On July 9, 2014, the California Supreme Court granted writs in Ramos v. Brenntag Specialties, Inc., 169 Cal. Rptr. 3d 513 (Cal. Ct. App. 2014), to determine if, as matter of law, the “component parts” doctrine is alive and well, or its time has passed. Under the “component parts” doctrine (and the related “bulk supplier” and “sophisticated buyer” defenses), manufacturers of a component part incorporated into an end product or suppliers of bulk, raw materials have limited exposure to liability. Because many times “what happens in California does not stay in California,” component manufacturers and suppliers of raw materials should closely follow the Ramos decision.
The plaintiff in Ramos worked as a machine operator in a metal product foundry. He worked with and around silica sand, limestone, marble, plaster, and zircon sand, all of which were melted and used in the manufacturing process where plaintiff worked. Plaintiff’s air-borne exposure to fumes from these raw materials labeled as “products” allegedly caused Plaintiff to sustain interstitial pulmonary fibrosis in his lungs.
The trial court granted a motion to dismiss the plaintiff’s complaint at the pleadings stage on the grounds that the facts alleged in his complaint were barred, as a matter of law, under California’s “bulk supplier,” “sophisticated buyer,” and “component parts” doctrines (collectively referred to as the “component parts” doctrine). The California Fourth Circuit reversed the trial court, see Ramos v. Brenntag Specialties, Inc., 169 Cal. Rptr. 3d 513 (Cal. Ct. App. 2014), holding that the plaintiff had stated product liability claims upon which relief could be granted.The Ramos circuit court distinguished and limited the application of the “component parts”, the “sophisticated buyer,” and the “bulk supplier” doctrines based upon the following reasoning:
- The “component parts” doctrine only applies to harm caused by a “finished product” or “end product” into which the component manufacturer’s product has been incorporated. In contrast, the plaintiff, Ramos, alleged a direct injury from the intended use of the the component product or bulk material “product” ―not from any finished product. Therefore, the doctrine did not apply.
- The court ruled that the plaintiff’s employer—a foundry that used raw materials (or “products”) for years—was not a “sophisticated buyer” because the plaintiff had not alleged the facts to satisfy the elements of the “sophisticated buyer” defense;
- Even if the plaintiff’s employer were a “sophisticated buyer,” the “sophisticated buyer” defense does not shield the supplier of bulk materials from a defective warnings claim unless the supplier can show that it had reason to believe the worker using its “product” knew, or should have known, of the product’s hazards.
- Finally, the Ramos court held that the “bulk supplier” doctrine did not apply to the claims by plaintiff that he had been injured by exposure to these bulk material “products” because the plaintiff had alleged that these raw materials were “specialized materials sold for use in the metal casting manufacturing process” and had not asserted that the materials were “basic raw materials.”
A decision by the California Supreme Court in Ramos ruling in favor of plaintiff may establish product liability exposures that component manufacturers and bulk suppliers never knew they had.