Fall 2007 SBH Quarterly Newsletter
Washington Workers' Compensation: Board Decisions
Subjective complaints, alone, are not a valid basis for PPD rating.
The Board refused to award a permanent partial disability rating where the only deviation from a normal clinical examination was a general soreness and tenderness in the lower thoracic, upper lumber spine. It reasoned that subjective complaints of tenderness, sensory loss (that cannot be related to the industrial injury), and decreased range of motion primarily related to the lumber spine (an area that was symptomatic prior to the industrial injury and not impacted by it), did not provide a sufficient basis for a permanent partial disability award. In re Sonja J. Ruffin, Dckt. No. 06 13212 (March 19, 2007).
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