BILL ANALYSIS                                                                                                                                                                                                    �







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        |Hearing Date:April 28, 2014        |Bill No:SB                         |
        |                                   |1328                               |
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                      SENATE COMMITTEE ON BUSINESS, PROFESSIONS 
                               AND ECONOMIC DEVELOPMENT
                              Senator Ted W. Lieu, Chair
                                           

                            Bill No:  SB 1328   Author:Hill
                       As Amended:  April 21, 2014 Fiscal:  Yes

        
        SUBJECT:  Weights and measures.
        
        SUMMARY:  Authorizes the Department of Food and Agriculture (DFA) to  
        adopt regulations consistent with federal law to establish a uniform  
        policy relating to the use of dry or wet tare weight methods of  
        measurement for the retail sale of meat, poultry, and fish products  
        and adopt regulations imposing an additional assessment.  Also  
        authorizes DFA to add up to $2 dollars for the business license of a  
        business using a point of sale (POS) system for purposes of POS  
        enforcement.  Specifies that a grocery store, as defined, that  
        displays a refund or no charge policy for overcharged items, shall not  
        be fined or assessed any other penalty for the first item that is not  
        in compliance during an initial standard inspection.

        Existing law:
        
        1)Provides that the Secretary of the DFA has a duty to enforce the  
          laws relating to weights and measures and measuring devices, and  
          provides for the enforcement of those laws by the Secretary and each  
          county sealer under the Secretary.  (Business and Professions Code  
          (BPC) Division 5, Chapter 2, commencing with � 12001)

        2)Makes it unlawful for any person to sell any dressed poultry or any  
          other fowl or smoked, fresh, frozen, cooked, dried, or pickled meats  
          or fish other than by weight determined at the time of sale on a  
          scale properly sealed in accordance with specified requirements.  
        (BPC � 12024.5)

        3)Makes it unlawful for any person, at the time of sale of a  
          commodity, to charge an amount that is greater than the price of the  





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          commodity.  (BPC � 12024.2)

        4)Makes it a misdemeanor to knowingly mark or stamp any false or short  
          weight or measure, or to knowingly mark false tare on any container,  
          or knowingly sell any falsely marked container.  (BPC � 12021)

        5)Provides that fat added to fresh meats or roasts is tare weight,  
          unless the package is clearly and prominently labeled in eight-point  
          type or larger font with the words "fat added."  
        (BPC � 12022.5)

        6)Makes it a misdemeanor to violate any of the weights and measures  
          provisions of the BPC or any rules, regulations, tolerances,  
          specifications, or standards adopted under those provisions.  (BPC �  
          12026)
        7)Authorizes the board of supervisors of a county or city and county  
          to license businesses and to levy business license fees.  (BPC  
          Division 7, Part 1, commencing with � 16000)

        8)Establishes the criteria and methodology for cities and counties to  
          use when inspecting the pricing accuracy of a retail establishment  
          using a point-of-sale (POS) system, and specifies that enforcement  
          action may be taken for any item that is not accurately scanned.  
        (BPC � 13350 (a) (b))

        9)Authorizes the county board of supervisors to charge a POS system  
          inspection fee or an annual registration fee.  (BPC �13350 (e))

        This bill:

        1)Authorizes the DFA to adopt regulations consistent with federal law  
          to establish a uniform policy relating to the use of dry or wet tare  
          weight methods of measurement for the retail sale of meat, poultry,  
          and fish products. 

        2)Authorizes the DFA to adopt regulations imposing an additional  
          assessment of up to 
        $2 dollars to obtain a business license for a business using a POS  
          system.  Requires the fee assessed to be deposited in the DFA Fund.   
          After appropriation by the Legislature, the fees would be available  
          to DFA to carry out the provisions relating to the use of POS  
          systems.

        3)Specifies that a grocery store shall not be fined or assessed any  
          other penalty for the first item not in compliance during an initial  
          standard inspection, provided that:





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           a)   The grocery store has a policy to refund the amount of the  
             product, or to provide the product free of charge, if the amount  
             charged for the item is greater than the price advertised,  
             posted, marked, displayed or quoted.

           b)   The grocery store posts a description of the policy in a clear  
             and conspicuous manner at each checkout location.

