second argument is based on the general common law. Union Pacific argues that, under the common law, it owes no duty to warn Nami of commonly-known or common-sense hazards, which Union Pacific claims includes mosquitoes. See Brookshire Grocery Co. v. Goss, 262 S.W.3d 793, 795 (Tex.2008). Specifically, Union Pacific argues that it is commonly known that mosquitoes carry diseases, and the evidence shows that Nami was aware that there were many mosquitoes at his Sweeny worksite. We are not persuaded by this argument. Texas courts have held that an employer owes no duty to warn an employee of hazards, that are commonly known or al ready appreciated by the employee unless there is evidence that the work is unusually precarious. . .See Kroger Co. v. Elwood, 197 S.W.3d 793, 794-95 (Tex.2006) (<HOLDING>); see also Jack in the Box, Inc. v. Skiles, 221
holding supplier of compactor had no duty to warn worker or his employer of the availability andor need for a rops for the compactor because this was an open and obvious danger holding danger was so open and obvious to plaintiff that as a matter of law he knew or should have known of danger holding that a restaurant supply employer had no duty to warn a delivery truck driver employee of the danger associated with water on a floor because that is a commonly known hazard and obvious to everyone holding that a grocery store employer had no duty to warn an employee that placing his hand in the doorjamb of a customers car is an obvious danger holding there is no duty to warn of risks obvious to the average user of the product