Pied Piper Pre-School Association (Wallerawang) Incorporated v Woolsey
[2004] NSWWCCPD 5
•2 February 2004
WORKERS COMPENSATION COMMISSION
APPEAL AGAINST A DECISION OF THE COMMISSION CONSTITUTED BY AN ARBITRATOR
CITATION:Pied Piper Pre-School Association (Wallerawang) Incorporated v Woolsey [2004] NSWWCCPD 5
APPELLANT: Pied Piper Pre-School Association (Wallerawang) Incorporated
RESPONDENT: Bernadette Marie Woolsey
INSURER:Allianz Australia Workers Compensation (NSW) Limited
FILE NUMBER: WCC 4674 -2002
DATE OF ARBITRATOR’S DECISION: 29 August 2003
DATE OF APPEAL DECISION: 2 February 2004
SUBJECT MATTER OF DECISION: Validity of Arbitral determination; Section 40 of the 1987 Act, Evidence of ‘suitable employment’; failure to base decision on logically probative evidence, error of law; Rule 70.
PRESIDENTIAL MEMBER: Dr Gabriel Fleming
HEARING:On the Papers
REPRESENTATION: Appellant: Dexter Healey Solicitors
Respondent: Higgins and Higgins Lawyers
ORDERS MADE ON APPEAL: The decision of the Arbitrator that “the Respondent pay the Applicant weekly compensation at the rate of $334.12 from 2 August 2002 under s40 of the Workers Compensation Act. Such weekly payments to continue in accordance with the provisions of the Act” is revoked.
The matter is referred back to the Arbitrator to determine the amount of the worker’s entitlements to compensation under section 40 of the Workers Compensation Act 1987, in accordance with these reasons.
BACKGROUND
On 21 August 2003, Allianz Australia Workers Compensation (NSW) Limited (‘the Appellant Insurer’) lodged an ‘Application for Appeal Against Decision of Arbitrator’ in the Workers Compensation Commission (‘the Commission’) on behalf of the employer Pied Piper Pre-School Association (Wallerawang) Incorporated (‘the Employer’). The appeal is against a decision dated 24 July 2003.
The Respondent to the Appeal is Bernadette Marie Woolsey (‘the Respondent Worker’).
An Amended Appeal and Submissions were filed on 9 September 2003 and served on the Respondent on 22 September 2003. This ‘Amended Appeal’ concerned an ‘Amended Decision’ dated 29 August 2003.
Rule 77(5) of the Workers Compensation Commission Rules 2003 (‘the Rules’), provides that the Reply should be filed within 14 days of being served with the application, which, in this case, was by or on 6 October 2003. The Respondent filed submissions in reply on 5 December 2003.
This matter was referred to me on 16 December 2003 for review.
VALIDITY OF THE DETERMINATION
The Appellant takes issue with the validity of the ‘Amended Certificate of Determination’ and ‘Amended Statement of Reasons’, both issued on 29 August 2003. To determine this issue it is necessary to review the conduct of the matter by the Commission.
A Certificate of Determination was issued by the Commission on 24 July 2003, with an attached statement of reasons. The letter that was sent to the parties accompanying the copy of the Certificate, is dated 23 July 2003.
A second Certificate of Determination and reasons, in exactly the same terms, was issued on 1 August 2003. The Appellant has produced a copy of this document, although the original document is not contained in the Commission file. I accept that this document was issued by the Commission.
On 4 August 2003 the Registrar received a request from the Insurer (copy to the worker’s legal representative) that a “replacement Certificate of Determination and Statement of Reasons be issued pursuant to Section 294 of the [Workplace Injury Management and Workers Compensation Act 1998] as amended replacing the sum of $227.30 per week with that of $163.92 per week” on the basis that the amount represented “obvious errors in respect of the rate of weekly compensation awarded by the Arbitrator”. The Insurer requested that “[a]lternatively, if the Arbitrator maintains that the sum of $227.30 per week is correct we request that further reasons be provided in respect of same”.
This request was sent to the Arbitrator on 18 August 2003.
