes hundreds of thousands of  
          California motorists at a cost of over $350 million.  Where the  
          repairer fails to install a replacement airbag, consumers can  
          even be killed in a crash.  This bill would strengthen current  
          law by requiring the parts invoice for any replacement airbag  
          installed as part of the vehicle repair to be attached to the  
          final repair invoice given to a consumer.  The US Department of  
          Transportation has found that 20% of all deaths in crashes  
          caused by an airbag failing to deploy are due to the airbag not  
          having been installed in a repair prior to the crash.

        CAS also argues that putting the toll free phone number of BAR on  
          both the repair estimate and invoice is essential, since  
          consumers normally have problems with vehicle repairs after they  
          leave the shop and the pamphlets and displays at the repair shop  
          do not inadequately inform consumers who to call.

        CAS believes that repair fraud continues to be a problem stating  
          that thirty years ago the U.S. Department of Transportation  
          documented that 53 cents out of every dollar consumers spend on  
          auto repair in general was wasted, and in 2003 the BAR's study  
          of auto body collision repairs showed that 42% of the vehicles  
          inspected had parts or labor listed on the invoice that were not  
          actually supplied or performed.

        CAS also asserts that this bill is completely different from prior  
          bills in that the bill deals with airbags that were not replaced  
          in crash repairs, and requires the BAR's toll free number on the  
          repair estimate and final invoice which neither of the previous  
          bills did.

         American Federation of State, County and Municipal Employees  
          AFL-CIO  supports the bill, believing that educating the public  
          about their right for an inspection by the BAR after their  
          vehicle is repaired will protect the consumer and the insurance  
          company in the event of criminal negligence on the part of the  
          ARD. 






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        6.Arguments in Opposition.   California New Car Dealers Association  
           (CNCDA) is opposed and contends that the bill requires  
          automotive repair dealers to duplicate work already required by  
          statute.  It is already fraud (intentional misrepresentation) to  
          disclose on an estimate that the repair dealer will put OEM  
          parts on a car, not do so, and then itemize that he or she did  
          so on the invoice.  CNCDA suggests instead that zealous  
          prosecution of existing law by the Bureau of Automotive Repair  
          (BAR) would accomplish that objective without the unnecessary  
          paperwork this bill would require.

        The  California Autobody Association  (CAA) is also opposed and  
          believes the bill only creates another layer of unnecessary  
          administrative paper work for the automotive repair dealer and  
          frustration and confusion to the consumer.  CAA argues the bill  
          duplicates existing law which requires written disclosures and  
          certifications on both the estimate and the final invoice for  
          all parts, including airbags; furthermore, repair shops must  
          already post signs listing consumer rights and the BAR's toll  
          free telephone number.

        The  Collision Repair Association of California  (CRA) writes that  
          it is supportive of efforts to curb auto parts fraud and  
          increasing BAR's re-inspection program, but not of simply  
          requiring ARDs to give customers copies of wholesale invoices  
          for airbags and to add fraud alerts to customer invoices.  CRA  
          further objects to adding "airbags" to the definition of "crash  
          parts" and states that the collision industry and insurers have  
          long viewed crash parts as non-mechanical parts while an airbag  
          is mechanical in nature.  CRA contends that the airbag is an  
          integral part of a safety restraint system, not a stand alone  
          part.

         NOTE  :  Double-referral to Judiciary Committee second.



        SUPPORT AND OPPOSITION:
        
         Support:   

        Center for Auto Safety (Sponsor)
        American Federation of State, County and Municipal Employees  
        AFL-CIO
        Consumer Federation of California
        Consumers for Auto Reliability and Safety





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        Personal Insurance Federation of California
        Public Citizen
        One Individual
         

        Opposition:  

        Automotive Service Councils of California
        California Autobody Association
        California New Car Dealers Association
        Collision Repair Association of California
        One Individual

        Consultant:G. V. Ayers