BRB No. 89-3849 BLA 
                         

WALTER KELLICHNER             )                        
                              )
          Claimant-Respondent )
                              )
     v.                       )
                              )
BARNES AND TUCKER COMPANY     )
                              )
          Employer-Petitioner )
                              )
DIRECTOR, OFFICE OF WORKERS'  )
COMPENSATION PROGRAMS, UNITED )
STATES DEPARTMENT OF LABOR    )
                              )
          Party-in-Interest   )    DECISION and ORDER

     Appeal of the Decision and Order and Decision and Order Denying Motion for
     Reconsideration of Gerald M. Tierney, Administrative Law Judge, United States
     Department of Labor.

     Theresa C. Homady (Pawlowski, Creany & Tulowitzki), Ebensburg, Pennsylvania,
     for claimant.

     John J. Bagnato (Spence, Custer, Saylor, Wolfe & Rose),     Johnstown,
Pennsylvania, for employer.

     Before:  SMITH and DOLDER, Administrative Appeals Judges, and CLARKE,
     Administrative Law Judge.*

     PER CURIAM:
     Claimant appeals the Decision and Order and Decision and Order Denying Motion
for Reconsideration (88-BLA-958) of Administrative Law Judge Gerald M. Tierney
awarding benefits on a claim filed pursuant to the provisions of Title IV of the
Federal Coal Mine *Sitting as a temporary Board member by designation pursuant to
the Longshore and Harbor Workers' Compensation Act as amended in 1984, 33 U.S.C.
§921(b)(5) (Supp. V 1987).
Health and Safety Act of 1969, as amended, 30 U.S.C. §901 et
seq. (the Act).  The administrative law judge reviewed this claim
pursuant to the provisions of 20 C.F.R. Part 718, and credited claimant with
twenty-seven years of qualifying coal mine employment.  The administrative law
judge found that claimant established the existence of pneumoconiosis arising out
of coal mine employment pursuant to 20 C.F.R. §§718.202(a)(4), 718.203(b)
and 718.302, and total disability pursuant to 20 C.F.R. §718.204(c)(4). 
Accordingly, benefits were awarded.  Employer appeals, challenging the
administrative law judge's findings under Section 718.204(c), and with regard to
the onset date of total disability pursuant to 20 C.F.R. §725.503.  Claimant
responds, urging affirmance.  The Director, Office of Workers' Compensation
Programs, has not participated in this appeal.[1] 
     The Board's scope of review is defined by statute.  If the administrative law
judge's findings of fact and conclusions of law are supported by substantial
evidence, are rational, and are consistent with applicable law, they are binding
upon this Board and may not be disturbed.  33 U.S.C. §921(b)(3), as
incorporated by 30 U.S.C. §932(a); O'Keeffe v. Smith, Hinchman & Grylls
Associates, Inc., 380 U.S. 359 (1965).
     In order to establish entitlement to benefits under 20 C.F.R. Part 718,
claimant must establish, by a preponderance of the evidence, that he is totally
disabled due to pneumoconiosis arising out of coal mine employment. 
See 20 C.F.R. §§718.3, 718.202, 718.203, 718.204.  Failure
to establish any of these elements precludes entitlement.  Anderson v. Valley
Camp of Utah, Inc., 12 BLR 1-111 (1989); Trent v. Director,
OWCP, 11 BLR 1-26 (1987).
     Employer maintains that the administrative law judge erroneously evaluated the
evidence on the issue of total disability pursuant to Section 718.204(c).  The
administrative law judge determined that all of the pulmonary function studies and
blood gas studies of record were non-qualifying[2]
, and that there was no evidence of cor pulmonale with right-sided congestive heart
failure.  Thus claimant has failed to establish total disability pursuant to
Section 718.204(c)(1) - (c)(3).  The administrative law judge found total
disability established pursuant to Section 718.204(c)(4), however, based on the
opinion of Dr. Mastrine, who concluded that claimant's respiratory symptoms were
of such severity that they rendered him totally disabled from performing his usual
coal mine employment, and the supporting opinion of Dr. Malhotra, who also found
that claimant was totally disabled. Decision and Order at 6, 7; Claimant's Exhibits
1, 2.  The administrative law judge further found that the severe respiratory
complaints noted in Dr. Mastrine's report were consistent with claimant's credible
testimony, twenty-seven year coal mine employment history, and the fact that Dr.
Sabo, claimant's treating physician, has prescribed breathing medications since
approximately 1985.[3]   Decision and Order at 7;
Director's Exhibit 18.  Employer contends that the administrative law judge erred
in assessing the physicians' conclusions without first determining whether the
underlying documentation was reliable and supported those conclusions; and that the
