BILL ANALYSIS                                                                                                                                                                                                    �






                             SENATE JUDICIARY COMMITTEE
                         Senator Hannah-Beth Jackson, Chair
                              2013-2014 Regular Session


          SB 1326 (Roth)
          As Amended April 21, 2014
          Hearing Date: April 29, 2014
          Fiscal: No
          Urgency: No
          TMW


                                        SUBJECT
                                           
                   Hearing Aids:  Warranty:  Work Order or Receipt

                                      DESCRIPTION  

          Existing law, the Song-Beverly Consumer Warranty Act, provides  
          that assistive devices (including hearing aids) have a 30-day  
          warranty from the time the assistive device is actually received  
          by the buyer or completion of fitting by the seller for the  
          particular needs of the buyer.  This bill would clarify hearing  
          aid warranty provisions by requiring a retailer to provide  
          written warranty beginning and expiration dates from the time  
          the hearing aids are initially delivered to the buyer.  This  
          bill would also clarify the hearing aid warranty tolling period  
          after repair or service and require the seller to provide a work  
          order or receipt with the date the warranty period resumes and  
          the revised expiration date of the warranty adjusted to reflect  
          the suspension of the warranty period during repair or service.

                                      BACKGROUND  

          In 1979, the Song-Beverly Consumer Warranty Act (Song-Beverly)  
          established warranty provisions for assistive devices, including  
          hearing aids.  At that time, hearing aids were analog and  
          amplified all sounds equally, and a completed fitting of the  
          hearing aid primarily involved turning the hearing aid sound up  
          or down.  

          Since 1979, analog hearing aids have been slowly phased out in  
          favor of digital hearing aids, which utilize computer chips to  
          convert incoming sounds into a digital code.  The computer chips  
          are adjusted based on each individual's hearing loss and  
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          listening needs.  As such, a successful fitting of digital  
          hearing aids may take a year or more, and each fitting may  
          require a consumer to return the digital hearing aids to the  
          provider for additional adjustments.  

          Under Song-Beverly, hearing aid purchasers have 30 days from  
          actual receipt by the purchaser or completion of fitting by the  
          seller, whichever occurs later, to return the hearing aid for a  
          replacement or for a full refund.  (Civ. Code Sec. 1793.02(a).)   
          With the advent of digital hearing aids and extended time frames  
          for fittings, and because Song-Beverly provides that the  
          warranty begins at the time of completion of fitting or actual  
          possession of the hearing aid by the buyer, whichever is later,  
          hearing aid consumers and providers have become uncertain as to  
          when the warranty begins.  Further, consumers may or may not  
          recall or have documentation to support the purchase or return  
          dates over the course of the fitting process.

          This bill is substantially similar to an amended version of SB  
          1444 (Anderson, 2012), which the author pulled from hearing in  
          this Committee.

          This bill, sponsored by the Hearing Healthcare Providers  
          California, would revise the warranty and tolling provisions for  
          hearing aids under Song-Beverly to clarify the warranty period.   
          This bill was heard by the Senate Business, Professions &  
          Economic Development Committee on April 7, 2014, and passed out  
          on a vote of 8-0.

                                CHANGES TO EXISTING LAW
           
          1.  Existing law  , the Song-Beverly Consumer Warranty Act  
            (Song-Beverly) provides implied warranties and remedies  
            relating to new and used assistive devices.  (Civ. Code Secs.  
            1793, 1793.02.)

             Existing law  requires all new and used assistive devices sold  
            in California to contain the retail seller's written warranty,  
            in at least 10-point bold type, as follows:
                 the assistive device is warranted to be specifically fit  
               for the particular needs of the buyer;
                 the device may be returned to the seller within 30 days,  
               or a longer period if specified by the seller, of the date  
               of actual receipt by the buyer or completion of fitting by  
               the seller, whichever occurs later, if the device is not  
               specifically fit for the buyer's particular needs; and
                                                                      



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                 the seller must either adjust or replace the device or  
               promptly refund the total amount paid by the buyer if the  
               buyer returns the device to the seller.  (Civ. Code Sec.  
               1793.02(a), (b).)

             Existing law  provides that if the buyer returns the assistive  
            device within the written warranty period, the seller shall,  
            without charge and within a reasonable time, adjust the device  
            or replace it with a device that is specifically fit for the  
            particular needs of the buyer.  (Civ. Code Sec. 1793.02(c).)

