What is the test for punitive damages in medical malpractice cases?

In West v. Johnson & Johnson Products, Inc. (1985) 174 Cal.App.3d 831, 868 to 870, the evidence supported a punitive damages instruction where the testimony was that the defendant had received continuing customer complaints about vaginal infection but inadequately tested its own product. As adequate testing would have revealed an association between use of its product and vaginal infection, there was substantial evidence that the defendant had acted in conscious disregard of the safety of others. (Id. at p. 869.)