Court Denies Truck Driver’s PTSD Claim from Minor Fire, Citing Normal Working Conditions

In a notable decision, the Commonwealth Court has ruled against a truck driver’s claim for workers’ compensation due to Post Traumatic Stress Disorder (PTSD) following a minor truck fire. The incident occurred in February 2015 when the claimant, while driving on the turnpike, noticed his truck’s "check engine" light and subsequently a red "engine shutdown" light. Upon pulling over, he observed flames outside the truck and smoke entering the cab, prompting him to exit the vehicle and seek help. The fire was extinguished within two minutes by another truck driver without causing any physical injuries.

The claimant initially won PTSD-related benefits from a workers’ compensation judge, a decision later affirmed by the Workers’ Compensation Appeal Board. However, upon further appeal, the Commonwealth Court sided with the employer, Premium Transportation Staffing, Inc., agreeing that the truck fire did not present an abnormal working condition. The court’s rationale highlighted that, within the truck driving profession, fires are potential occurrences that drivers might expect as part of their job. Therefore, the fire experienced by the claimant was not deemed "extraordinarily unusual," a key criterion for considering it an abnormal working condition warranting PTSD compensation. This judgment underscores the court’s stance on the nature of truck driving work and the expectations of encountering such hazards, emphasizing the need for an event to be significantly out of the ordinary to qualify as an abnormal working condition.