Kershaw v Spotless Services Australia Pty Ltd
[2024] NSWPICMP 471
•5 June 2024
| DETERMINATION OF APPEAL PANEL | |
| CITATION: | Kershaw v Spotless Services Australia Pty Ltd [2024] NSWPICMP 471 |
| APPELLANT: | Karina Kershaw |
| RESPONDENT: | Spotless Services Australia Pty Ltd |
| APPEAL PANEL | |
| MEMBER: | Deborah Moore |
| MEDICAL ASSESSOR: | Todd Gothelf |
| MEDICAL ASSESSOR: | Tommasino Mastroianni |
| DATE OF DECISION: | 5 June 2024 |
| CATCHWORDS: | WORKERS COMPENSATION - Workplace Injury Management and Workers Compensation Act 1998; appellant submitted that the Medical Assessor erred in his application of section 323 and in his assessment of scarring; Held – error in application of section 323; no error as regards to scarring; Medical Assessment Certificate revoked. |
BACKGROUND TO THE APPLICATION TO APPEAL
On 16 February 2024 Karina Kershaw (the appellant) lodged an Application to Appeal Against the Decision of a Medical Assessor. The medical dispute was assessed by Dr Tim Anderson, a Medical Assessor,(MA) who issued a Medical Assessment Certificate (MAC) on 22 January 2024
The appellant relies on the following grounds of appeal under s 327(3) of the Workplace Injury Management and Workers Compensation Act 1998 (the 1998 Act):
· the assessment was made on the basis of incorrect criteria, and
· the MAC contains a demonstrable error.
The delegate is satisfied that, on the face of the application, at least one ground of appeal has been made out. The Appeal Panel has conducted a review of the original medical assessment but limited to the ground(s) of appeal on which the appeal is made.
Rule 128 of the Personal Injury Commission Rules 2021 (the PIC Rules) and Procedural Direction PIC7 - Appeals, reviews, reconsiderations and correction of obvious errors in medical disputes set out the practice and procedure in relation to the medical appeal process under s 328 of the 1998 Act. An Appeal Panel determines its own procedures in accordance with r 128(1) of the PIC Rules.
The assessment of permanent impairment is conducted in accordance with the SIRA NSW Workers Compensation Guidelines for the Evaluation of Permanent Impairment, 4th ed
1 March 2021 (the Guidelines) and the American Medical Association Guides to the Evaluation of Permanent Impairment, 5th ed (AMA 5).
PRELIMINARY REVIEW
The Appeal Panel conducted a preliminary review of the original medical assessment in the absence of the parties and in accordance with the Procedural Direction PIC7.
As a result of that preliminary review, the Appeal Panel determined that it was not necessary for the worker to undergo a further medical examination because none was requested, and we consider that we have sufficient evidence before us to enable us to determine this appeal.
EVIDENCE
Documentary evidence
The Appeal Panel has before it all the documents that were sent to the MA for the original medical assessment and has taken them into account in making this determination.
SUBMISSIONS
Both parties made written submissions. They are not repeated in full, but have been considered by the Appeal Panel.
In summary, the appellant submits that the MA erred in his application of s 323 of the 1998 Act and in his assessment of scarring.
In reply, the respondent submits that no errors were made.
FINDINGS AND REASONS
The procedures on appeal are contained in s 328 of the 1998 Act. The appeal is to be by way of review of the original medical assessment but the review is limited to the grounds of appeal on which the appeal is made.
In Campbelltown City Council v Vegan [2006] NSWCA 284 the Court of Appeal held that the Appeal Panel is obliged to give reasons. Where there are disputes of fact it may be necessary to refer to evidence or other material on which findings are based, but the extent to which this is necessary will vary from case to case. Where more than one conclusion is open, it will be necessary to explain why one conclusion is preferred. On the other hand, the reasons need not be extensive or provide a detailed explanation of the criteria applied by the medical professionals in reaching a professional judgement.
The appellant was referred to the MA for assessment of whole person impairment (WPI) in respect of an injury on 14 December 2020 namely the left upper extremity (shoulder) and scaring.
The MA obtained the following history:
“Ms Kershaw related that she had been working as a cleaner in the accommodation blocks in the Police Academy in Goulburn. She was aware of aches and pains in her left shoulder from around 2018. Nevertheless, she was able to continue with her job. Unfortunately, on 14/12/20, she experienced a slip and fall, coming down predominantly on her left hand and also her knees. The transmission of forces caused severe deterioration of her left shoulder with a lot of aches and pains. Nevertheless, she basically toughed it out and continued working. The condition deteriorated badly, particularly over the following year.
