an expert said that if one took a bucket of water and dumped it in the ocean, that was a “substantial contributing factor” to the size of the ocean. [The expert’s] statement saying every breath is a “substantial contributing factor” is not accurate. If someone walks past a mechanic changing brakes, he or she is exposed to asbestos. If that person worked for thirty years at an asbestos factory making lagging, it can hardly be said that the one whiff of the asbestos from the brakes is a “substantial” factor in causing disease. Id. at 244 (opinion in support of affirmance) (emphasis in original). Judge Colville acknowledged the plaintiffs’ position found some support in the Superior Court’s decisions in Smalls and Andaloro v. Armstrong World Industries, Inc., 799 A.2d 71 (Pa.Super.2002) (<HOLDING>). Nevertheless, he reasoned that Smalls did not
holding that a cause of action on the theory of strict liability may be properly pled by alleging 1 the manufacturers relationship to the product in question 2 the unreasonably dangerous condition of the product and 3 the existence of a proximate causal connection between the condition of the product and the plaintiffs injury holding inter alia that the issue of whether a naval yard worker was exposed to a manufacturers product was for the jury holding that a victim impact aggravator was not unconstitutionally vague because it directed the jury to consider inter alia the effect of the crime on the victims family holding inter alia that common law claims were preempted holding inter alia that expert testimony was not required to prove damages for emotional distress in an abuse of process claim