Black Lung Presumption for Underground Miners Can Apply to Surface Workers, Too

A federal appellate court ruled that the presumption under the Black Lung Benefits Act for coal miners who put in 15 or more years of underground work can also apply to an above-ground worker. Case: Fairfield Southern Co. v. OWCP, No. 24-10651, 12/08/2025, published. Facts: Billie Barr Jr. worked as a railroad engineer for U.S. Steel and Fairfield Southern Co., transporting rail cars to and from the Concord Mine in Alabama. The mine closed in the early 1980s, and the site was converted to a coal preparation plant. A system of conveyor belts transported coal to the plant from the Oak Gr...