Section 294(3) of the Workplace Injury Management and Workers Compensation Act 1998 (‘the 1998 Act) provides that:
If the Registrar is satisfied that a Certificate as to a determination or a statement attached to the certificate contains an obvious error, the Registrar may issue, or approve of an Arbitrator issuing, a replacement certificate or statement to correct the error.
In relation to the request for “further reasons” it should be noted that neither the 1998 Act nor the Rules require (nor indeed allow) an Arbitrator to provide more than one statement of reasons in relation to a decision (see section 294(2) of the 1998 Act and Rule 73).
Section 350(3) of the 1998 Act provides that:
The Commission may reconsider any matter that has been dealt with by the Commission and rescind, alter or amend any decision previously made or given by the Commission.
No application was made to the Registrar or the Arbitrator to reconsider the substance of the decision, nor is there any record on the Commission file to indicate that the Arbitrator did so.
There is also nothing on the Commission file to indicate that the worker was given the opportunity to express a view on the Insurer’s request to correct an “obvious error” in the decision.
An “Amended Certificate of Determination” was then issued on 29 August 2003, accompanied by an “Amended Statement of Reasons”. This was identical to the first two statements of reasons up to paragraph 40 (i.e. the second paragraph ‘40’ in the first two decisions - there were two paragraphs numbered 40).
The amended Certificate of Determination, and attached reasons, makes no reference to reconsideration pursuant to section 350, nor to section 294 of the 1998 Act and what, if any, parts of the Certificate have been corrected for ‘obvious error’.
The substance of the decision was substantially altered by the orders contained in the Amended Certificate of Determination. The reasons for the decision were also substantially changed. The amount of compensation to be paid to the worker was increased by the new order. The previous orders directed that the Respondent pay $334.12 from 2 August 2002 to 2 November 2002 only, and further directed that the amount of $227.30 be paid on and from 3 November 2002 (the later orders are set in full out below).
The Appellant Insurer is correct in raising issues as to the force and effect of the third ‘Amended Certificate of Determination’, dated 29 August 2003. Correction of an “obvious error” pursuant to section 294 of the 1998 Act does not extend to substantive reconsideration of the decision.
I also accept the Appellant’s submission that the requirements of procedural fairness apply to the Commission and to any review or reconsideration of an Arbitrator’s decision.
The Appellant has not sought to have the decision wholly set aside, nor has the Respondent worker taken issue with the conduct of the matter. The central issue in the appeal is the proper calculation of the worker’s section 40 entitlements, which the Appellant insurer claims were wrongly calculated in all of the Certificates of Determination issued by the Commission. Given this, and the flexibility given to the Commission in regard to its procedures (section 354 of the 1998 Act) I will proceed to review the determination dated 29 August 2003. For the purpose of this appeal the orders and reasons dated 29 August 2003 are taken to be the final determination by the Arbitrator.
THE DECISION UNDER REVIEW
The Amended Certificate of Determination, dated 29 August 2003, records the Arbitrator’s orders as follows:
· That the Respondent pay the Applicant weekly compensation at the rate of $437.12 from 6 May 2002 to 1 August 2002 under s36 of the Workers Compensation Act 1987.
· That the Respondent pay the Applicant weekly compensation at the rate of $334.12 from 2 August 2002 under s40 of the Workers Compensation Act. Such weekly payments to continue in accordance with the provisions of the Act.
· That the Respondent pay the Applicant’s section 60 of the Workers Compensation Act expenses on production of accounts or receipts.
· That the Respondent pay the Applicant’s costs as agreed or assessed.
The Appellant disputes the amount of the worker’s entitlement pursuant to section 40 of the Workers Compensation Act 1987 (‘the 1987 Act), i.e. order 2 above, and submits that the Arbitrator has erred in the calculation of the worker’s entitlement.
ISSUES IN DISPUTE
The issues in dispute are:
1. Does the appeal meet the threshold criteria for the grant of leave set out in section 352 of the 1998 Act?
2. If the answer to 1 is yes, did the Arbitrator err in calculating the rate of the worker’s entitlement to compensation pursuant to section 40 of the 1987 Act?
A further procedural issue arises, namely; should the Respondent’s late submissions be permitted in the appeal?