        1)Defines "grocery store", for these purposes, as a full-line,  
          self-service retail store with gross annual sales of $2 million or  
          more that sells a line of dry groceries, canned goods, nonfood  
          items, and some perishable items.
        

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

        COMMENTS:
        
       1.Purpose.  This bill is sponsored by the  California Grocers  
          Association  .  According to the Author, the bill will:

           a)   Provide a permanent funding source for the Division of  
             Measurement Standards (DMS) within the DFA to restore programs  
             eliminated by recent budget cuts.

           b)   Help establish consistency for businesses and consumers  
             through a uniform standard for tare weight to be used by  
             retailers.

           c)   Incentivize retailers to post a store policy to refund the  
             price difference or provide the product to the customer free of  
             charge when an overcharge occurs.

       2.Background.  According to the Author, the recent State fiscal crisis  
          has eliminated most general fund monies from the DFA.  Because the  
          DMS was 100% funded by the General Fund, budget cuts have eliminated  
          certain consumer and business protection programs that ensure  
          products are labeled accurately, specifically the quantification and  
          price accuracy programs in the counties which rely on the state to  
          oversee.

          The Author also states that, while counties can adopt programs to  
          remedy the issue, not all do.  The Author indicates that less than  





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          30 counties have a price accuracy program.  Therefore, the Author  
          notes that a large number of consumers are unprotected from  
          retailers and manufacturers that mislabel products.

          Because not every county has a program, the fees added by the bill  
          are attached to the business license fee.  Further, the Author notes  
          that there will likely be enough businesses utilizing POS systems  
          paying the additional $2 dollar fee.
          

          In 2005. AB 889 (Ruskin, Chapter 529, Statutes of 2005) added BPC �  
 
          13350 to create a statistical sampling method to test POS system  
 
          accuracy.  The sampling method is currently partially based on the  
 
          national standard set forth in the National Institute of Standards  
 
          and Technology Handbook 130.  It varies because � 13350 required  
 
          that there be a 100 percent accuracy requirement for POS  
 
          inspections, while the national standard requires 98 percent  
 
          accuracy.



          According to the Author, the average chain grocery store has 10,000  
 
          items for sale, and hundreds of items are either going on or coming  
 
          off sale.  The price changes are entered by hand into the system by  
 
          employees, and while most stores have a "very good record, a single  
 
          violation leads to an enforcement action."



           The latest amendments prohibit a grocery store from being fined or  
 
          assessed any other penalty for the first item found to not be in  
 
          compliance during an inspection, provided that the store has a  
 





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          posted policy of refunding the amount of the product, or giving the  
 
          product free if the scanned price is greater than the product's  
 
          advertised price  .



       3.National Institute of Standards and Technology Handbook 130 (HB 130)  
          - Examination Procedures for Price Verification.  The National  
          Conference on Weights and Measures (NCWM), supported by the National  
          Institute of Standards and Technology (NIST), established the Price  
          Verification Working Group in 1993 to respond to public concern  
          about price accuracy in retail stores.  In 1995, the NCWM adopted  
          procedures for verifying the accuracy of automated prices in retail  
          stores.  These procedures are embodied in NIST's HB 130 -  
          Examination Procedures for Price Verification.

          The procedures apply to all retail stores, including food, hardware,  
          general merchandise, drug, automotive supply, convenience, club or  
          other stores.  The goal of these procedures was to provide  
          regulators with tools, guidance, and background information, as well  
          as uniform test procedures and enforcement practices, to enhance the  
          economic well-being of consumers and retail businesses.  Further, by  
          implementing the price verification program in cooperation with  
          industry, regulators would help to restore and maintain consumer  
          confidence in retail pricing practices and technologies, such as  
          scanners, and provide economic benefits for consumers and  
          businesses.


          According to HB 130, 39 other states have either adopted the  
 
          handbook or have guidelines based on the handbook as follows:



           a)   30 states have adopted the handbook in its entirety and update  
 
             the laws on an annual basis;



           b)   7 states have adopted an older version of the handbook;







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           c)   2 states have no laws or regulations but use the handbook as a  
 
             guideline;


           d)   14 states either have no laws or regulations or have laws and  
 
             regulations that are not based on the handbook (California  
 
             included).



