Diagnoses 'predominantly attributable to the accumulation of work-related exposure to trauma'
An Alberta employer's bid to peel back workers' compensation coverage for a firefighter-paramedic's PTSD and major depressive disorder has failed on three counts after the Appeals Commission denied each one.
In a May 14, 2026 decision, an Appeals Commission for Alberta Workers' Compensation panel chaired by Lynn Faulder confirmed the 58-year-old worker's entitlement to an additional diagnosis of major depressive disorder, refused to consolidate his two claims, and denied the employer cost relief on a psychological injury claim.
The worker held two open Workers' Compensation Board (WCB) claims. Under Claim A, the WCB accepted PTSD and, later, a depressive disorder. Under Claim B, the WCB accepted a back strain the worker sustained in May 2021 after he tried to steady himself when an ambulance hit a bump. He was prescribed anti-inflammatories and physiotherapy, and was cleared for regular duty by late June 2021.
The employer argued the back injury had reactivated a pre-existing PTSD the worker had carried since 2012, and that his psychological injuries flowed from the compensable back injury rather than his frontline duties. On that theory, the employer asked the Appeals Commission to roll Claim A into Claim B.
The employer also pointed to the worker's personal life, submitting that he had concurrent depression and anxiety tied to a divorce while recovering from PTSD, and would have recovered sooner without those personal stressors. Any psychological injury costs, the employer argued, belonged with the back injury claim.
Psychological assessment
A comprehensive psychological assessment dated July 17, 2021 diagnosed the worker with major depressive disorder (mild, single episode), PTSD, and other problems related to employment. The assessing psychologist tied the diagnoses to two specific service calls the worker had responded to in quick succession, alongside ongoing workplace issues.
The panel acknowledged an earlier psychologist's letter referencing "partner relational difficulties with possible underlying post-traumatic distress and depression," but placed greater weight on the fuller assessment. Chronic PTSD symptoms, the panel noted, had "waxed and waned over the years" before being aggravated by the two service calls.
On the divorce theory, the panel was direct: "We did not accept the representative's arguments that the worker's depression and anxiety were related to his experience of going through a divorce while recovering from the PTSD," it wrote.
The medical evidence, it found, supported direct personal experience providing first response to victims of severe trauma.
First responder’s presumption
On the additional diagnosis, the panel found that the worker was entitled to coverage for major depressive disorder. The first responder's presumption under section 24.2(3) of the WCA, which treats a diagnosed psychological injury as work-related unless the contrary is proven, was not rebutted.
On consolidation, the panel found that the back strain and psychological injuries had different mechanisms of injury and could not be combined. The back claim, it said, "resolved within standard timelines for strain injuries" and was unaffected by anything in Claim A.
On cost relief, the panel rejected the employer's concurrent condition theory. While acknowledging long-standing symptoms, it relied on the specialist's determination that the diagnoses were "predominantly attributable to the accumulation of work-related exposure to trauma in the course of his work."
The Dispute Resolution and Decision Review Body's Sept. 9, 2025 decision was confirmed on all three issues.
