The California Supreme Court has agreed to review a lower appeals court’s ruling on the application of the component parts doctrine in a metal worker’s suit claiming lung injury. See Ramos, et al. v. Brenntag Specialties Inc., et al., No. B248038 (Cal. review granted 7/9/14).
In Ramos v. Brenntag Specialties, Inc. , 224 Cal.App.4th 123, the court had disagreed with the well-reasoned opinion in Maxton v. Western States Metals, 203 Cal.App.4th 81 (2012).
Generally, suppliers of raw materials to manufacturers cannot be liable for negligence, or under a strict products liability theory, to the manufacturers‘ employees who sustain personal injuries as a result of using the raw materials in the manufacturing process. Only in extraordinary circumstances —such as when the raw materials are contaminated, the supplier exercises substantial control of the manufacturing process, or the supplier provides inherently dangerous raw materials— can suppliers be held liable. Product components include raw materials, bulk products, and other constituent products sold for integration into other products. The products at issue in these cases clearly are mere raw materials because they could be used in innumerable ways, and they were not sold directly to consumers in the market place. Rather, they were sold to plaintiff‘s employer for the purpose of using them to manufacture other products.
Under California law, component and raw material suppliers are not liable to ultimate consumers when the goods or material they supply are not inherently dangerous, they sell goods or material in bulk to a sophisticated buyer, the material is substantially changed during the manufacturing process, and the supplier has a limited role in developing and designing the end product. When these factors exist, the social cost of imposing a duty to the ultimate consumers or users far exceeds any additional protection provided. The rationale for not imposing liability on a supplier of product components is a matter of equity and public policy. Such suppliers ordinarily do not participate in developing the product components into finished products for consumers. Imposing liability on suppliers of product components would force them to scrutinize the buyer-manufacturer‘s manufacturing process and end-products in order reduce their exposure to lawsuits. This would require many suppliers to retain experts in a huge variety of areas, especially if the product components are versatile raw materials. Courts generally do not impose this onerous burden on suppliers of product components because the buyer- manufacturer is in a better position to ensure safety.
In Ramos, a different lower appellate court rejected the argument that raw material suppliers are not liable for injuries caused by finished products that use those raw materials. Hopefully, the California Supreme Court will clarify.