       4.Accuracy under HB 130, and California POS Law.  Under HB 130, the  
 
          required accuracy is 98 percent on the 100-item sample (that is, at  
 
          most two errors are permitted on a 100-item sample).  If more than  
 
          two errors are found and verified, the store does not meet the  
 
          accuracy requirement.



       Under California POS Law, random samples are taken from up to 50 items  
 
          at a retail establishment (BPC � 13350 (a) 4)), and "Enforcement  
 
          action may be taken for any item not in compliance"  (BPC � 13350  
 
          (b)).



       While California has a lower number of items to be sampled, which  
 
          enables inspections to be conducted much more quickly and  
 
          efficiently and at a lower cost to the county and to the retailer,  
 
          California law requires compliance with all items scanned in the  
 
          sample taken.







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       AB 889 (Ruskin, Chapter 529, Statutes of 2005) established the criteria  
 
          and methodology in California law by which the pricing accuracy of  
 
          POS systems may be verified.  In establishing that authority and  
 
          standards for inspecting POS systems, Assemblymember Ruskin agreed  
 
          to amend the bill to reference HB 130.  With regard to those  
 
          amendments, the Senate Business, Professions and Economic  
 
          Development analysis for AB 889 stated:



             "In discussing the amendments to implement this commitment, it  
 
             was found that the explicit standards in Handbook 130 only  
 
             required a 98% accuracy in the POS systems.  Therefore, the  
 
             standard would allow a 2% error rate in cost overruns for scanned  
 
             prices.  This level of error tolerance was not acceptable to  
 
             those involved in discussing the amendments.  Therefore, this  
 
             bill provides that 'Enforcement action may be taken for any item  
 
             not in compliance' - eliminating any allowance for cost  
 
             overruns."



           The latest amendments to this bill seeks to maintain the 100%  
 
          accuracy requirement of California law, but waives any fine for a  
 
          single scanned item found to be out of compliance during an  
 
          inspection.  If any additional items are scanned at a higher price  
 
          than the advertised or displayed price, the sealer can assess a fine  





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          for those violations.

        5.Prior Legislation.   AB 889  (Ruskin, Chapter 529, Statutes of 2005)  
 
          authorized counties to inspect the pricing accuracy of retail point  
 
          of sale systems.  That bill, among other things, established until  
 
          2009, the authority for counties to inspect the pricing accuracy of  
 
          retail POS systems.



           AB 1907  (Ruskin, Chapter 434, Statutes of 2008) extended the POS  
 
          inspection law to January 1, 2014.



           AB 482  (Hill, Chapter 166, Statutes of 2013) removed the sunset on  
 
          the POS inspection provisions, thereby indefinitely extending the  
 
          authority for counties to inspect the pricing accuracy of retail POS  
 
          systems.



           AB 2285  (Ruskin, Chapter 556, Statutes of 2006) made changes to the  
 
          list of items required to be displayed for consumers by automatic  
 
          checkout systems, and recast the term "automatic checkout" to refer  
 
          to the term "point-of-sale" and modified the definition of  
 
          "point-of-sale system."



           AB 2732  (Washington, Chapter 818, Statutes of 2002) required  
 
          automatic checkout systems to display the price read by the  





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          computer.  Also required a business that uses an automatic checkout  
 
          system to ensure that the price of the goods or services registered  
 
          by the computer is conspicuously displayed to the consumer, along  
 
          with any price reductions, taxes, surcharges and the total amount of  
 
          the transaction, and authorized enforcement by local governments.



           SB 369  (Kopp, 1997) would have required DFA to adopt regulations  
 
          relating to retail scanner accuracy, including regulations to verify  
 
          the accuracy of advertised prices, price representations and  
 
          computations related to retail scanners.  This bill would have  
 
          authorized counties to charge the owner or operator of retail  
 
          scanners an annual registration fee to recover the costs of  
 
          inspection and make other requirements.  (  Status:  SB 369 died in the  
 
          Assembly Appropriations Committee.)


