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 November 12, 2021, the CPSC announced the following recall related to a product that presents a fire hazard:

RH Recalls Outdoor Torches Due to Fire Hazard (Recall Alert).

According to the CPSC’s website, “[t]orch fuel can leak from the top of the torch canister and ignite, posing a fire hazard.”