In the Matter of the Claim of Ryszard Cala
Ryszard Cala, an asbestos handler, filed a workers' compensation claim for binaural hearing loss, alleging it was caused by prolonged occupational exposure. A Workers' Compensation Law Judge (WCLJ) established the claim with a 25.32% schedule loss of use, a decision affirmed by the Workers' Compensation Board. The Board credited the findings of the carrier's consultant, Daniel Arick, over claimant's physician, Michael Alleva. Cala appealed, arguing that Arick's independent medical examination (IME) report should have been precluded due to the absence of an accompanying audiogram, which is a requirement per Board precedent. The Appellate Division reversed the Board's decision, finding that the Board failed to provide a rational basis for departing from its own precedent regarding the submission of audiograms with IME reports, and remitted the matter for further proceedings.