What is the Component Part/Raw Material Doctrine?
This article discusses the "Component Part/Raw Material Doctrine" defense used in product liability actions and summmarizes the important factors that the Courts apply in determining whether a supplier or manufacturer is exempt from liability for a defect in the final product for which the part was assembled.
The General Motors and Chrysler bankruptcies resulted in a new era of claims against automotive suppliers. With the primary defendants (i.e, the car manufacturer) unable to provide the financial compensation to many catastrophically injured plaintiffs, the attorneys were more likely to join and pursue claims against the automotive part suppliers (most notable seat belt suppliers). While suppliers were joined in crashworthiness cases pre-bankruptcy, the supplier claims were often secondary to the primary automotive defendant and involved smaller payouts or were used primarily for discovery purposes. Where the suppliers were primary defendants, the claims against the supplier were generally limited to manufacturing defect cases involving fractures or failed performance. Due to the limited recovery against the automotive manufacturers, the post-bankruptcy era brought new types of claims focused on the role of the suppliers in the overall design process of the restraint systems. In some cases, the defendants have responded by raising the “component part doctrine” defense.
A. Component Part Doctrine
The component part/raw material doctrine (CPRM) cuts off liability where there is sufficient distance between the raw part manufacturer and the ultimate user of the product who is injured. It is a legal duty analysis that limits strict liability and negligence claims under specific situations where the relationship is too remote.
CPRM stands for the proposition that:
Making suppliers of inherently safe raw materials and component parts pay for the mistakes of the finished product manufacturer would not only be unfair but would impose an intolerable burden on the business world. Suppliers of versatile materials like chains, valves, sand, gravel, etc. cannot be expected to become experts in the infinite number of finished products that might conceivably incorporate their multiuse raw materials or components.
The CPRM applies to bulk manufacturers and manufacturers of raw parts that can be used in many different types of end products. CPRM has also been applied where the part is pre-fabricated and sold wholesale in same form to numerous purchasers. Good examples of the type of product subject to this defense are chains, fertilizer products, sand, gas valves, foam, raw asbestos. To fit within the CPRM, and cut off liability for strict liability, the component part is generally raw materials or multi-use, where the manufacturer has limited or no knowledge of the use of the product, and it would pose severe financial burden on the part manufacturer to review the design.
See, Childress v. Gresen Mfg. Co., 888 F.2d 45, 49 (6th Cir. 1989; In re TMJ Implants Product Liability Litigation, 8th Cir. 1996) 97 F.3d 1050, 1057; Hill v. Wilmington Chem. Corp., 156 N.W.2d 898 (Minn. 1968)(Chemical solvent sold in bulk to unknown end users and could be used in a variety of ways; In re Silicone Gel Breast Implant Prods. Liab. Litig., 887 F.Supp 1463 (N.D. Ala., 1995) (The case involved bulk foam and an unknown end user. Court held that manufacturers of bulk foam which has hundreds of uses, not liable for failing to warn consumers when its product was utilized by breast-implant manufacturers as one component in composition of the implant); Kanesko v. Hilo Coase Processing, 654 P.2d 343 (Haw. 1982)(Prefabricated girders for buildings)
Jones v. Serv. Inc., 549 P.2d 1383 (Kan. 1976)(Wholesale manufacturer of propane gas sold in bulk in same form to numerous users.); Crossfield v. Quality Control Equip. Co., 1 F.3d 701 (8th Cir. 1993)(the chain could be put to use in numerous machines and settings and sold generally to many users)Port Authority of NY and NJ v. Acadian Corp., 189 F.3d 305 (3rd Cir. 1999)(Fertilizer products not dangerous until transformed by terrorists into energized materials and suitable for use in many other applications); Smith v. Walter C. Best, Inc. 927 F.2d 736 (3rd. Cir. 1990((applying Ohio law)(sand was bulk material use merous ways by numerous entities); see also, Goodbar v. Whithead Bros., 591 F.Supp. 552 (W.D. Va. 1984); Dougherty v. Edward J Meloney, Inc., 661 A.2d 375 (Pa. Sup. Ct. 1995)(involved gas valves used in a variety of commercial boilers )Gray v. Derderian, 365 F. Supp, 2d 218 (D. R.I., 2005)(multi use foam not designed for specific user or purpose); Cimino v. Raymark Industries, IOnc. 151 F.3d 297 (5th Cir)(supplied raw asbestos that could be used in numerous industrial products);Cipollone v. Yale Industrial Products Inc. 202 F.3d 376 (1st Cir. 2000). (End user was unknown and the loading dock was of a general design and interchangeable at many different loading docks.)