ON THE PAPERS REVIEW
Section 354(6) of the 1998 Act provides that:
If the Commission is satisfied that sufficient information has been supplied to it in connection with proceedings, the Commission may exercise functions under this Act without holding any conference or formal hearing.
Both parties agree to the determination of this matter on the papers.
Having regard to the Commission’s Practice Directions (see No.1 and No. 6), and the submission by the parties that the appeal can proceed to be determined on the basis of the documents before me, I am satisfied that I have sufficient information to proceed ‘on the papers’, without holding any conference or formal hearing, and that this is the appropriate course in the circumstances.
The matter of the late filing of a Reply by the Respondent may be briefly dealt with. The Appellant Insurer objects to the Respondent Worker being permitted to file her Reply out of time. In the ordinary course of an appeal good reasons must be provided to justify why a Reply, filed several months late, should be admitted. In this matter the Reply is of so little
substance and assistance to the Commission and the Appellant, that the point is moot. The Reply, in full, is as follows:· The respondent argues leave should not be granted to review the decision as the Arbitrator had the benefit of viewing the applicant on the hearing giving evidence (sic) and making findings of fact based thereon. The Arbitrator was correct in his decision and there are no grounds for an appeal therefrom.
· The Application for leave should be determined on the papers as there are no new or novel questions of law involved. The matter is simply a finding on the facts by the Arbitrator who had the opportunity of making his own decisions on credit and the workers capacity generally on the open labor (sic) market of the Applicant.
I will take these brief submissions into account.
LEAVE
Before proceeding to deal with an appeal the Commission must determine whether the application meets the requirements of section 352 of the 1998 Act, which provides:
352Appeal against decision of Commission constituted by Arbitrator
(1)A party to a dispute in connection with a claim for compensation may, with leave of the Commission constituted by a Presidential member, appeal to the Commission as so constituted against a decision in respect of the dispute by the Commission constituted by an Arbitrator.
(2)The Commission is not to grant leave to appeal unless the amount of compensation at issue on the appeal is both:
(a)at least $5,000 (or such other amount as may be prescribed by the regulations), and
(b) at least 20% of the amount awarded in the decision appealed against.
(3)If the Commission refuses to grant leave to appeal, the Commission must state reasons for the refusal in writing to the parties.
(4)An appeal can only be made within 28 days after the making of the decision appealed against.
(5)An appeal under this section is to be by way of review of the decision appealed against.
(6)Evidence that is fresh evidence or evidence in addition to or in substitution for the evidence received in relation to the decision appealed against may not be given on an appeal to the Commission except with the leave of the Commission.
(7)On appeal, the decision may be confirmed or may be revoked and a new decision made in its place.
(8)In this section, decision includes an award, interim award, order, determination, ruling and direction.
The appeal was lodged within 28 days of the Arbitrator’s decision in compliance with section 352(4) of the 1998 Act.
The Appellant disputes the amount of the award in Order 2 above, and submits that Ms Woolsey has been awarded $170.20 per week in excess of her weekly entitlements from 7 May 2003 to date and continuing. This amounts to more than $5,000.
The amount is also more than 20% of the amount awarded in the decision appealed against. Taking the above calculations into account, the appeal meets the threshold requirements pursuant to section 352(2)(a) and (b) of the 1998 Act.
Leave to appeal is granted.
EVIDENCE AND SUBMISSIONS ON SECTION 40 ENTITLEMENTS
A conciliation was held in this matter on 12 June 2003. The parties were unable to reach a settlement of the matter and, therefore, it proceeded to arbitration on the same day. In accordance with the mandatory ‘Guideline for the Practice of the Conciliation Arbitration Process’ the arbitration phase of the proceedings was recorded.
The Appellant stated in submissions that it “did not obtain a copy of the transcript of proceedings as it did not expect to be placed in a position where it would be forced to file an Appeal” after having sought only the correction of ‘obvious errors’. The Appellant has since formally asked the Registrar for a copy of the sound recording of the arbitration. I am advised that the Registrar cannot meet this request, as the sound recording disc of the arbitration cannot be located.
