Case name: Gryglak v. Scott Peterson 12 ILWCLB 38 (Ill.Ind.Comm.2004).
Ruling: The Commission affirmed the arbitrator’s decision awarding 56 weeks of temporary total disability, $2,823 in medical expenses and expenses for recommended surgery for a meat packer’s knee injury sustained while squatting at work.
What it means: An employee who engages in repetitive squatting as part of his job duties is subjected to an increased risk of a knee injury.
Summary: The claimant worked as a meat packer on an assembly line. His job required that he turn and grab boxes from a pallet, pick up packages as they come down the assembly line, place the packages into boxes, and push the boxes down the assembly line. He and his coworker together packed approximately 1,800 boxes an hour. The boxes were located on pallets. He had to bend/squat down to pick up the boxes located on the lower level of the pallet and then he stood to place the boxes at his work station. On the day of the accident at issue, the claimant was cleaning up his work area at the end of his shift. He bent over or squatted to pick up his gloves form the floor. Upon rising, he felt pain in left knee. He was diagnosed with a torn medial and lateral menisci tears of the left knee. The Commission awarded benefits, finding that the claimant performed repetitive squatting as part of his job duties which subjected him to an increased risk of injury and resulted in his left knee condition.
The Commission explained that the claimant was engaged in repetitive squatting to a greater degree than squatting performed by members of the general public on a daily basis. Unlike the courts’ holdings in Greater Peoria Mass Transit Dist. v. Industrial Commission, Hansel & Gretel Day Care v. Industrial Commission and Pryor v Industrial Commission, the Commission viewed the events in the instant case not as an isolated incident but rather as a series of repetitive traumas. These traumas manifested themselves at the time the claimant was cleaning up his work station and after performing highly repetitive bending/squatting while standing at his work station all day.