Claim of Barcomb v. Delphi Automotive
Claimant, an assembler, developed angioedema and asthma attributed by medical professionals to an airborne work-related allergen, although the specific allergen remained unidentified. A Workers’ Compensation Law Judge initially awarded benefits, but the Workers’ Compensation Board reversed, ruling that the lack of specific allergen identification precluded a finding of causal relationship to employment. On appeal, the court found that the Board misinterpreted legal precedent, particularly Matter of Adams v Univera Health Care/Excellus, by placing undue emphasis on the claimant's inability to identify the specific allergen. The court clarified that establishing a causal connection to the workplace is paramount. Consequently, the court reversed the Board's decision and remitted the matter for further consideration, emphasizing a proper application of causation standards.