       6.Arguments in Opposition.   California Agricultural Commissioners and  
          Sealers Association  (CACASA) shares the Author's concern that the  
          Division of Measurement Standards is an integral resource for  
          California consumers and badly needs additional funding, but argues  
          that the bill provides for the collection of a fee on businesses to  
          help fund the DFA in return for relaxed consumer protection laws.   
          CACASA argues the bill would dilute the law by allowing retailers to  
          "pass" mandatory annual price verification inspections even in cases  
          when an overcharged item is discovered during the course of the  
          test.  The measure would prevent the county sealer from taking  
          action on these overcharges.  CACASA insists that, in all cases,  
          consumers deserve the right to accurate and fair commercial  
          transactions.  Lowering the bar for compliance will only serve to  
          decrease necessary efforts to comply with the law.

       Concerning the April 21 amendments to this bill, CACASA states that the  





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          amendments do not remove their opposition, stating:  "First, the  
          language specifying that the signage promoting the required 'policy'  
          to refund a consumer for an overcharged item is 'conspicuous' is not  
          an acceptable substitute for strict liability independent  
          enforcement.  Consumers are encouraged to be vigilant, but are not  
          expected to police the industry.  Second, the removal of the fines  
          and penalties for the discovery of an overcharged item also removes  
          any tools that the county sealers currently employ to encourage  
          compliance.  The current fines for a single overcharge are small  
          (typically $100 or less), but they are used effectively to bring the  
          matter to the attention of the retailer."

       7.Suggested Amendments.  The following amendments are suggested by  
          Committee staff to clarify and correct the bill:

           a)   The Author's stated intent is to keep the 100% accuracy  
 
             compliance rate to pass a POS inspection in California, but allow  
 
             for one overcharge before a fine is assessed.  The intent is that  
 
             when one violation is found, that a written violation would be  
 
             issued, but no fine would be imposed.  However, the latest  
 
             amendments provide that a store:  "shall not be fined or assessed  
 
             any other penalty for the fist item not in compliance?"  It  
 
             appears that it could be argued that a grocery store could not  
 
             even be issued a written violation for the first item out of  
 
             compliance.  Staff recommends the following clarifying amendment  
 
             on page 4 lines, 29 through 39: 



               (d) (1) Notwithstanding any other law, a grocery store that  
 
               meets the requirements of paragraph (2)  may be issued a written  
 
               violation but  shall not be fined or assessed any other penalty  
 
               for the first item not in compliance during an initial standard  





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               inspection.


           b)   The bill refers to a grocery store policy for a refund or free  
 
             item:  "if the amount charged for the item is greater than the  
 
             price advertised, posted, marked, displayed, or quoted."  By  
 
             specifying the refund or free item is given when the "the amount  
 
             charged" is greater, some grocers could argue that the customer  
 
             would first have to pay the higher price for the item, in order  
 
             to be eligible for the refund or free item.  Staff suggests the  
 
             following clarifying amendment on page 5, lines 1 through 6:


               (2) (A) The grocery store has a policy to refund the amount of  
               the product, or to provide the product free of charge, if the  
               amount  charged   displayed or computed by the POS checkout  
               register  for the item is greater than the price advertised,  
               posted, marked, displayed or quoted.

           c)   This bill refers to "each checkout location" however BPC �  
 
             13350, which this bill amends consistently uses the term  
 
             "checkout registers."  Staff suggests the following conforming  
 
             amendment:



               On page 5, line 6, strike out "location" and insert "register"



           d)   The latest amendments appears to contain a drafting error.   
 
             Staff recommends the following correcting amendment:







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               On page 5, line 7 strike out "(C) The entire store"



       8.Suggested Author's Amendment.  Committee staff suggests amendments to  
          place a 3 year sunset (January 1, 2018) on BPC � 13350 (d), as added  
          by this bill, which specifies that a grocery store displaying a  
          refund or no charge policy for overcharged items, may be issues a  
          written violation but shall not be fined or assessed any other  
          penalty for the first item that is not in compliance during an  
          initial standard inspection.  


        SUPPORT AND OPPOSITION:
        
         Support:  

        California Grocers Association (Sponsor)

         Opposition:  

        California Agricultural Commissioners and Sealers Association
        Los Angeles County Board of Supervisors


        Consultants:Vincent Chee/G.V. Ayers