She was referred to Specialist Orthopaedic Surgeon, Dr Hamish Rae. The extent of the degenerative changes in her left shoulder was identified and she was advised that arthroscopy would probably not be beneficial and that the only realistic surgical management would have to be a shoulder joint replacement. This was eventually agreed and went ahead on 22/02/22. After that, she had a lot of physiotherapy. She achieved a surprisingly good result.”
Present symptoms were noted as follows: “Ache in the left shoulder, mostly focused towards the posterior. Reduced range of power and reduced movement.”
In describing the appellant’s work history, the MA said:
“Ms Kershaw has a background of working in an abattoir, then a chicken hatchery and then working for Spotless Cleaning Services in the Goulburn Police Academy. She ceased this work in November 2021.
In May 2023 she was able to get back to work full time, 38 hours a week as a hospital cleaner. This is very much lighter work than the Police Academy and she is able to manage satisfactorily.”
The MA then set out details of the impact of her injury on her social activities and activities of daily living (ADL’s) and said:
“Mrs Kershaw is divorced and was a single mother. She is a non-smoker and a non-drinker. She is not involved in any physical recreational or remedial activity. She used to play the piano and still has one but rarely uses it. She is interested in lightweight gardening and particularly in bonsai. She has a manual vehicle, which she can drive for short local trips but has difficulty changing gears. She has a gardener, who cuts the grass. She tries to do her own housework but finds this difficult. Her daughter frequently gives assistance.”
Findings on physical examination were reported as follows:
“She was not in obvious discomfort.
Cervical Spine. There was no complaint of pain in the neck, nor was there any tenderness. Movement of the head and neck was throughout the normal range.
Upper Limbs. There was a completely normal range of movement of the elbows, wrists, hands and all digits. There were no neurological features.
The surgical scar over the left shoulder had healed well.”
He then noted the radiological material he had.
The Medical Assessor summarised the injuries and diagnoses as follows:
“Ms Kershaw sustained an injury to her left shoulder in mid-December 2020 when she fell, landing mostly on her left forearm. It was identified that she had extensive degenerative changes in the left shoulder joint complex. Initially, her clinical management was conservative. It was considered that arthroscopy would not be beneficial to her and ultimately it was decided that she should have a shoulder joint replacement. This was agreed and went ahead on 22/02/22. This gave her a surprisingly good result. At this assessment she had a good range of movement and relatively little else to find.”
The MA assessed 17% WPI in respect of the left upper extremity and 0% for scarring.
He explained his calculations as follows:
“Left Upper Extremity. From AMA 5 Page 506, Table 16-27 there is provision for a further 24% UEI for the implant arthroplasty. This is combined with the 5% from the reduced range of movement, giving 28% UEI.
From Page 439, Table 16-03 this converts to 17% WPI.
Scarring. This is addressed in the SIRA Guidelines, Page 74, Table 14.1. The surgical scar is a standard approach for an elective, defined procedure. There was slight alteration of pigmentation but no adherence or alteration of contour. No further treatment is indicated and no alteration of activities of daily living arises from this. The scar is therefore uncomplicated and carries a Whole Person Impairment of 0%.”
He then turned to consider the other medical opinions and evidence and said:
“In general, the baseline impairments calculated by Specialist Orthopaedic Surgeons, Dr Brett Courtenay, Dr Stephen Rimmer and myself are relatively similar. The difference arises from the deduction proportion. Dr Courtenay advises a deduction of one-quarter, yet Dr Stephen Rimmer advises that all of this condition is due to pre-existing features and all of it should be deducted.
It is fairly obvious that there was extensive pre-existing degenerative changes and that without this condition, it is unlikely that there would have been the need for a shoulder joint replacement. Nevertheless, a deduction of 100% is too excessive. Similarly, I believe a deduction of only one-quarter is insufficient, bearing in mind the nature of the injury and the results from the radiological investigations. I would also advise that scarring of 2% WPI is also considered to be excessive for a standard surgical approach for a defined elective procedure where there are no complications.”
