Seekford v. WCAB (R.P.M. Erectors)

In Seekford v. Workers' Compensation Appeal Board (R.P.M. Erectors), 909 A.2d 421 (Pa. Cmwlth. 2006), a claimant sought specific loss benefits when he lost his arm as a result of a surgical procedure to treat a previous work-related back injury. The claimant attempted to characterize his specific loss as a separate and distinct injury and we rejected his appeal based on statute of limitation issues. In doing so, the Court stated, "it is well established that where medical treatment for a work injury aggravates the existing disability or causes a new or additional injury, the injury is deemed to have been caused by the original work injury." Id. at 425-426.