KATZ, Associate Justice.
This appeal arises from a products liability action brought by the plaintiffsFN1 against the defendants, Chicago Pneumatic Tool Company (Chicago Pneumatic), Stanley Works and Dresser Industries, Inc. (Dresser). The plaintiffs claim that they were injured in the course of their employment as shipyard workers at the General Dynamics Corporation Electric Boat facility (Electric Boat) in **1325 Groton as a result of using pneumatic hand tools manufactured by the defendants. Specifically, the plaintiffs allege that the tools were defectively designed because they exposed the plaintiffs to excessive vibration, and because the defendants failed to provide adequate warnings with respect to the potential danger presented by excessive vibration.


The trial record reveals the following facts, which are undisputed for purposes of this appeal. The plaintiffs were employed at Electric Boat as “grinders,” positions which required use of pneumatic hand tools to smooth welds and metal surfaces.FN2 In the course of their employment, the plaintiffs used various pneumatic hand tools, including chipping and grinding tools, which were manufactured and sold by the defendants. The plaintiffs' use of the defendants' tools at Electric Boat spanned approximately twenty-five years, from the mid-1960s until 1987. The plaintiffs suffer from permanent vascular**1326 and neurological impairment of their hands, which has caused blanching of their fingers, pain, numbness, tingling, reduction of grip strength, intolerance of cold and clumsiness from restricted blood flow. As a result, the plaintiffs have been unable to continue their employment as grinders and their performance of other activities has been restricted. The plaintiffs' symptoms are consistent with a diagnosis of hand arm vibration syndrome. Expert testimony confirmed that exposure to vibration is a significant contributing factor to the development of hand arm vibration syndrome, and that a clear relationship exists between the level of vibration exposure and the risk of developing the syndrome.

In addition to these undisputed facts, the following evidence, taken in favor of the jury's verdict, was presented. Ronald Guarneri, an industrial hygienist at Electric*205 Boat, testified that he had conducted extensive testing of tools used at the shipyard in order to identify occupational hazards. This testing revealed that a large number of the defendants' tools violated the limits for vibration exposure established by the American National Standards Institute (institute), and exceeded the threshold limit promulgated by the American Conference of Governmental and Industrial Hygienists (conference).

Richard Alexander, a mechanical engineering professor at Texas A & M University, testified that because machinery vibration has harmful effects on machines and on people, engineers routinely research ways to reduce or to eliminate the amount of vibration that a machine produces when operated. Alexander discussed various methods available to control vibration, including isolation (the use of springs or mass to isolate vibration), dampening (adding weights to dampen vibrational effects), and balancing (adding weights to counterbalance machine imbalances that cause vibration). Alexander testified that each of these methods has been available to manufacturers for at least thirty-five years. #p#分页标题#e#

Alexander also stated that, in 1983, he had been engaged by another pneumatic tool manufacturer to perform testing of methods by which to reduce the level of vibration in its three horsepower vertical grinder. The vertical grinder had a live handle, which contained hardware for the air power, and a dead handle, which vibrated significantly more than the live handle because it weighed less. Alexander modified the design by inserting rubber isolation mounts between the handles and the housing, and by adding an aluminum rod to the dead handle to match the weight of the two handles. As a result of these modifications, which were published in 1987, Alexander achieved a threefold reduction in vibration levels.

After a six week trial, the trial court rendered judgment on jury verdicts in favor of the plaintiffs. Finding that the defendants' tools had been defectively designed so as to render them unreasonably dangerous, the jury awarded the plaintiffs compensatory damages.FN3 The jury also concluded that the manufacturers had provided inadequate warnings. Because the plaintiffs failed to prove that adequate warnings would have prevented their injuries, the jury did not **1327 award damages on that claim. Finally, the jury declined to award the plaintiffs punitive damages. This appeal and cross appeal followed. Additional facts will be provided as warranted.

We first address the defendants' argument that the trial court improperly failed to render judgment for the *207 defendants notwithstanding the verdicts because there was insufficient evidence for the jury to have found that the tools had been defectively designed. Specifically, the defendants claim that, in order to establish a prima facie design defect case, the plaintiffs were required to prove that there was a feasible alternative design available at the time that the defendants put their tools into the stream of commerce. We disagree.

