Significant Decisions

CAUSAL RELATIONSHIP
(See also AGGRAVATION, PERMANENT TOTAL DISABILITY and SUBSEQUENT CONDITION TRACEABLE TO ORIGINAL INJURY)

CAUSAL RELATIONSHIP

Audiologist

Hearing loss must be established by medical evidence. The testimony of an audiologist is therefore insufficient to make a prima facie case for causal relationship and extent of permanent partial disability. ....Virgil Degolier, 60,471 (1983)

Chiropractor

Following the amendment of RCW 18.25.006, chiropractors are allowed to treat upper and lower extremities and can testify about causation of upper and lower extremity conditions as matters within the scope of chiropractic practice.  ….Tami Lynn, 09 16657 (2010)

Because the low back is a part of the anatomy falling within the special field of chiropractic, a chiropractor may testify to the causal relationship between the worker's low back condition and the injury. ....Ernest Pfenniger, 41,425 (1973) [dissent]

Chiropractic testimony is sufficient to establish a prima facie case for a causal relationship between an industrial injury and the worker's low back condition, since the treatment of low back conditions is within the "special field" of chiropractic. ....H. U. Shipley, 08,043 (1957)

Physical therapist
A physical therapist is not qualified to render opinions of medical causation.  ....Juan Muñoz, 05 11698 (2007)  [Editor's Note:  The Board's decision was appealed to superior court under King County Cause No.07-2-38541-0KNT].

Physician's Assistant

Because the Department's medical aid rules permit a physician's assistant to render opinions on causation, a physician's assistant's opinion is a sufficient expert opinion to prove causation of a diagnosed condition.  ….Evelyn Woods, 07 23506 (2009)

Psychologist

Psychologist diagnoses of certain mental health conditions not listed in DSM-IV were within the psychologists' scope of practice and were valid diagnoses of the worker's conditions caused by the exposure at work.  ….Diana Gegg, 08 16647 (2010)

A licensed clinical psychologist is competent to testify on the issue of the cause of mental conditions. ....Robert Hedblum, 88 2237 (1989) [Editor's Note: The Board's decision was appealed to superior court under Thurston County Cause No. 89-2-02751-5.]