The MA added:
“As advised, there were significant pre-existing features to the left shoulder complex. It is therefore appropriate that there would be an appropriate deduction to account for this. With the existing circumstances, a frequently utilised deduction of one-tenth would be at complete odds with the existing information. Ultimately a deduction of half is considered appropriate.”
The submissions
The appellant’s submissions may be summarised as follows:
(a) the MA recorded radiological investigations. The MA does not otherwise record any complaints or history relative to problems with the left shoulder prior to commencing employment with the employer in question and no history or evidence of any impairment or restriction associated with left shoulder movement prior to the injury.
(b) The applicant in the years prior to injury and indeed while employed by the respondent had been investigated and treated extensively for neck, back, right hip and knee complaints including a knee replacement, but little if any attention been drawn to the shoulder.
(c) Following the injury the applicant was referred to Dr Rae, who recorded the following history 29 April 20213:
“. . . She was in a motor vehicle accident 28 years ago and had some shoulder pain for twelve months afterwards but no ongoing problems (relevant shoulder not identified).Karina had started to get some shoulder pains over the last twelve to eighteen months which were relevantly [sic] minor. She was investigated with an ultrasound that was reported to demonstrate bursitis and she underwent corticosteroid injection without relief of her pain. Unfortunately, in December 2020 (approximately four months ago)…she lost her footing before landing onto the hard floor. She developed extensive bruising particularly her left hand and elbow but as well as over her knee…
(d) The treating history is of some minor discomfort but no impairment or restriction of the shoulder.
(e) Dr Courtenay recorded the following relative to the past medical history:
“She has had no other particular major problems with her shoulder. She has had no injuries. She was aware of some aches and pains in her left shoulder, but it was her non-dominant arm and she could manage. She stated she could do the cleaning and by the description she provided she did not lose any time as a result of her left shoulder in the past.”
(f) Dr Courtney considered that there was a degenerative process and made a s 323 deduction of 25%.
(g) Dr Rimmer recorded the following history:
“She has a significant past history of left shoulder pain intermittently for years. Prior to the work injury she had consulted with Dr Rae who had recommended a left total shoulder replacement, however, for personal reasons she declined.”
(h) The MA, certainly Dr Rimmer and to a certain extent Dr Courtenay have not taken the correct approach to the application of s 323 of the 1998 Act.
(i) The only evidence of any impairment or restriction in the applicant's left shoulder prior to the workplace injury was at best nominal.
(j) There is no evidence that the applicant had any impairment or restriction in her capacity to work, exercise or undertake domestic pursuits.
(k) The MA in considering the application of s 323 simply referenced the fact that an MRI performed post injury showed degenerative change in the shoulder joint. The approach was flawed.
(l) Cole v Wenaline Pry Ltd (2010) NSWSC 78, for example, is authority for the proposition that in order for a deduction to be made under s 323 there must be evidence that a pre-existing abnormality, condition or previous injury contributes to the impairment.
(m) In Fire & Rescue NSW v Clinen [2013] NSWSC 629, Campbell J referred to D'Aelo v Ambulance Service of New South Wales (1996) NSWCCR 139; Elcheikh v Diamond Formwork (NSW) Pty Ltd (in liq) [2013] NSWSC 365; and Cole. Campbell J said at [32]:
“As Schmidt J pointed out in Cole and Elcheikh, it is necessary to find a pre-existing abnormality or condition, here the latter, actually contributing to the impairment before s.323 WIM is engaged. This conclusion has to be supported by evidence to that effect. Assumption will not suffice.”
Campbell J also noted that it was “...necessary for the evidence acceptable to the appeal panel to actually support the connection between a previous injury (here, pre-existing abnormality or condition) and the overall degree of impairment in the instant case.”
(n) There is no evidence of a prior, symptomatic, condition.
(o) The mere existence of 'degenerative change' is insufficient to warrant a deduction; more is needed to attribute any assessable impairment to such a condition for it to be of any relevance.
(p) There is no evidence there was any impairment of the left shoulder prior to injury that would justify any deduction under s 323; let alone the 100% posited by Dr Rimmer and the 50% posited by the MA.
(q) It is also observed that while the approach of Dr Courtenay in applying a 25% deduction is more modest the application of same, in the applicant's submission, is still incorrect and that the correct approach would be no deduction or with reference to the identified tendinopathy pre-injury perhaps justify the application of a 10% deduction.