             Existing law  provides that if the seller does not adjust or  
            replace the device so that it is specifically fit for the  
            particular needs of the buyer, the seller must promptly refund  
            to the buyer the total amount paid for the assistive device  
            and any other consideration exchanged as part of the  
            transaction, and the sale is rescinded.  (Civ. Code Sec.  
            1793.02(c).)

             Existing law  provides that if a sale of assistive devices is  
            rescinded, the seller may not charge, penalize, or impose any  
            other fee on the buyer in connection with the purchase,  
            fitting, financing, or return of the device.  (Civ. Code Sec.  
            1793.02(c).)

             This bill  would revise the above warranty provisions for  
            hearing aids to require the retail seller to provide to the  
            buyer with a written warranty that the hearing aid is  
            specifically fit for the particular needs of the buyer, and if  
            the hearing aid is not initially fit for the buyer's  
            particular needs, the hearing aid may be returned to the  
            seller within 30 days of the initial date of delivery to the  
            buyer.   

            This bill  would provide that if the buyer returns the hearing  
            aid to the retail seller, the seller will either adjust or  
            replace the hearing aid or promptly refund the total amount  
            paid.  

             This bill  would authorize the retail seller to specify a  
            warranty period longer than 30 days.
             
            This bill  would require the retail seller's written warranty  
            to specify the initial date of delivery to the buyer of the  
            hearing aid and the expiration date of the warranty.

                                                                      



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          2.  Existing law  provides that a warranty period is tolled for the  
            period from the date upon which the buyer either delivers  
            nonconforming goods to the seller for warranty repairs or  
            service, or notifies the seller of the nonconformity of the  
            goods, until the date upon which the repaired or serviced  
            goods are delivered to the buyer, the buyer is notified the  
            goods are repaired or serviced and are available, or the buyer  
            is notified that repairs or service is completed, if repairs  
            or service is made at the buyer's residence.  (Civ. Code Sec.  
            1795.6(a).)

             Existing law  provides that the warranty period shall not be  
            deemed expired if either or both of the following situations  
            occur:
                 the warranty repairs or service has not been performed  
               due to delays caused by circumstances beyond the control of  
               the buyer; or
                 the warranty repairs or service performed upon the  
               nonconforming goods did not remedy the nonconformity for  
               which such repairs or service was performed and the buyer  
               notified the manufacturer or seller of this failure within  
               60 days after the repairs or service was completed.  (Civ.  
               Code Sec. 1795.6(b).)

             Existing law  requires the seller to provide to the buyer a  
            receipt showing the date of purchase.  (Civ. Code Sec.  
            1795.6(d).)

             Existing law provides that, if the seller performed warranty  
            repairs or service, the seller must provide to the buyer a  
            work order or receipt with the date of return and either the  
            date the buyer was notified that the goods were repaired or  
            serviced or, where applicable, the date the goods were shipped  
            or delivered to the buyer.  (Civ. Code Sec. 1795.6(d).)
             This bill  would specify that the warranty period for hearing  
            aids would resume on the date upon which (1) the repaired or  
            serviced hearing aids are delivered to the buyer, or (2) five  
            days after the buyer is notified the hearing aids are repaired  
            or serviced and are available for the buyer's possession,  
            whichever is earlier.
             
            This bill  would require hearing aid sellers, after receiving  
            the hearing aids for warranty repairs or service, to provide  
            to the buyer at the time of delivery to the buyer a work order  
            or receipt specifying (1) the date the warranty period  
            resumes, and (2) the revised expiration date of the warranty,  
                                                                      



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            as adjusted to reflect the suspension of the warranty period. 

                                        COMMENT
           
          1.  Stated need for the bill  
          
          The author writes:
            
            The technology of hearing aids has advanced significantly  
            since Song-Beverly was introduced in 1979.  At that time,  
            hearing aids were analog; "fitting" them meant turning the  
            volume up or down.  Modern digital hearing aids convert sound  
            into a code that can be adjusted to amplify specific parts of  
            the sound to meet an individual's needs.  Due to this  
            additional complexity, the fitting of a hearing aid takes  
            longer, with each fitting requiring the hearing aid be  
            returned to the provider for adjustment.

            The problem lies with the several interpretations of what  
            completion of fitting means in Song-Beverly.  Currently, the  
            30 days may toll, only to be restarted with each successive  
            trip to the provider.  The result is a warranty period that  
            can last upwards of a year or more. 

