Medical Conditions (By Specific Condition): Eczema Dermatitis

Bailey v. State Fund [1/5/96] 1996 MTWCC 3 Subsection defining certain forms of alleged accidents as WCA injuries only if the accident is the "primary cause" of the physical harm applies to claim for compensation relating to eczema dermatitis condition. The subsection refers to "cardiovascular, pulmonary, respiratory, or other disease." While the word "disease" is not defined in the WCA or ODA, the dictionary definition of the word is broad enough to encompass dermatitis caused by allergens or environmental conditions. 36-year old construction worker failed to persuade WCC that particular roofing job was primary cause of skin condition, diagnosed as eczema dermatitis.