If the oral evidence given at the arbitration hearing on 12 June 2003 was critical to the review, then it may have been necessary to allow fresh evidence (pursuant to section 352(6) of the 1998 Act). This difficulty has been avoided to some extent, as the parties are not seeking to introduce fresh evidence and are content to rely on the documentary evidence and submissions that were before the Arbitrator. The Appellant states that the worker did not give oral evidence before the Arbitrator and her evidence is as set out in a statement dated 30 September 2002. The Respondent worker however, as set out above, claims that one reason why the Arbitrator’s decision should not be overturned is that the Arbitrator “had the benefit of viewing the applicant on the hearing giving evidence”. Clearly the record of oral evidence and submissions made at the arbitration, if any, are not before me.
The documentary evidence that was before the Arbitrator is set out in the Arbitrator’s Amended Statement of Reasons, and it is not necessary that it be restated here in full. Not all of this evidence is before me on the appeal. A number of key documents do not appear on the Commission file, namely, the updated report of Dr Parmegiani dated 7 May 2003, and WorkCover Medical Certificates dated 8 June 2001, 19 June 2001, 15 June 2001, 9 May 2002 and 23 May 2002.
The Arbitrator made a number of findings upon which the calculation of Ms Woolsey’s entitlement to compensation was made. These include that:
· On and from 2 August 2002 Ms Woolsey was partially incapacitated for work as a result of a psychological injury, for which the Appellant Insurer was liable under the Workers Compensation Acts.
· At the time of her injury Ms Woolsey was earning $13.66 per hour and was working 32 hours per week. Her probable weekly earnings, but for the injury, had she continued at the same or in some comparable employment, were $437.12 per week.
· On and from 7 May 2003 Ms Woolsey was able to work at least 20 hours per week.
· Suitable employment was not available to her for more than five and a half hours per week. The Arbitrator considered Ms Woolsey’s own evidence that no more hours of suitable work were available to her. She worked for five and a half hours at the Lithgow Family Daycare Centre. The Arbitrator had regard to her “place of residence, . . . age and work experience”.
· At the time of the hearing she earned $103.00 per week for five and a half hours work at Lithgow Family Daycare Centre.
· She is entitled to $334.12 per week ($437.12-$103.00) from 2 August 2002 and continuing pursuant to section 40 of the 1987 Act.
The Appellant’s submissions may be summarised as follows:
· The Arbitrator’s finding that work in excess of five and a half hours per week was not available to the worker at the time of the hearing “is incorrect, not based on logically probative evidence and against the weight of the evidence”.
· This finding was based only on a finding that “the labour market reasonably open to the Applicant consisted solely of the Applicant’s current employment with the Lithgow Family Daycare Centre”.
· The worker’s ability to earn must be assessed in terms of her particular circumstances and the labour market accessible to her (Mangion v Visy Board Pty Limited (1992) 8 NSWCCR 175 at 180).
· Ms Woolsey’s evidence “reveals the presence of many potential child care employers in the Lithgow/Wallerawang area” (see paragraph 5 of statement). There is no evidence to support the finding that Lithgow Family Daycare Centre represents the only employment available to Ms Woolsey and, therefore, the Arbitrator erred in finding that her earnings with that employer represented the total amount she was able to earn in the general labour market, reasonably accessible to her.
· The Appellant submits that the worker is able to secure twenty hours of child care employment in the Lithgow area and, therefore, the correct award pursuant to section 40 is $163.92 per week (being $437.12 per week less $273.20 per week ($13.66 per hour times 20 hours).
· Alternatively, the Appellant submits that the report of Dr Parmegiani, dated 31 October 2002, supports a finding that the worker had been offered fifteen hours per week by her Lithgow Family Daycare Centre. Thus a finding that work in excess of five and a half hours of work was not available to her at the time of the hearing is inconsistent with the evidence. Accepting this evidence, the correct award “from 7 May 2003 to date and continuing is $232.22 per week being the Applicant’s pre-injury earnings of $437.12 per week less her ability to earn of $204.90 per week being $13.66 per hour x fifteen hours”.
As noted above, the Respondent worker’s submissions on the appeal do not take these issues any further.
The Arbitrator did not set out in detail the evidence that was before him in relation to ‘suitable employment’ available to Ms Woolsey.