            The purpose of this bill is to provide a defined and reliable  
            warranty period for new and used hearing aid devices. 
            
          2.  Revising the warranty provisions for hearing aids  

          Existing law, the Song-Beverly Consumer Warranty Act  
          (Song-Beverly), provides that assistive devices, including  
          hearing aids, are warrantied to be specifically fit for the  
          particular needs of the buyer.  (Civ. Code Sec. 1793.02(a).)   
          Song-Beverly also provides that an assistive device may be  
          returned to the seller within 30 days, or longer if specified by  
          the seller, of the date of actual receipt by the buyer or  
          completion of fitting by the seller, whichever occurs later.   
          (Civ. Code Sec. 1793.02(b).)  This bill would clarify those  
          provisions for hearing aids by requiring a retailer to provide  
          the beginning and expiration dates of the warranty at the time  
          the hearing aids are initially delivered to the buyer.  This  
          bill would also provide that if the hearing aids are not  
          initially fit for the particular needs of the buyer, the buyer  
          would have 30 days from the initial date of delivery to return  
          the hearing aids for adjustment, replacement, or a full refund.   

                                                                      



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          The author argues that ambiguity exists as to when a hearing aid  
          has been specifically fitted for the particular needs of the  
          buyer.  Hearing aids that are molded to fit the particular  
          buyer's ears may take up to a year to completely fit the  
          particular needs of the buyer.  Accordingly, "completion of  
          fitting," has been interpreted different ways by the hearing aid  
          seller and buyer.  The hearing aid seller has to determine,  
          based on the unique and circumstantial definition of "completion  
          of fitting," when the 30-day warranty period starts and stops.   
          The buyer also has to argue the definition of completion of  
          fitting, and has to maintain accurate records as to when the  
          hearing aids were purchased, picked up, and potentially returned  
          for adjustments over the course of the fitting to validate their  
          claim in the event the seller refuses to refund the purchase  
          price and services associated with the hearing aid.  

          Instead of qualifying the warranty on a "completion of fitting"  
          standard provided under existing law, and in order to provide  
          clarity for providers and consumers, this bill would provide  
          that the warranty period begins to run when the buyer takes  
          delivery of the hearing aid.  Should the buyer be dissatisfied  
          with the hearing aid performance or fit after taking possession  
          of the hearing aid, the warranty tolling provision discussed in  
          Comment 3 would allow the buyer to return the hearing aid for  
          proper fitting, repair, or remake and allow the hearing aid  
          seller the ability to fix the hearing aid during the warranty  
          period.  Although, the buyer may choose to return the hearing  
          aid for a full refund.

          It is important to note that removing the "completion of  
          fitting" condition from the warranty start date does not remove  
          the implied warranty of fitness for a particular purpose  
          provided in existing law and continued in this bill.  Hearing  
          aids, by nature of their use to address each individual's  
          hearing loss, require more than a general warranty of  
          merchantability or ordinary purpose.  Existing case law,  
          American Suzuki Motor Corp. v. Superior Court (1995) 37  
          Cal.App.4th 1291, reasoned that the applicability of an implied  
          warranty of fitness for a particular purpose is appropriate in  
          certain circumstances.  The Court of Appeal held:

            [A]n implied warranty of fitness for a particular purpose  
            exists where the seller at the time of contracting has reason  
            to know (a) any particular purpose for which goods are  
            required, and (b) that the buyer is relying on the seller's  
                                                                      



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            skill or judgment to select or to furnish suitable goods for  
            such purpose.  "A 'particular purpose' differs from the  
            ordinary purpose for which the goods are used in that it  
            envisages a specific use by the buyer which is peculiar to the  
            nature of his business whereas the ordinary purposes for which  
            goods are used are those envisaged in the concept of  
            merchantability and go to uses which are customarily made of  
            the goods in question." . . . 

            The Song-Beverly Act incorporates the provisions of  
            [California Uniform Commercial Code] sections 2314 and 2315.   
            It "supplements, rather than supersedes, the provisions of the  
            California Uniform Commercial Code" by broadening a consumer's  
            remedies to include costs, attorney's fees, and civil  
            penalties.  (Id. at 1295; internal citations omitted.)

          In most circumstances, the consumer consults an audiologist, who  
          tests the individual for hearing loss problems.  The consumer  
          then relies on the audiologist's skill or judgment to select the  
          appropriate hearing aid for the consumer's hearing needs.   
          Hearing aids are then "fit" for the particular needs of the  
          individual.  Song-Beverly encompasses this transaction by  
          providing consumer protection with a warranty of fitness for a  
          particular purpose.  Accordingly, this bill would maintain that  
          a seller is warranting that the hearing aid is specifically fit  
          for the particular needs of the buyer.  