(r) The fundamental problem with the MA's approach is the assumption that evidence of pre-existing condition means, ipso facto, a deduction must be applied. This misunderstands the statutory scheme and is an error.
(s) As regards the issue of scarring, the MA should have assessed at least 1% WPI having regard to all of the evidence.
As we said earlier, the respondent submits that no errors were made.
Specifically, the respondent submits:
(a) as held in Bustos v Cleaners NSW Pty Ltd (in liquidation) [2019] NSWWCCMA 32, the MA is entitled to their own independent assessment and an assessor is not bound to follow and/or accept previous findings by other doctors.
(b) The MA made an appropriate deduction with respect to the left shoulder – a deduction of 0% to 10%, would be at odds with the evidence before the MA.
(c) The MA’s assessment of the pre-existing condition under s 323 is correct and is based on his independent assessment of the appellant and review of the material provided to him.
(d) As was held in Vitaz v Westform (NSW) Pty Limited [2011] NSWCA 254 at [43], (Vitaz) an MA is entitled to reach his own conclusions, no doubt partly on an intuitive basis, and no reasons are required in circumstances where the alternative conclusion is not presented by the evidence and is not shown to be necessarily available.
(e) In accordance with clause 14.6 of the Guidelines, “…uncomplicated scars for standard surgical procedures do not, of themselves, rate an impairment”.
(f) Dr Rimmer also assessed 0% WPI for scarring on the basis that the appellant “is not conscious of scar. Any suture marks are barely visible. No contour defect. No affect on any ADL [activities of daily living]”.
(g) The MA has assessed the appellant with 0% WPI based on his clinical observations made during the assessment, and adequate and proper consideration of the applicable Guidelines.
Discussion
Dealing firstly with the s 323 issue, we note that the section provides as follows:
“(1) In assessing the degree of permanent impairment resulting from an injury, there is to be a deduction for any proportion of the impairment that is due to any previous injury (whether or not it is an injury for which compensation has been paid or is payable under Division 4 of Part 3 of the 1987 Act) or that is due to any pre-existing condition or abnormality. (2) If the extent of a deduction under this section (or a part of it) will be difficult or costly to determine (because, for example, of the absence of medical evidence), it is to be assumed (for the purpose of avoiding disputation) that the deduction (or the relevant part of it) is 10% of the impairment, unless this assumption is at odds with the available evidence.” (Emphasis added.)
In Ryder v Sundance Bakehouse [2015] NSWSC 526 (Ryder), Campbell J said:
“What s.323 requires is an inquiry into whether there are other causes, (previous injury, or pre-existing abnormality), of an impairment caused by a work injury. A proportion of the impairment would be due to the pre-existing abnormality (even if that proportion cannot be precisely identified without difficulty or expense) only if it can be said that the pre-existing abnormality made a difference to the outcome in terms of degree of impairment resulting from the work injury”. (Emphasis added.)
The principle established in Vitaz is that if a pre-existing condition is a contributing factor causing permanent impairment, a deduction is required even though the per-existing condition had been asymptomatic prior to the injury.
In the present case, there is in our view clear evidence of such a pre-exiting condition not only in light of the radiological material and the histories obtained and opinions expressed by Drs Courtney, Rimmer and the MA but for a number of other reasons set out below.
In her statement dated 14 June 2023, Ms Kershaw said:
“Approximately two years before the injury, I started experiencing intermittent mild pain in my left shoulder.
I used heat packs, anti-inflammatories, and had to take occasional breaks to manage the pain.
When I slipped, I landed heavily on my hands, knees, and elbows.
On my landing, I experienced massive pain in my left elbow, left thumb and both knees. Initially I thought that I broke my left thumb.
The next day, I experienced pain in my left shoulder, knees, and elbows due to the bruises.
I consulted Dr Ejaz Mohammad, the company doctor. He recommended rest, ice, and elevating my legs. He prescribed anti-inflammatory medication.
When I revisited the doctor a week later and reported no improvement, the GP referred me for an ultrasound of my left shoulder. [The scan] revealed some issues in my left shoulder, prompting the NTD to order an MRI scan. I underwent the scan in February 2021.
Subsequently, Dr Mohammad referred me to orthopaedic surgeon Dr Hamish Rae, whom I consulted sometime in May 2021.
Dr Rae informed me that my shoulder had developed arthritis and required surgery.
