New SectionCommission Held That Claimant’s Epicondylitis Condition Was Caused By Repetitive Work Activities

Claimant was employed as a graphics shop manager for a two year period.

He was responsible for processing and developing screens and printing materials for museum exhibits. His job duties included making wooden frames and completing the silk screening process, which involved the preparation of the panels to which the silk screen would be applied. Claimant used power tools and hand tools to measure, cut, sand, prime and paint the panels. Such tools included a claw hammer, screwdriver, hand staple gun, scrub brush, pump spray bottle, high-pressure water spray gun, rollers and carpenter’s angle. In implementing the tools, claimant used his hands and arms to turn, twist, flip, push and pull.

He began to experience problems with his upper extremities and was diagnosed as suffering from bilateral lateral epicondylitis and left medial epicondylitis.

Claimant’s treating doctor testified that claimant’s epicondylitis condition was an overuse syndrome or a cumulative trauma disorder caused by his employment. The doctor noted that claimant had no other predisposing factors. Also, the doctor found no scientific evidence that aging produces epicondylitis or that the condition was caused by congenital or familial factors.

The arbitrator found that claimant sustained a repetitive trauma injury to both of his elbows which arose out of and in the course of his employment with defendant. In so holding, the arbitrator found claimant’s testimony credible and relied upon the findings and conclusions of claimant’s treating doctors. The arbitrator determined that claimant established a causal connection through a “chain of events” analysis, where claimant demonstrated a previous condition of good health, repetitive trauma to both arms while working and subsequent medical condition resulting in disability. Further, the arbitrator pointed out that the medical experts agreed claimant’s condition was not caused by a degenerative aging process.

The Commission affirmed the arbitrator’s decision.