Dr Parmegiani’s report of 31 October 2002 states that Ms Woolsey “was recently offered 15 hours per week [at the Lithgow Family Daycare Centre] but she did not feel able to take up the offer”.
The Arbitrator’s Amended Statement of Reasons states, in part, that:
“40. . . . Section 43A(3)(a) WCA requires me to have regard to what is “ suitable employment”. I have considered the elements of this section including the worker’s place of residence and the worker’s age and work experience.
41. I have made allowance in my orders for the fact that the Applicant had alternative suitable employment which paid her $103 per week for five and a half hours work from 2 August 2002. While I note that the Applicant has reduced her hours to three hours, I have no evidence before me to suggest that she could not return to five and a half hours per week if she wished. It is clear that as of 2 August 2002 the Applicant suffered from only a partial incapacity as she was able to return to work similar to her pre-injury employment. I understand from the Applicant that work in excess of five and a half hours was not available at the time of this hearing. Having regard to s40(3)WCA I find that this sum is the total amount the Applicant is able to earn in the general labour market accessible to the Applicant”
The Arbitrator’s reference to section 43A(3) (a) of the 1987 Act in paragraph 40 of the Amended Statement of Reasons is curious. That section concerns ‘suitable employment’ provided by the worker’s employer, which was not the issue the Arbitrator was considering in this matter.
DISCUSSION AND FINDINGS
The review of the Arbitrator’s decision in this matter is complicated by the lack of a transcript of the proceedings, the lack of a record of all the evidence on the Commission file and the administrative conduct of the matter in terms of the issue of three Certificates of Determination. I have proceeded to review the matter, bearing in mind the objectives of the Commission (section 367 of the 1998 Act), the flexibility of its procedures (section 354 of the 1998 Act) and the need to now bring this matter to resolution for the parties. I am of the view that it was not the intention of the legislation that a Presidential Member hears evidence on appeal that should have been given at first instance before the Arbitrator (Shipman Pty Ltd v Matters [2003] NSWWCC PD 19).
Section 40 of the 1987 Act provides as follows:
40 Weekly payments during partial incapacity—general
(1)Entitlement
The weekly payment of compensation to an injured worker in respect of any period of partial incapacity for work is to be an amount not exceeding the reduction in the worker’s weekly earnings, but is to bear such relation to the amount of that reduction as may appear proper in the circumstances of the case.(2)Calculation of reduction in earnings of worker—general
The reduction in the worker’s weekly earnings is (except as provided by this section) the difference between:(a) the weekly amount which the worker would probably have been earning as a worker but for the injury and had the worker continued to be employed in the same or some comparable employment (but not exceeding $1,000), and
(b) the average weekly amount that the worker is earning, or would be able to earn in some suitable employment, from time to time after the injury (but not exceeding $1,000).
Section 43A(1) of the 1987 Act sets out the matters that must be considered in relation to the provision of ‘suitable employment’ as follows:
For the purposes of sections 38, 38A and 40:
suitable employment, in relation to a worker, means employment in work for which the worker is suited, having regard to the following:
(a) the nature of the worker’s incapacity and pre-injury employment,
(b) the worker’s age, education, skills and work experience,
(c) the worker’s place of residence,
(d) the details given in the medical certificate supplied by the worker,
(e) the provisions of any injury management plan for the worker,
(f) any suitable employment for which the worker has received rehabilitation training,
(g) the length of time the worker has been seeking suitable employment,
(h) any other relevant circumstances.
The approach to be taken to the construction of section 40 of the 1987 Act was considered by the Court of Appeal, Kirby P, Handley JA and Sheller JA, in J C Ludowici & Son Ltd v Cutri (1992) 26 NSWLR 580 (Ludowici). Kirby P, concluded (at 593) that:
“… the preferable construction is that which has been repeatedly stated in the decisions of this Court. It is that where the worker is earning, the average weekly amount produced thereby is normally to be taken as the par (b) component of the equation. It is only otherwise where the decision-maker concludes that the worker is able to earn more than that sum in some suitable employment. Then, but then only, is a notional sum taken into account. It is subject to the maximum provided in par (b) itself. It is also subject to determinations as s 40(1A) and s 40(2) provide.
. . .