Unfortunately, Dr Rae believed that my employment with Spotless was not the primary cause of my injuries…
I finally underwent shoulder surgery on 1 March 2022…”
To begin with, Ms Kershaw herself admitted to prior left shoulder pain which required treatment and “breaks” to manage the pain.
Dr Rae was not convinced that her symptoms were caused by her employment with the respondent.
Clinical notes from Goulburn Medical Clinic record: “Past History:…18/07/2017 Osteoarthritis.”
Clinical notes from the Goulburn Clinical Hub note: “04/08/2020 Left Osteoarthritis of shoulder.”
An X-ray of the left shoulder on 5 November 2021, after the shoulder surgery, demonstrated: “There is glenohumeral joint osteoarthritis with osteophytic lipping and marked joint space narrowing. There is minor acromial spurring.”
In his report dated 29 April 2021, Dr Rae said:
“The MRI scan has revealed fairly severe glenohumeral osteoarthritis as well as moderate AC joint arthrosis. There is also a minor partial thickness tearing to the superior border of subscapularis at the biceps pulley as well as a small supraspinatus partial thickness tear that is likely only a minor contributor to her issues…
There is underlying moderate to severe osteoarthritis which could be better assessed on plain x-rays and I would like her to return with those next week.”
In a report dated 7 May 2021 Dr Rae said:
“X-rays have confirmed the advanced arthritis with osteophyte formation, loss of joint space, sclerosis and small subchondral cysts. There is some posterior wear of the glenoid on the axial view. I have once again discussed Karina's options with her. She is currently experiencing exacerbation of her shoulder arthritis from a fall at work. The ongoing pain, irritation, and stiffness. means that she is coming to a shoulder replacement in the not too distant future.”
In his report dated 16 November 2022, Dr Courtney said:
“She has had no other particular major problems with her shoulder. She has had no injuries. She was aware of some aches and pains in her left shoulder, but it was her non dominant arm and she could manage…
It was an on and off problem, but she kept doing all her general activities.
Ms Kershaw had a known osteoarthritis of her left shoulder prior to her having the fall in December 2020. However she was working, and continued to work. She was actually, on the day of the fall, doing fairly heavy work where she was using a tile striper to clean oil and residue off floor tiles. If she had been managing that, and from the description that she gave me, that despite some aches and pains and modifying her activities, she had been able to continue with her work despite the shoulder issue.
The fall on that particular day caused severe pain in the left shoulder, and that shoulder pain did not settle.
With regards to the outcome of the shoulder, if it had not been for the fall she would have had continuing symptoms in that shoulder, however there is no evidence to suggest, with it being her non dominant arm, that it would have actually stopped her from working as a cleaner until her normal expected retirement age which was approximately six (6) or seven (7) years after she had her particular fall. The fall acutely exacerbated and accelerated the symptomatology of that shoulder, and it did necessitate the reverse shoulder replacement. There is no doubt that there was a component of pre-existing problems, however if it were not for the fall, I am of the opinion that she would not have required that surgery, and certainly not for many years to come.
Following examination, the writer would proffer a diagnosis of osteoarthritis of the left shoulder.”
Dr Courtney assessed 20% WPI in respect of the left upper extremity from which he deducted 25% under s 323.
He said: “There is a degenerative process and I am of the opinion that it was exacerbated, but there is a requirement for some deduction due to pre-existing. I have made that assessment at 25% deduction, due to the pre-existing [condition].”
Dr Rimmer saw the appellant on 27 March 2023. He noted that he did not have any radiological material before him. In his report dated 28 March 2023 he said:
“She has a significant past history of left shoulder pain intermittently for years. Prior to the work injury she had consulted with Dr Rae who had recommended a left total shoulder replacement however for personal reasons she declined.
Yes her diagnosis is consistent with that of a disease process ie; chronic degenerative osteoarthritis of the left shoulder. In my opinion employment has not been the main contributing factor to the deterioration of disease process as it is well documented prior to the subject injury Ms Kershaw had consulted with Dr Rae for her left shoulder who had recommended a total shoulder replacement however for personal reasons Ms Kershaw declined at that time.”
Dr Rimmer assessed 14% WPI, adding:
“100% of the WPI is apportioned to a pre existing condition to the left shoulder ie; prior to the subject incident she had consulted with Dr Rae (orthopaedic surgeon) regarding a left total shoulder replacement.”
