Highlights of Noteworthy Decisions

Decision 245 22
02/06/2022
A. Somerville - M. Falcone - K. Hoskin
  • Alcoholism
  • Post-traumatic stress disorder
  • Loss of earnings {LOE} (eligibility) (impairment)
  • Consequences of injury (secondary condition)

The issues under appeal were entitlement for an alcohol use disorder (AUD) and entitlement to LOE benefits from March 13, 2018 to August 15, 2018.

The appeal was allowed in part.
The worker testified that his alcohol consumption in mid-2017 had increased due to his work stressors. However, the Panel found that the medical documentation indicated otherwise, which referred to alcohol dependence which pre-dated the worker's start date with the accident employer in January 1997. The Panel concluded that the worker had AUD prior to beginning to work with the accident employer, and as such, his work duties were not a significant contributing factor in the development of the worker's AUD.
With respect to the worker's submissions, the Panel noted that whether AUD is adjudicated under the traumatic mental stress policy, or as a disablement accident, a worker's work duties must be a significant contributing factor in the development of the condition. The Panel determined that work was not a significant contributing factor in the development of the worker's AUD. Accordingly, given the findings regarding the worker's drinking history, the Panel did not accept that the worker's AUD was aggravated or caused by PTSD, and stated that it was not necessary to address this submission.
With respect to entitlement for LOE benefits, the Panel found that the evidence established, on the balance of probabilities, that the worker was suffering from his compensable PTSD from March 19, 2018 until August 15, 2018, as well as from non-compensable AUD. The Panel concluded that the worker was totally disabled from work during this time, and that his PTSD was a significant contributing factor to his inability to work. The worker was therefore entitled to full LOE benefits from March 19, 2018 to August 15, 2018.