administrative law judge failed to consider all contrary probative evidence
contained in the record.  Specifically, employer contends that the administrative
law judge ignored the pulmonary function study and blood gas study results which
were interpreted as normal; failed to address the invalidations of Dr. Malhotra's
pulmonary function study by Drs. Pickerill and Fino, both Board-certified pulmonary
specialists, see  Employer's Exhibits 18, 19; and failed to address
either Dr. Fino's review of Dr. Mastrine's pulmonary function study tracings, in
which Dr. Fino opined that the spirometric values reflected an underestimation of
claimant's true pulmonary function, see  Employer's Exhibit 8, or the
deposition testimony of Dr. Begley, a Board-certified pulmonary specialist, finding
that Dr. Mastrine misinterpreted his pulmonary function study results,
see  Employer's Exhibit 22 at 16, 17.  As an administrative law judge
may not reject relevant evidence without explanation, and must address the opinions
of physicians who have reviewed pulmonary function study tracings,
see generally Revnack v. Director, OWCP,
7 BLR 1-771 (1985), we hereby vacate the administrative law judge's findings under
Section 718.204(c) and we remand this case for the administrative law judge to
reconsider all of the relevant probative evidence of record thereunder, like and
unlike, pursuant to Fields v. Island Creek Coal Co., 10 BLR 1-19
(1987), and Shedlock v. Bethlehem Mines Corp., 9 BLR 1-195 (1986). 
Employer further maintains that the administrative law judge failed to provide a
proper reason for according less weight to the opinions of Drs. Katter, Gress,
Lantos and Fino, who found that claimant suffered no pulmonary impairment. 
See Employer's Exhibits 7, 10, 11, 16, 17, 21, 23.  The
administrative law judge gave less weight to the opinions of said physicians, as
they offered no objective explanation for claimant's respiratory complaints. 
Decision and Order at 7.  Subjective symptoms, however, are not the equivalent of
a respiratory impairment, see generally Clay v.
Director, OWCP, 7 BLR 1-82 (1984), and a physician's failure to explain the
source of subjective complaints does not constitute a basis for rejecting the
opinion, see Coleman v. Kentland Elkhorn Coal Co., 5
BLR 1-260 (1982).  On remand, therefore, the administrative law judge must reassess
the opinions of Drs. Katter, Gress, Lantos and Fino under Section 718.204(c)(4).
     Finally, employer contends that the administrative law judge erred in finding
that claimant was entitled to benefits from March 1, 1987, the month in which
claimant filed his claim for benefits, without providing any analysis concerning
the onset date of total disability.  See 20 C.F.R. §725.503;
Williams v. Director, OWCP, 13 BLR 1-28 (1989); Lykins v.
Director, OWCP, 12 BLR 1-181 (1989).  We agree.  Consequently, if on remand
the administrative law judge finds total disability established pursuant to Section
718.204, he must then determine the onset date of total disability pursuant to
Williams, supra; Lykins,
supra.
     Accordingly, the administrative law judge's Decision and Order awarding
benefits and Decision and Order Denying Motion for Reconsideration are affirmed in
part, vacated in part, and this case is remanded for further consideration
consistent with this opinion.
     SO ORDERED.

                                                 
                    ROY P. SMITH
                    Administrative Appeals Judge



                                                 
                    NANCY S. DOLDER
                    Administrative Appeals Judge



                                                 
                    DAVID A. CLARKE, JR.
                    Administrative Law Judge

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Footnotes.
 1) The administrative law judge's findings under Sections
718.202, 718.203(b), 718.302, and with regard to length of coal mine employment,
are affirmed as unchallenged on appeal.  See Skrack v. Island
Creek Coal Co., 6 BLR 1-710 (1983).
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 2) A "qualifying" pulmonary function study or blood gas study
yields values that are equal to or less than the appropriate values set out in the
tables at 20 C.F.R. Part 718, Appendices B and C, respectively.  A "non-qualifying"
study yields values that exceed those values.
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 3) Employer notes that the administrative law judge failed to
additionally discuss the fact that Dr. Sabo's objective studies were non-qualifying
and his pulmonary function study was interpreted as showing no obstructive or
restrictive disease.  See Director's Exhibits 15, 23.
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