In summary, there is ample evidence to show that the appellant had significant arthritis in her left shoulder.
That arthritis in our view certainly contributed to the overall impairment. It was that condition which led to her surgery.
Ms Kershaw was treated for the condition prior to the work injury, and was equally (to a degree) symptomatic at the time of the injury.
The description of the fall she gave was primarily onto her elbows and knees, but it is accepted that the force of the impact contributed to increased left shoulder pain.
The only real error the Panel can see is the submission by the appellant that: “The mere existence of 'degenerative change' is insufficient to warrant a deduction; more is needed to attribute any assessable impairment to such a condition for it to be of any relevance.”
That is where the MA has fallen into error.
He simply stated that: “With the existing circumstances, a frequently utilised deduction of one-tenth would be at complete odds with the existing information. Ultimately a deduction of half is considered appropriate.”
He did not explain his reasons for determining that a 50% deduction was “appropriate.”
A failure to provide adequate reasons is an error.
Although he correctly identified that a 10% deduction would be at odds with the available evidence, (in his view), he has failed to adequately consider factors such as the appellant’s ability to function well prior to the fall, in that she worked full time in a fairly strenuous occupation and was able to undertake all necessary personal and other tasks.
The Panel has carefully considered all of the evidence, the submissions and the various authorities to which we have referred.
In our view, a deduction of one-third seems to reflect all of the evidence and the various medical opinions provided.
Turning next to the issue of scarring, only Dr Courtney considered that there was an impairment. He said: “There is a very obvious anterior scar, but it is well healed and there is no hypersensitivity in the area of that scar.”
Dr Rimmer opined: “She is 0% WPI ie; claimant is not conscious of scar. Any suture marks are barely visible. No contour defect. No affect on any ADL which is 0%.”
In her statement the appellant made no reference to her scar, let alone any issues she experienced with it.
According to the table for the evaluation of minor skin impairment (TEMSKI) the following matters are relevant to the assessment of ‘best fit’:
· conscious of the condition;
· colouration (matching with surrounding skin);
· easily located;
· trophic changes;
· staple or suture marks visible;
· anatomic location relative to usual clothing/hairstyle;
· contour defect, and
· effect on ADL’s.
There is no doubt that it was listed in the referral to the MA and Dr Courtney and Dr Rimmer were specifically asked to address it.
Only Dr Rimmer has made some attempt to address the requirements of the TEMSKI scale.
We agree that the MA failed to do this, as did Dr Courtney. A mere statement that the there is “a very obvious anterior scar, but it is well healed and there is no hypersensitivity in the area of that scar” is insufficient.
Although as we said the MA failed to address the relevant requirements, so did the appellant.
In the absence of any complaints by the appellant, it is difficult to see how any rateable impairment could be assessed.
For these reasons, we do not consider that the appellant has any impairment such that a 0% assessment is correct.
For these reasons, the Appeal Panel has determined that the MAC issued on 22 January 2024 should be revoked, and a new MAC should be issued. The new certificate is attached to this statement of reasons.
WORKERS COMPENSATION DIVISION
APPEAL PANEL
MEDICAL ASSESSMENT CERTIFICATE
Injuries received after 1 January 2002
Matter number: | W6518/23 |
Applicant: | Karina Kershaw |
Respondent: | Spotless Services Australia Pty Ltd |
This Certificate is issued pursuant to s 328(5) of the Workplace Injury Management and Workers Compensation Act 1998.
The Appeal Panel revokes the Medical Assessment Certificate of Medical Assessor Tim Anderson and issues this new Medical Assessment Certificate as to the matters set out in the table below:
Table - whole person impairment (WPI)
| Body Part or system | Date of Injury | Chapter, page and paragraph number in WorkCover Guides | Chapter, page, paragraph, figure and table numbers in AMA 5 Guides | % WPI | Proportion of permanent impairment due to pre-existing injury, abnormality or condition | Sub-total/s % WPI (after any deductions in column 6) |
| 1. Left upper extremity (shoulder) | 14/12/20 | Chap 2 P 10 | P 476 P 477 P 479 P 506 P 439 | 17% | 1/3rd | 11% |
| 2. Scarring | 14/12/20 | P 74 T 14.1 | 0% | N/A | 0% | |
| Total % WPI (the Combined Table values of all sub-totals) | 11% | |||||
0
6
0