WCAB

Introduction

In this case we hold that the compensability threshold established by Labor Code section 3208.3, subdivision (b)(1) applies to any claim for psychiatric injury, whether or not it is related to a compensable physical injury. Employer Lockheed Martin Corporation (Lockheed) and its insurer, Bankers Standard Insurance Company (Bankers), petitioned for review of a decision of the Workers’ Compensation Appeals Board (Board or WCAB) reversing the finding of a workers’ compensation administrative law judge (WCJ) that employee applicant Virginia McCullough suffered no compensable psychiatric injury. We granted the petition and now reverse the Board’s order in case No. WCK 32177.

Background

In 1986, while employed by General Electric (G.E.), McCullough sustained an admitted industrial injury to her left forearm and was awarded 35.5 percent permanent disability. In 1988, she filed another claim against G.E. alleging cumulative pulmonary and internal trauma (exposure to toxic chemicals), later adding an allegation of associated psychiatric injury. During the period ending April 1996, while employed by Lockheed, she sustained admitted cumulative injury to her right…