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 March 24, 2021, the CPSC announced the following recall related to a product that presents a fire hazard:

Flame King Recalls Hog 100-Pound Propane Cylinders Due to Fire Hazard.

According to the CPSC, “[t]he propane cylinders manufactured with a handle below the weld on the side could leak propane gas, posing a fire hazard.”