          3.  Warranty tolling provisions during hearing aid adjustment,  
            remake, or replacement  

          Song-Beverly provides that if a hearing aid seller does not  
          adjust or replace the device so that it is specifically fit for  
          the particular needs of the buyer, the seller must promptly  
          refund to the buyer the total amount paid for the assistive  
          device and any other consideration exchanged as part of the  
          transaction, and the sale is rescinded.  (Civ. Code Sec.  
          7093.02(c).)  Further, existing law provides that a warranty  
          period is tolled if the buyer has returned the device to the  
          seller for repair or service, as specified, and the warranty  
          period resumes when the repair or serviced good is returned to  
          the buyer or when the buyer is notified that the goods are  
          repaired or serviced and are available for the buyer to pick up.  
           (Id.).  (Civ. Code Sec. 1795.6.)  This bill would clarify the  
          hearing aid warranty tolling period after repair or service and  
          require the seller to provide a work order or receipt with the  
          date the warranty period resumes and the revised expiration date  
                                                                      



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          of the warranty adjusted to reflect the suspension of the  
          warranty period during repair or service.

          The author argues that Song-Beverly does not adequately address  
          periods of time during the warranty period when the hearing aid  
          device may require adjustment or repair and is not in the  
          possession of the consumer.  Unlike other digital consumer  
          devices, such as cameras and computers, digital hearing aids are  
          adjusted based on each individual's hearing loss and listening  
          needs.  Further, some hearing aids are modeled to conform to the  
          buyer's ear shape.  As such, the buyer may not be aware of any  
          particular sound or shape issue with the hearing aid until after  
          the buyer has picked up the hearing aid and worn it for a few  
          days.  

          The author notes that other states, such as Florida (Fla. Stat.  
          468.1246) and Texas (22 TAC Sec. 141.16), provide that the  
          hearing aid warranty is tolled when the hearing aid is returned  
          by the buyer for repair, remake, or adjustment, and the running  
          of the warranty period is suspended for one day for each 24-hour  
          period that the hearing aid is not in the buyer's possession.   
          Texas also provides that the warranty period resumes on the day  
          the buyer reclaims the repaired, remade, or adjusted hearing aid  
          or within five working days of notification of availability.  

          Using this framework, this bill was amended to provide consumers  
          a clearly defined tolling period that would resume on the day  
          the buyer reclaims the hearing aid or five days after the buyer  
          is notified the hearing aid has been repaired or serviced and  
          are available to be reclaimed, whichever date is earlier.  The  
          author's recent amendments also require the seller to provide  
          the buyer with a written notice of the tolling period.  Such  
          notice would be required to include the date the warranty period  
          resumes and the revised expiration date of the warranty,  
          adjusted to reflect the tolling period. 


           Support  :  AA Hearing Aids Center; Advanced Ear Care; American  
          Hearing Aid Center of the South Bay, Inc.; Bartlett's Hearing  
          Aids; California Academy of Audiology; California  
          Speech-Language Pathology and Audiology and Hearing Aid  
          Dispensers Board; Creekside Hearing Aid Service; Gillett Hearing  
          Aid Center; Hearing Aid Systems, Inc.; Miracle-Ear Center; Sears  
          Hearing Aid Centers; Twin Cities Hearing Aid Center

           Opposition  :  None Known
                                                                      



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                                        HISTORY
           
           Source  :  Hearing Healthcare Providers California

           Related Pending Legislation  :  None Known

           Prior Legislation  :  

          SB 1444 (Anderson, 2012) See Background.

          SB 648 (Battin, 2003), under the Assistive Devices Warranty Law,  
          would have allowed a hearing aid seller to charge a nominal  
          adjustment fee at the discretion of the seller.  This bill was  
          referred to this Committee but returned to the Secretary of the  
          Senate pursuant to Joint Rule 56.

          AB 1889 (Seastrand, Ch. 228, Stats. 1991), among other things,  
          exempted hearing aids sold by catalog from the list of assistive  
          devices excluded, as specified, from the Assistive Devices  
          Warranty Law.

           Prior Vote  :  Senate Committee on Business, Professions &  
          Economic Development (Ayes 8, Noes 0)

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