United States Department of Labor 

Employees’ Compensation Appeals Board 

__________________________________________ 

B.Z., Appellant 

and 

U.S. POSTAL SERVICE, POST OFFICE, 

Madison, WI, Employer 

__________________________________________ 

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Docket No. 16-1031 

Issued: November 9, 2016 

Appearances: Case Submitted on the Record

Appellant, pro se 

Office of Solicitor, for the Director 

DECISION AND ORDER 

Before: 

CHRISTOPHER J. GODFREY, Chief Judge 

PATRICIA H. FITZGERALD, Deputy Chief Judge 

VALERIE D. EVANS-HARRELL, Alternate Judge 

JURISDICTION 

On April 19, 2016 appellant filed a timely appeal from a November 19, 2015 merit 

decision of the Office of Workers’ Compensation Programs (OWCP). Pursuant to the Federal 

Employees’ Compensation Act1

 (FECA) and 20 C.F.R. §§ 501.2(c) and 501.3, the Board has 

jurisdiction over the merits of this case. 

ISSUE 

The issue is whether appellant met her burden of proof to establish that her bilateral 

carpal tunnel syndrome was causally related to factors of her federal employment. 

FACTUAL HISTORY 

On August 7, 2015 appellant, then a 51-year-old mail handler, filed an occupational 

disease claim (Form CA-2) alleging that she sustained bilateral carpal tunnel syndrome as a 

result of repetitively delivering mail, opening bags, working on the deck, and working as a mail 

 1

 5 U.S.C. § 8101 et seq.
2

handler for the past nine years. She first became aware of her condition on October 14, 2008 and 

realized it resulted from her employment in June 2015. Appellant stopped work on 

August 5, 2015. In a handwritten statement, she explained that the pain started after repeatedly 

opening bags, working on the deck, and moving equipment. Appellant indicated that she tried 

acupuncture and occupational medicine, but it did not help. 

In a July 30, 2015 report, Dr. Abhishek Julka, an orthopedic hand surgeon, noted that he 

treated appellant for bilateral carpal tunnel syndrome, moderate on right and mild on the left. He 

reported that he could not say that appellant’s carpal tunnel was caused by work, but it could 

have been aggravated by repetitive activities. 

Dr. Julka provided an August 18, 2015 work status note which indicated that appellant 

was his patient and would need to be excused from work because she was recovering from carpal 

tunnel syndrome. He noted that appellant would be reevaluated in four weeks. 

By letter dated August 27, 2015, OWCP advised appellant that the evidence of record 

was insufficient to establish her claim. It requested that appellant provide a detailed description 

of the employment activities which she believed contributed to her condition and submit medical 

evidence to establish that she sustained a diagnosed condition as a result of the described 

employment activities. Appellant was afforded 30 days to submit the additional evidence. 

In a September 22, 2015 report, Dr. Julka indicated that appellant was examined and 

could return to work with restrictions of no lifting, pushing, or pulling more than 40 pounds and 

a maximum of eight hours per day. 

OWCP denied appellant’s claim by decision dated November 19, 2015. It accepted that 

appellant was employed as a mail handler and was diagnosed with bilateral carpal tunnel 

syndrome, but denied her occupational disease claim as the medical evidence submitted was 

insufficient to establish that her medical condition was causally related to factors or her federal 

employment. 

LEGAL PRECEDENT 

An employee seeking benefits under FECA has the burden of proof to establish the 

essential elements of his or her claim by the weight of the reliable, probative, and substantial 

evidence2

 including that he or she sustained an injury in the performance of duty and that any 

specific condition or disability for work for which he or she claims compensation is causally 

related to that employment injury.3

 

In an occupational disease claim, appellant’s burden requires submission of the 

following: (1) a factual statement identifying employment factors alleged to have caused or 

contributed to the presence or occurrence of the disease or condition; (2) medical evidence 

