## Facts

- Ivy Edwards, an illiterate golf-course groundskeeper, applied Ortho Standard Lead Arsenate to golf greens at the Boca Raton Hotel and Country Club.
- The insecticide contained lead arsenate, a highly toxic substance that could be absorbed by inhalation, skin contact, or ingestion.
- The product bag included detailed application and mixing directions and displayed “poison” warnings with skull-and-crossbones symbols and cautions not to inhale, ingest, or allow skin contact.
- The label did not state that safe use required a respirator or special protective clothing (e.g., rubber or neoprene).
- Edwards became ill with arsenic poisoning and alleged the manufacturer and distributor negligently failed to warn about necessary protective equipment.

## Issues

1. Whether the adequacy of a toxic product’s warning label—particularly the omission of warnings to use a respirator and protective clothing—could be resolved as a matter of law on summary judgment.
2. Whether, under negligence principles, a manufacturer/distributor’s duty to warn may require specific instructions about protective measures needed for safe use.

## Decision

- The Florida District Court of Appeal reversed the trial court’s summary judgment for the manufacturer and distributor and remanded.
- The court held that, given the product’s toxicity and the alleged omission of key safety instructions, the warning’s adequacy presented a jury question.
- The Florida Supreme Court denied certiorari, leaving the appellate decision in place.

## Legal Principles

- In negligence failure-to-warn claims, the adequacy and reasonableness of product warnings are generally questions of fact for the jury when reasonable jurors could disagree.
- For highly toxic or inherently dangerous products, reasonable care in warning may require more than a general “poison” label and generic cautions; it may require stating specific precautions and protective equipment necessary for safe use.
- Summary judgment is improper where the evidence permits a finding that the warning did not adequately inform foreseeable users of the hazard and the practical steps required to avoid it.

## Conclusion

The court allowed the failure-to-warn negligence claim to proceed because a jury could reasonably find that labeling a highly toxic insecticide as “poison,” without expressly warning that safe use required a respirator and protective clothing, was an inadequate warning.


Edwards v. California Chemical Co., 245 So. 2d 259 (Fla. Dist. Ct. App. 1971), cert. denied, 247 So. 2d 440 (Fla. 1971)