Products Liability: Component Parts Doctrine
Posted in Products Liability on June 3, 2015
Uriarte v. Scott Sales Co., (Second District, June 13, 2014) 226 Cal.App.4th 1396, 172 Cal.Rptr.3d 886, 14 Cal. Daily Op. Serv. 6588, 2014 Daily Journal D.A.R. 7553
A man who worked as a sandblaster filed suit against the manufacturers and suppliers of silica sand purchased by his employer, contending that the airborne toxins produced by sandblasting with their product caused him to develop interstitial pulmonary fibrosis and other illnesses. The plaintiff alleged that the sandblasting media supplied by the defendants, when used in the manner intended by the manufacturers and suppliers, resulted in the generation and release of toxicologically significant amounts of toxic airborne fumes and dust.
The defendants moved for judgment on the pleadings on the basis of the component parts doctrine, which provides that the manufacturer of a component part is not liable for injuries caused by the finished product into which the component has been incorporated unless the component itself was defective and caused harm. The trial court granted the motions but the court of appeal reversed, concluding that because the plaintiff’s injuries were allegedly caused by the use of the silica sand during the manufacturing process, rather than by the finished product, the component parts doctrine did not apply, disagreeing with the interpretation and application of the component parts doctrine articulated in Maxton v. Western States Metals (2012) 203 Cal.App.4th 81, 136 Cal.Rptr.3d 630:
Here, Uriarte does not allege that the silica sand supplied by Scott and Simplot was incorporated into finished products that caused him harm—he does not allege that his injuries were caused by Lubeco’s finished products at all. Rather, he alleges that Scott’s and Simplot’s silica sand was used in Lubeco’s manufacturing process in the manner intended by Scott and Simplot, and that he was injured in the course of that process by that intended use of the silica sand. The component parts doctrine therefore does not apply.
In addition to being inapplicable by its own terms, the component parts doctrine is inapplicable as a matter of policy. As explained by the Restatement Third, the purpose of the doctrine is to protect sellers of nondefective components by prohibiting the imposition of liability that is based “solely on the ground that the manufacturer of the integrated product utilizes the component in a manner that renders the integrated product defective.” (citation) The rationale is that “[i]mposing liability would require the component seller to scrutinize another’s product which the component seller has no role in developing” and 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.” …
No part of that rationale applies here, because Uriarte was not injured by an integrated product into which Scott’s and Simplot’s silica sand was allegedly incorporated as a component. Rather, he alleges that he was injured by both his use and his coworkers’ use of the silica sand in precisely the way intended by its sellers, Scott and Simplot. His theory of liability thus does not require Scott or Simplot to scrutinize Lubeco’s products or review Lubeco’s business decisions. Scott and Simplot need only scrutinize their own products and warn about the scientifically known dangers of using those products in the manner that Scott and Simplot intend them to be used. That is not a novel requirement under California law.