California Court of Appeal Holds Supplier of Mineral Spirit Used in Cleaning Solvent Not Entitled to Component Parts Doctrine Defense

Recently, the California Court of Appeal addressed whether a raw materials supplier of mineral spirits was entitled to a defense from tort liability, the component parts doctrine.  In this case, the distributor provided a product used in a cleaning solvent that allegedly caused the plaintiffs’ leukemia. The component parts doctrine allows suppliers and distributors of non-inherently dangerous materials to avoid liability.  The court discussed the rationale behind the doctrine, stating that the defendant had not shown that their mineral spirits were not inherently dangerous.

Plaintiffs Ernest Brady and David Gibbs both worked as mechanics from 1989 to 2007, and 1973 to 2006, respectively.  Part of their duties included degreasing and scrubbing automotive parts, using Safety-Kleen 105 Solvent.  In 2008, the plaintiffs brought separate products liability lawsuits against Safety-Kleen and its suppliers. The cases were consolidated, and Calsol was added as a defendant. Calsol was a distributor of mineral spirits to Safety-Kleen between 1993 and 1996.

The plaintiffs alleged causes of action against Calsol for negligence, strict liability, breach of implied warranties, and loss of consortium.  In their complaint, the plaintiffs contended their leukemia was caused by the carcinogen benzene.  Benzene was present in the mineral spirits supplied to Safety-Kleen.

At issue was a dispute about the level of benzene found in the mineral spirits that were supplied to Safety-Kleen. Calsol contended that these were low concentrations, while the plaintiffs asserted that Safety-Kleen had tested the spirits and were aware they held benzene at concentrations that may cause harm.

Calsol moved for summary judgment, which was granted by the trial court.  The plaintiffs appealed.

The court stated that products liability cases rely on either strict liability or negligence. The plaintiff must prove that a defect in the product caused an injury. In a negligence claim, the plaintiff must show the defect in the product was the result of the defendant’s negligence. In this case, the plaintiffs alleged design and warning defects, claims based on strict liability as well as negligence.

Calsol moved for summary judgment based on the component parts, or raw materials, doctrine.  This holds that a seller of components is subject to liability for harm caused by the end product if the component itself has a defect, or the seller substantially participated in integrating the component into the end product, and this integration caused the product to be defective.  The rationale is that component sellers should not be liable when the component itself is not defective.

The law regarding defective products holds that defective products have a manufacturing or design defect, or are inadequately labeled. In the case of raw materials that are defective or contaminated, the seller of the raw material is subject to liability for harm caused by the defects.

The court reviewed cases in which suppliers of products that are not inherently dangerous, such as silicone, were protected by the component parts doctrine.  In the present situation, Calsol argued that the mineral spirits supplied to Safety-Kleen were not inherently dangerous.  Based on the factors articulated in another California case, Carsol also needed to show they were sold in bulk to a sophisticated buyer, the mineral spirits were substantially changed during the manufacturing process, and the company had a limited role in developing and designing the final product.

Calsol argued that the component parts doctrine does not require showing a component is not “inherently dangerous.”  The plaintiffs argued that mineral spirits are inherently dangerous because they contain a known carcinogen, benzene.  Since there was a triable issue of fact as to whether the mineral spirits had a carcinogen, the plaintiffs argued the defendant should not prevail under the component parts doctrine.

The appellate court stated that mineral spirits, unlike asbestos, are an ingredient with legitimate uses.  Similar to knives, these chemicals can be deemed useful, although also dangerous.  The policy of not holding a manufacturer liable for a part that is not inherently dangerous lies in making sure the suppliers need not become experts in the “infinite number of finished products” containing their materials or components. However, a supplier should understand the dangers inherent in its own product.

Here, the court stated that Calsol did not address whether mineral spirits are inherently dangerous. The company failed to  establish a complete defense based on the component parts doctrine. The court found a triable issue remained regarding whether the mineral spirits supplied by Calsol were in fact inherently dangerous.

The appellate court reversed the summary judgment and remanded the case for further proceedings.

The personal injury attorneys at Sharifi Firm help individuals injured throughout Southern California understand their legal rights and obligations. We provide a free, confidential consultation and can be reached by calling 866-422-7222.

More Blog Posts:

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California Court of Appeals Holds Government Not Liable for Risks Inherent in Use of Tree Rope Swing Located In County Park, Southern California Injury Lawyer Blog, December 15, 2015

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