When Does Statute of Limitations Begin to Run In Occupational Disease Cases In Pennsylvania ?
In Price v. Workmen's Compensation Appeal Board, 533 Pa. 500, 626 A.2d 114 (1993), our Supreme Court held that the statute of limitations for an occupational disease begins to run from the date a claimant learns that his disability is caused by an occupational disease.
It explained this point as follows:
This knowledge will most often occur following a medical diagnosis of the total disability due to occupational disease made known to the claimant.
While we recognize that a claimant can gain knowledge of total disability due to occupational disease by means other than a medical diagnosis, nevertheless, we view the rule stated above as establishing a strong presumption that discovery of an occupational disease resulting in total disability first occurs when a competent medical diagnosis is made known to the claimant. Id. at 501, 626 A.2d at 115.