Cumulative Trauma Claim Jon B. Tucker, M.D. Case Presentation Cumulative Trauma Claim Jon B. Tucker, M.D.

Current complaint: Tingling in the hands and low back Minimal bilateral knee discomfort

History Male, age 61 Railroad worker from 1985 until 2016, retired in 2016 on “disability” Various jobs; trackman, foreman, machine operator, truck driver Back sprain in 2008; three weeks work missed. ? MRI done Diagnosed with “carpal tunnel” in 2013, conservative treatment Knee pain started 2013; xrays taken, no treatment 2015 emergency low back surgery for large disc and partial cauda equina syndrome

At time of IME Medical imaging left wrist advanced degenerative dz Knees, minimal degenerative dz, age appropriate Lumbar spine, diffuse mild degenerative dz, evidence of lami

Positive Exam Findings Left wrist, limited crepitant range of motion Positive Tine and Phalen’s tests ( consistent with carpal tunnel syndrome) Slight painless crepitus with bilateral knee range of motion All other musculoskeletal exam findings were normal on physical examination

Plaintiff’s allege Cumulative work trauma caused or contributed to conditions/diseases including but not limited to L1-L2 Disk herniation Degenerative disease of the lumbar spine Bilateral carpal tunnel syndrome Bilateral knee arthritis

Plaintiff alleges Unsafe work environment Outdated tools and equipment Hazardous and excessive pace of work Hand-arm vibration syndrome Forceful, repetitive work in awkward positions Walking for long periods of time on uneven railroad ballast surfaces

Records provided to expert MD for review Complaint Safety History Training Record/classes Occupational medical record Medical provider records from 1978-present Medical imaging and reports Defendant’ ergonomist’s report Plaintiff expert reports Plaintiff MD expert report Plaintiff ergonomist report

Issues to consider Jurisdiction What is the threshold/bar? Apply appropriate medical evidence based decision analysis to expert opinion ideation Redacted opinion letter distributed