In subrogation cases where the insured’s damages were caused by a defective product, the fact that the product at issue is or was subject to a recall announced by the Consumer Product Safety Commission (CPSC) may help to establish that the product was defective when it left the manufacturer’s possession and control. On February 24, 2021, the CPSC announced the following recalls related to products that present fire-related hazards:

1. Urban Outfitters Recalls Margo Taper Candle Holders Due to Fire Hazard. According to the CPSC, “[t]he candle holders can catch on fire if they come in contact with the candle’s flame, posing a fire hazard.”
2. Potter Electric Recalls Addressable Pull Stations Single/Dual Action Due to Failure to Alert to Fire. According to the CPSC, “[t]he pull handle on some units can fail to activate the fire alarm system when manually pulled, posing a risk of failure to alert consumers to a fire.”