Although courts have widely accepted the concept of strict tort liability, some of the specifics of strict tort liability remain in question. In particular, courts have sharply disagreed over the appropriate definition of defectiveness in design cases.FN7 As the Alaska Supreme Court has stated: “Design defects present the most perplexing problems in the field of strict products liability because there is no readily ascertainable external measure of defectiveness. While manufacturing flaws can be evaluated against the intended design of the product, no such objective standard exists in the design defect context.” Caterpillar Tractor Co. v. Beck, 593 P.2d 871, 880 (Alaska 1979).

Section 402A imposes liability only for those defective products that are “unreasonably dangerous” to “the ordinary consumer who purchases it, with the ordinary knowledge common to the community as to its characteristics.” 2 Restatement (Second), supra, § 402A, comment (i). Under this formulation, known as the *212 “consumer expectation” test, a manufacturer is strictly liable for any condition not contemplated by the ultimate consumer that will be unreasonably dangerous to the consumer. #p#分页标题#e#

This court has long held that in order to prevail in a design defect claim, “[t]he plaintiff must prove that the product is unreasonably dangerous.” Id. We have derived our definition of “unreasonably dangerous” from comment (i) to § 402A, which provides that “the article sold must be dangerous to an extent beyond that which would be contemplated by the ordinary consumer*215 who purchases it, with the ordinary knowledge common to the community as to its characteristics.” 2 Restatement (Second), supra, § 402A, comment (i). This “consumer expectation” standard is now well established in Connecticut strict products liability decisions.

The defendants propose that it is time for this court to abandon the consumer expectation standard and adopt the requirement that the plaintiff must prove the existence of a reasonable alternative design in order to prevail on a design defect claim. We decline to accept the defendants' invitation.

In support of their position, the defendants point to the second tentative draft of the Restatement (Third) of Torts: Products Liability (1995) (Draft Restatement [Third] ), which provides that, as part of a plaintiff's prima facie case, the plaintiff must establish the availability of a reasonable alternative design. Specifically, § 2(b) of the Draft Restatement (Third) provides: “[A] product is defective in design when the foreseeable risks of harm posed by the product could have been reduced or avoided by the adoption of a reasonable alternative design by the seller or other distributor, or a predecessor in the commercial chain of distribution, and the omission of the alternative design renders the product not reasonably safe.” The reporters to the Draft Restatement (Third) state that “[v]ery substantial authority supports the proposition that [the] plaintiff must establish a reasonable alternative design in order for a product to be adjudged defective in design.” Draft *216 Restatement (Third), supra, § 2, reporters' note to comment (c), p. 50.

We point out that this provision of the Draft Restatement (Third) has been a source of substantial controversy among commentators. See, e.g., J. Vargo, “The Emperor's New Clothes: The American Law Institute Adorns a ‘New Cloth’ for Section 402A Products Liability Design Defects-A Survey of the States Reveals a Different Weave,” 26 U.Mem.L.Rev. 493, 501 (1996) (challenging reporters' claim that Draft Restatement (Third)'s reasonable alternative design requirement constitutes “consensus” among jurisdictions); P. Corboy, “The Not-So-Quiet Revolution: Rebuilding Barriers to Jury Trial in the Proposed Restatement (Third) of Torts: Products Liability,” 61 Tenn.L.Rev. 1043, 1093 (1994) (“[t]he decisional support for [the reasonable alternative design requirement], however, appears to be overstated by the Reporters, who claim that [eighteen] states support the rule”); F. Vandall, “The Restatement (Third) of Torts: Products Liability Section 2(b): The Reasonable Alternative Design Requirement,” 61 Tenn.L.Rev. 1407, 1428 (1994) (“The centerpiece of the Restatement (Third) of Torts: Products Liability is the requirement that the plaintiff present evidence of a reasonable alternative design as part of her prima facie case. This requirement is not supported by the majority of the jurisdictions that have considered the question.”). Contrary to the rule promulgated in the Draft Restatement (Third), our independent review of the prevailing common law reveals that the majority of jurisdictions do not impose upon plaintiffs an absolute requirement to prove a feasible alternative design. #p#分页标题#e#

