Temporal connection fails to connect chemical exposure, symptoms
Case name: Knowlton v. Wood River Medical Center, No. 37360 (Idaho 05/26/11).
The Idaho Supreme Court held that a secretary did not meet her burden of showing her symptoms were causally related to a chemical exposure at work.
What it means: In Idaho, a temporal connection between a worker's symptoms and a chemical exposure at work alone does not establish causation.
Summary: A secretary at a medical center was working at her assigned station when a patient's toilet or bathroom floor drain became clogged. A maintenance worker used a chemical to remedy the problem, which produced a foul odor. A fan placed in the doorway of the patient's room blew air past the secretary's work station. She developed a headache, cough, and body aches. The secretary learned that the chemical contained sulfuric acid. She was diagnosed with reactive airway disease and gastroesophageal reflux disease. The secretary sought benefits. The Idaho Supreme Court held that the secretary was not entitled to benefits.
The secretary claimed that she contracted reactive airway disease as a result of the chemical exposure. The court said that the secretary did not meet her burden of proving that her symptoms were causally related to the chemical exposure. A doctor specializing in treating patients exposed to toxic chemicals concluded that her symptoms were not likely caused by chemical exposure but by gastroesophageal reflux disease. The doctor said the secretary's symptoms on her first day of the exposure were not consistent with someone who had been exposed to sulfuric acid. Also, she was the only person at the center who claimed to have suffered effects from the chemical exposure.
Despite the secretary's claim that she developed gastroesophageal reflux disease after the chemical exposure and as a result of reactive airway disease, the doctor said no medical evidence indicated that the gastroesophageal condition was caused by the reactive airway disease. The court said that a temporal connection alone did not establish causation. The secretary also had normal pulmonary functioning tests. Two doctors also testified that the secretary's symptoms were likely caused by her emotional distress rather than the chemical exposure.
Read more at the WorkersComp Forum homepage.
July 18, 2011
Copyright 2011© LRP Publications