 2 J.P., 59 ECAB 178 (2007); Joseph M. Whelan, 20 ECAB 55, 58 (1968). 

3 M.M., Docket No. 08-1510 (issued November 25, 2010); G.T., 59 ECAB 447 (2008); Elaine Pendleton, 40 

ECAB 1143, 1145 (1989). 
3

establishing the presence or existence of the disease or condition for which compensation is 

claimed; and (3) medical evidence establishing that the diagnosed condition is causally related to 

the employment factors identified by the employee.4

Causal relationship is a medical issue and the medical evidence generally required to 

establish causal relationship is rationalized medical opinion evidence.5 The opinion of the 

physician must be based on a complete factual and medical background of the employee, must be 

one of reasonable medical certainty, and must be supported by medical rationale explaining the 

nature of the relationship between the diagnosed condition and the specific employment factors 

identified by the employee.6

 

ANALYSIS 

Appellant alleged that she developed bilateral carpal tunnel syndrome as a result of her 

repetitive duties as a mail handler. OWCP denied appellant’s claim because the medical 

evidence submitted failed to establish that her bilateral carpal tunnel syndrome resulted from her 

employment. The Board finds that appellant has failed to meet her burden of proof to establish 

that her diagnosed condition was causally related to factors of her employment. 

Dr. Julka examined appellant and provided reports dated July 30 to September 22, 2015 

which indicated that he treated appellant for bilateral carpal tunnel syndrome. He reported that 

he could not opine that appellant’s condition was caused by work, but explained that carpal 

tunnel syndrome could have been aggravated by repetitive activities. Dr. Julka provided an 

August 18, 2015 work status note which requested that appellant be excused from work because 

she was recovering from carpal tunnel syndrome. In a September 22, 2015 work status note, he 

authorized appellant to return to work with restrictions. 

Dr. Julka did not provide any opinion on the cause of appellant’s condition except his 

notation that it could have been aggravated by repetitive activities. The Board has held that 

medical opinions that are speculative or equivocal in character are of diminished probative 

value.7

 Moreover, Dr. Julka neither described any of appellant’s employment duties, nor 

explained how appellant’s employment caused or contributed to her bilateral carpal tunnel 

syndrome. The Board has found that rationalized medical opinion evidence must relate to 

specific employment factors identified by the claimant to the claimant’s condition, with stated 

reasons by a physician.8

 Because Dr. Julka’s reports failed to explain how appellant’s bilateral 

carpal tunnel syndrome was causally related to factors of her employment, his reports are 

insufficient to establish appellant’s claim. 

 4 R.H., 59 ECAB 382 (2008); Ernest St. Pierre, 51 ECAB 623 (2000). 

5 I.R., Docket No. 09-1229 (issued February 24, 2010); D.I., 59 ECAB 158 (2007). 

6

 I.J., 59 ECAB 408 (2008); Victor J. Woodhams, 41 ECAB 465 (2005). 

7 D.D., 57 ECAB 734, 738 (2006); Kathy A. Kelley, 55 ECAB 206 (2004). 

8 L.F., Docket No. 10-2287 (issued July 6, 2011); Solomon Polen, 51 ECAB 341 (2000). 
4

The mere fact that work activities may produce symptoms revelatory of an underlying 

condition does not raise an inference of an employment relation. Such a relationship must be 

shown by rationalized medical evidence of a causal relation based upon a specific and accurate 

history of employment conditions which are alleged to have caused or exacerbated a disabling 

condition.9

 Because appellant has failed to provide such rationalized medical evidence, she has 

not met her burden of proof to establish her occupational disease claim. 

Appellant may submit new evidence or argument with a written request for 

reconsideration to OWCP within one year of this merit decision, pursuant to 5 U.S.C. § 8128(a) 

and 20 C.F.R. §§ 10.605 through 10.607. 

CONCLUSION 

The Board finds that appellant has failed to meet her burden of proof to establish that her 

bilateral carpal tunnel syndrome was causally related to factors of her federal employment. 

ORDER 

IT IS HEREBY ORDERED THAT the November 19, 2015 decision of the Office of 

Workers’ Compensation Programs is affirmed. 

Issued: November 9, 2016 

Washington, DC 

 

 Christopher J. Godfrey, Chief Judge 

 Employees’ Compensation Appeals Board 

 

 Patricia H. Fitzgerald, Deputy Chief Judge 

 Employees’ Compensation Appeals Board 

 

 Valerie D. Evans-Harrell, Alternate Judge 

 Employees’ Compensation Appeals Board 

 9 Patricia J. Bolleter, 40 ECAB 373 (1988).