MATTER OF BENWARE v. Benware Creamery
Appellate Division of the Supreme Court of the State of New York · 1964-12-11 · cited 7×
The case involved a claim by a creamery worker for workers' compensation benefits based on Raynaud’s disease, which caused his hands to become white, numb, swollen, and stiff after exposure to cold water, cold milk, and cold air while washing bottles, equipment, and handling milk cartons. The Workmen’s Compensation Board awarded benefits, finding the condition an occupational disease precipitated by the job's distinctive features, and the Appellate Division affirmed. The majority held there was substantial medical and lay evidence of a causal link between the disability and the claimant's repeated exposure to cold as a natural hazard of creamery work, meeting the standard from Matter of Detenbeck v. General Motors Corp. that requires proof of a recognizable link to a job feature common to all such positions, even where the underlying disease may stem from a predisposition. A concurrence emphasized that the test focuses on the disease's connection to the work environment rather than whether it is literally peculiar to the occupation.