> Insights > Client Alert: Woo v. General Electric Co., et al.

No. 74458-5-I | April 3, 2017

> Insights > Client Alert: Woo v. General Electric Co., et al.

No. 74458-5-I | April 3, 2017

Client Alert: Woo v. General Electric Co., et al. No. 74458-5-I | April 3, 2017

April 20, 2017Client Alerts

Significance

The Washington State Court of Appeals narrowed the holding of Simonetta/Braaten stating that a manufacturer has a duty to warn of the hazards of asbestos-containing products that it did not produce or supply where the manufacturer knew that the asbestos-containing products were necessary to the function of its own product.

Facts

Woo worked as an engineer for the Navy maintaining propulsion steam equipment in the 1940s and 1950s.  The equipment required the use of asbestos-containing thermal heat insulation, gaskets, and packing to properly function.  Defendant supplied the original gaskets installed in the turbines; but, the insulation, packing, and replacement gaskets were procured by the military from third-party manufacturers. 

Holding

The Court focused on a Technical Information Letter (“TIL”) issued by defendant in 1989 which advised customers of the potential locations of asbestos-containing materials” and provide information on “non-asbestos substitutes which are now commercially available.” Accordingly, the Court held that the Defendant had a duty to warn of the hazards of asbestos-containing insulation, packing, and gaskets manufactured by others.

The Woo ruling narrows the 2008 Washington State Supreme Court’s holding that a manufacturer is not responsible for the asbestos contained in another manufacturer’s product that it did not place in the steam of commerce  Simonetta v. Viad Corp., 165 Wn.2d 341, 262-63 (2008); Braaten v. Saberhagen Holdings, 165 Wn.2d 373 (2008).1

 

1 The Braaten Court did not reach the question of whether a duty to warn “might arise with respect to the danger of exposure to asbestos-containing products specified by the manufacturer to be applied to, in, or connected to their products, or required because of a peculiar, unusual, or unique design.”  165 Wn.2d at 397.

Related Practice Areas & Industries

View All Practice Areas & Industries

Related Locations

View All Locations

Related Professionals

View All Professionals

Recent News & Insights

  • Foley Mansfield Earns National Ranking in 2026 Chambers USA Guide for Products Liability & Mass Torts

    Foley Mansfield is pleased to announce its recognition in the 2026 Chambers USA Guide, earning a national ranking in Products Liability & Mass Torts – Nationwide, Highly Regarded....

  • California Assistant Managing Partners Earn Prestigious Certification Following Intensive Executive Education Program at Harvard Law School in Cambridge

    CALIFORNIA — Foley Mansfield, PLLP is proud to announce that Angela V. Sayre and Suzanna Minasian, the Assistant Managing Partners of the firm’s California offices located in Los...

  • Foley Mansfield Welcomes 2026 Summer Associate Class Across Four National Offices

    Foley Mansfield is pleased to welcome its 2026 Summer Associate class, comprised of talented law students from four distinguished law schools across the nation including Bhargav Nannapaneni of...

  • Summary Judgment Secured for New York Municipal Client

    New York, NY - Congratulations to Foley Mansfield New York litigation team including, Dennis Vega, Michael Tuttle and William Miedel, on securing a win for their municipality client...