In our view, the feasible alternative design requirement imposes an undue burden on plaintiffs that might preclude otherwise valid claims from jury consideration.FN12 Such a rule would require plaintiffs to retain an expert witness even in cases in which lay jurors can *218 infer a design defect from circumstantial evidence. Connecticut courts, however, have consistently stated that a jury may, under appropriate circumstances, infer a defect from the evidence without the necessity of expert testimony. See, e.g., Standard Structural Steel Co. v. Bethlehem Steel Corp., 597 F.Supp. 164, 183 (D.Conn.1984) (recognizing Connecticut law permits fact finder to draw inference of defect from circumstantial evidence); Living & Learning Centre, Inc. v. Griese Custom Signs, Inc., 3 Conn.App. 661, 664, 491 A.2d 433 (1985) (“It is not necessary that the plaintiff in a strict tort action establish a specific defect as long as there is evidence of some unspecified dangerous condition. In the absence of other identifiable causes, evidence of malfunction is sufficient evidence of a defect under § 402A of the Second Restatement of Torts.”); Kileen v. General Motors Corp., 36 Conn.Supp. 347, 349, 421 A.2d 874 (1980) (“[t]he fact finder can find, where other identifiable causes are absent, that the mere evidence of a malfunction is sufficient evidence of a defect”); see also annot., 65 A.L.R.4th 346, 354-58 (1988) (listing twenty-eight states that allow establishment of prima facie case of design defect based upon inferences from circumstantial evidence).

Moreover, in some instances, a product may be in a defective condition unreasonably dangerous to the user even though no feasible alternative design is available. In such instances, the manufacturer may be strictly liable for a design defect notwithstanding the fact that there are no safer alternative designs in existence. See, e.g., O'Brien v. Muskin Corp., 94 N.J. 169, 184, 463 A.2d 298 (1983) (“other products, including some for which no alternative exists, are so dangerous and of such little use that ... a manufacturer would bear the cost of liability of harm to others”); Wilson v. Piper Aircraft Corp., 282 Or. 61, 71 n. 5, 577 P.2d 1322 (1978) ( “Our holding should not be interpreted as a requirement that [the practicability of a safer alternative design] must in all cases weigh in [the] plaintiff's favor before **1333 the case can be submitted to the jury. There might be cases in which the jury would be permitted to hold the defendant liable on account of a dangerous design feature even though no safer design was feasible (or there was no evidence of a safer practicable alternative).”); Sumnicht v. Toyota Motor Sales, U.S.A., Inc., 121 Wis.2d 338, 371, 360 N.W.2d 2 (1984) (“[a] product may be defective and unreasonably dangerous even though there are no alternative, safer designs available”). Accordingly, we decline to adopt the requirement that a plaintiff must prove a feasible alternative design as a sine qua non to establishing a prima facie case of design defect. #p#分页标题#e#

Although today we adopt a modified formulation of the consumer expectation test, we emphasize that we do not require a plaintiff to present evidence relating to the product's risks and utility in every case. As the California Court of Appeals has stated: “There are certain kinds of accidents-even where fairly complex machinery is involved-[that] are so bizarre that the average juror, upon hearing the particulars, might reasonably think: ‘Whatever the user may have expected from that contraption, it certainly wasn't that.’ ” Akers v. Kelley Co., 173 Cal.App.3d 633, 651, 219 Cal.Rptr. 513 (1985). Accordingly, the ordinary consumer expectation test is appropriate when the everyday experience of the particular product's users permits the inference that the product did not meet minimum safety expectations. See Soule v. General Motors Corp., 8 Cal.4th 548, 567, 882 P.2d 298, 34 Cal.Rptr.2d 607 (1994).

Conversely, the jury should engage in the risk-utility balancing required by our modified consumer expectation test when the particular facts do not reasonably permit the inference that the product did not meet the safety expectations of the ordinary consumer. See id., at 568, 34 Cal.Rptr.2d 607, 882 P.2d 298. Furthermore, instructions based on the ordinary consumer expectation test would not be appropriate when, as a matter of law, there is insufficient evidence to support a jury verdict under that test. See id. In such *223 circumstances, the jury should be instructed solely on the modified consumer expectation test we have articulated today.

With these principles in mind, we now consider whether, in the present case, the trial court properly instructed the jury with respect to the definition of design defect for the purposes of strict tort liability. The trial court instructed the jury that a manufacturer may be strictly liable if the plaintiffs prove, among other elements, that the product in question was in a defective condition, unreasonably dangerous to the ultimate user.FN17 The court further instructed the jury **1335 that, in *224 determining whether the tools were unreasonably dangerous, it may draw its conclusions based on the reasonable expectations of an ordinary user of the defendants' tools. Because there was sufficient evidence as a matter of law to support the determination that the tools were unreasonably dangerous based on the ordinary consumer expectation test, we conclude that this instruction was appropriately given to the jury.