Columbia Forest Products v. Woolner

Employer seeks review of an order of the Workers’ Compensation Board overturning employer’s current condition denial. The primary question on review is whether an employer may issue a preclosure claim denial under ORS 656.262(7)(b) 1 for a “combined condition” if its earlier acceptance did not expressly identify the claim as one for a combined condition. We reverse and remand.

We state the facts as the Board found them, supplemented with undisputed evidence in the record. Claimant injured her neck and right shoulder at work on May 29,1996. She had a preexisting condition, bilateral…