Component Parts Doctrine Inapplicable to Suppliers of Silica Sand Used in Manufacturing Process
The California Court of Appeal, Second Appellate Division, reached a decision in the toxic tort case of Francisco Uriarte v. Scott Sales, Inc., et al. (2014 Cal. App. LEXIS 518), last week in which it reversed a Los Angeles trial court’s order dismissing Mr. Uriarte’s claim at the pleading stage. The Court addressed the issue of whether the distributor of a product used in the manufacturing process rather than in the finished product can escape liability through the component parts doctrine and determined that the component parts doctrine does not apply.
In reaching this conclusion, the Court agreed with the component parts doctrine interpretation in Ramos v. Brenntag Specialties, Inc. (2014) 224 Cal.App.4th 123) and disagreed with the component parts doctrine interpretation in Maxton v. Western States Metals (2012) 203 Cal.App.4th 81. The Court also noted that the allegations in Tellez-Cordova v. Campbell-Hausfeld/Scott Fetzger Company (2004) 129 Cal.App.4th 577 were not materially distinguishable from the allegations alleged by Mr. Uriarte.
In this personal injury case filed by the Metzger Law Group, Mr. Uriarte claimed that from 2004 to 2008 he worked as a sandblaster for Lubeco, Inc., where he used silica sand supplied by a number of distributors. When Mr. Uriarte and his coworkers used the silica sand in the manner intended by the distributors, such use “resulted in the generation and release of toxicologically significant amounts of toxic airborne fumes and dusts” which Mr. Uriarte “was thereby exposed to and inhaled.” Mr. Uriarte claimed he developed interstitial pulmonary fibrosis and other injuries as a result of this exposure.
The Court determined that as articulated in both O’Neil and the Restatement Third of Torts, Products Liability, the component parts doctrine does not apply to the facts alleged by Mr. Uriarte. Rather, the component parts doctrine, when it applies, shields a component part manufacturer from liability “for injuries caused by the finished product into which the component has been incorporated.” O’Neil v. Crane Co. (2012) 53 Cal.4th 335, 355. The doctrine concerns “harm to persons or property caused by a product into which the component is integrated.” Restatement Third, § 5.
The Court noted that no California case other than Maxton has extended the component parts doctrine to apply to injuries caused during the manufacturing process in which the defendant’s product was used as intended, rather than injuries caused by the finished product that were the result of that process. The Court concluded that the component parts doctrine is inapplicable to the facts set forth by Mr. Uriarte because he did not allege he was injured by a finished product into which the defendants’ silica sand was incorporated. Rather, he alleged that the use of the silica sand itself, in precisely the way the distributors intended it to be used, caused his injuries.