Products Liability: Component Parts Doctrine
Posted in Products Liability on February 17, 2015
Ramos v. Brenntag Specialties, (Second District, March 21, 2014) 2014 WL 1116961, 14 Cal. Daily Op. Serv. 3129, 2014 Daily Journal D.A.R. 3597, — Cal.Rptr.3d —-
A mold maker/machine operator who was diagnosed with interstitial pulmonary fibrosis brought an action against several manufacturers of metals, plaster and minerals which he had worked around for many years at a metal foundry. The plaintiff alleged that his disease was caused by on- the-job exposure to, inter alia, fumes from the molten metal and dust from plaster, sand, limestone and marble, which were used in the fabrication process. The plaintiff further alleged that although state and federal regulations identified the products or their constituents as hazardous, the defendant provided no warnings to him.
The defendants moved for judgment on the pleadings, contending that the claims were barred under Maxton v. Western States Metals (2012) 203 Cal.App.4th 81, 136 Cal.Rptr.3d 630, which addressed similar claims and held that because the metal products at issue were raw material and were not inherently dangerous, under the component parts doctrine the defendants could not be liable. Following amendments to the complaint, the trial court sustained demurrers without leave to amend.
The court of appeal reversed, disagreeing with the holding in Maxton, and holding that neither the component parts doctrine nor its underlying rationale support its application where the injuries alleged result from the direct and intended use of the defendants’ products, and not from injuries resulting from the use of any end product:
Although the doctrine may be invoked when a worker suffers injury while engaged in employment that incorporates or uses a supplier’s component part, its application has ordinarily been restricted to situations in which the injuries were attributable to an item over which the supplier lacked material control, such as the employer’s manufacturing system itself (viewed as the “finished product”), or to some other element of the system, rather than to the supplier’s component part. Here, in contrast, the FAC alleges a direct injury from the intended use of respondents’ products—not from any finished product, manufacturing system into which the products were integrated, or apparatus built to the employer’s specifications.
Apart from falling outside the letter of the component parts doctrine, the injuries alleged in the FAC also fall outside the doctrine’s rationale. The Restatement Third of Torts, Products Liability, explains that rationale in the following terms: “As a general rule, component sellers should not be liable when the component itself is not defective…. If the component is not itself defective, it would be unjust and inefficient to impose liability solely on the ground that the manufacturer of the integrated product utilizes the component in a manner that renders the integrated product defective. Imposing liability would require the component seller to scrutinize another’s product which the component seller has no role in developing. This would require the component seller to develop sufficient sophistication to review the decisions of the business entity that is already charged with responsibility for the integrated product.”) Here, the FAC alleges that Ramos suffered injuries not from a defective “integrated product” that incorporated respondents’ products, but from those products themselves, which he used as respondents intended in the course of Supreme’s manufacturing process.
When, as in the FAC, a worker alleges that he suffered injuries directly from the supplier’s product, but not from his employer’s end product, the supplier’s lack of control over the design and development of the end product is irrelevant to the rationale underlying the component parts doctrine, and thus to the supplier’s liability. In sum, insofar as Maxton determined that the component parts doctrine is applicable to claims of the type alleged in the FAC, we respectfully disagree.