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What Do You Think: Did ‘Double Whammy’ of Heat, Physical Labor, Fuel Roadside Mechanic’s Heart Attack?
06 Feb, 2024 Chris Parker
Greencastle, PA (WorkersCompensation.com) -- When an employee has a heart attack at work, there is always the question of whether his job activities, rather than his personal habits and physical health, caused the attack.
As a Pennsylvania case shows, the answer to that question may come down to the nature of the work and the setting in which it’s performed.
The deceased mechanic in that case worked fixing trucks when they broke down on the road. The work involved fixing flats. Fixing a flat often started with the mechanic spending 30 to 45 minutes using a heavy jack to lift the truck and prying a hundred-pound tire off the rim on the side of the highway with the ever present possibility of being run over by a passing vehicle and the heat intensifying and wafting off the asphalt.
One very hot day, the trucker had just removed two tires from a truck when he experienced shortness of breath. He went back to his cab and collapsed from a heart attack.
It goes without saying that it was a doozy of a job. But so, arguably, was the driver’s physical fitness. The driver had a history of smoking a pack of cigarettes a day and a family history of heart disease. He was on the lower end of the obesity scale. He had never had heart problems but, at the time of the accident, had been taking blood pressure medication for two years. And, according to witnesses, he had a sedentary lifestyle.
The driver’s spouse filed a claim for death benefits. Her medical expert testified that the mechanic’s heart attack was caused by his work environment and the physically demanding nature of the work. He got a “double whammy,” the doctor testified. First, the heat caused his body to need to pump more blood to the skin. Second, the physical work caused the body to need to pump more blood to the muscles.
The employer’s medical expert, on the other hand, pointed to the mechanic’s 30-year-long smoking habit, his weight, and his sedentary lifestyle as the real causes of his heart attack.
The court explained that for a decedent's fatal heart attack to be compensable, the claimant must establish that the heart attack was causally related to the decedent's employment. If the causal connection is not obvious, the connection must be established by unequivocal medical testimony.
Was the mechanic’s death compensable?
A. Yes. The medical expert connected the heart attack to the mechanic’s job duties.
B. No. He was an obese smoker with a family history of cardiovascular disease; that was what caused his heart attack.
If you selected A, you agreed with the court in T.A. Operating, LLC v. Maurer, No. 320 C.D. 2022 (Pa. Commw. Ct. 01/17/24, unpublished), which held that the mechanic’s job, which required physically demanding work in extreme weather, caused his death.
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The court pointed to the claimant’s medical expert’s testimony that the combination of hot weather and strenuous work triggered the mechanic’s heart attack.
It also noted evidence concerning the physically challenging nature of the work, and the fact that the mechanic had been changing two heavy tires around the time that he collapsed.
Finally, the court pointed to the weather as a factor that likely contributed to the strain on the mechanic's heart.
The court, however, rejected the argument that the claimant had to prove exactly which activity precipitated the attack. The court upheld the worker’s compensation judge’s finding upholding the spouse’s fatal claim petition.
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