Parliament included the reference to what the worker “ is earning” for a purpose. The phrase cannot be ignored. The earnings are not mere evidence of what the worker is “able to earn”. In fact, if the worker is “ earning” that will normally be the end of the inquiry. It is only if, for some reason, that amount, where it exists, or existed, is suggested to be an under-estimate or a false measure of the worker’s ability to earn that the alternative inquiry will be embarked upon.”
In this case the evidence was that Ms Woolsey was, at the time of the hearing, working for five and a half hours per week at the Lithgow Family Daycare Centre. At first instance, following the reasoning in Ludowici, this amount should be accepted as representing her earnings under section 40 (2)(b) of the 1998 Act and should be deducted from the amount that she “would probably have been earning … but for (her) injury and had (she) continued to be employed in the same or some comparable employment” (section 40(2)(a)).
The question then to be considered by the Arbitrator is whether, on the evidence before him, that amount is suggested to be an under-estimate of Ms Woolsey’s ability to earn in suitable employment, taking into account the factors outlined in the definition of that term in section 43(A)(1) of the 1998 Act.
The Arbitrator accepted the evidence of Dr Parmegiani that “the Applicant can work at least 20 hours per week as at 7 May 2003”. In my view this was sufficient to enliven an inquiry as to whether her actual earnings of $103 per week at the Lithgow Family Daycare Centre were an under-estimate of her ability to earn in suitable employment. Thus the Arbitrator was required to embark upon further inquiries.
The determination of the amount that the worker could earn in some suitable employment is a question of fact to be determined by the arbitrator on the basis of logically probative evidence (North Broken Hill Ltd v Tumes [1999] NSWCA 309). The failure to make a decision based on logically probative evidence is an error of law (Azzopardi v Tasman UEB Industries Ltd (1985) 4 NSWLR 139) and a breach of the Rules (Rule 70).
The Appellant submits that the Arbitrator’s decision was against the weight of the evidence. Given that Ms Woolsey had demonstrated that she was actually earning $103 per week, it was for the employer (the Appellant in the appeal) to prove that this did not, in fact, represent the amount that she was able to earn in some suitable employment. Evidence relevant to establishing the availability of ‘suitable employment’, may include:
· reports addressing the worker’s capacity to find work, considering her age, skill, education and experience,
· labour market data about the particular geographic region or industry,
· evidence of application for employment and inability to be successful, and
· evidence of any specific barriers to employment relevant to the particular worker.
On the basis of the documents before me in the appeal there was limited evidence upon which to make any findings in relation to this issue. The factors taken into account were as follows:
· (a) and (b) of the list in section 43A(1) of the 1987 Act were obvious from the worker’s statement and the medical report of Dr Parmegiani.
· The Arbitrator states that he took into account Ms Woolsey’s “place of residence”. There was no evidence before him of the employment situation in Lithgow for childcare workers, or any other workers. There is a reference in the reasons to the Respondent’s contention that Ms Woolsey may be suited to work as a ‘shop assistant’. There is no evidence of the status of the labour market in the Lithgow area vis a vis child care or retail employment.
· The Arbitrator’s reasons state that he “understands from the Applicant that work in excess of five and a half hours was not available at the time of this hearing”. The Appellant’s point is well made that the employment situation at Lithgow Family Daycare may not provide a reasonable nor comprehensive picture of the employment possibly available to Ms Woolsey in Lithgow.
· There is a reference in Dr Parmegiani’s report to the offer of fifteen hours work per week at Lithgow Family Daycare Centre. However Dr. Parmegiani was reporting on what he was told by the worker, who did not give any evidence of this in her written statement.
There was, in my view, no persuasive evidence either way in relation to the availability of suitable employment to Ms Woolsey.
The review of this decision has been plagued with the difficulties outlined above. However, on balance, I am of the view that the question of Ms Woolsey’s ability to earn in suitable employment (section 40(2)(b)) has not been properly considered. In my view the appropriate decision on the appeal is that the order of the Arbitrator in relation to weekly payment of compensation during partial incapacity (section 40 of the 1987 Act) should be revoked. Given the state of the evidence before me on appeal, it is not appropriate that I proceed to make a determination of the issue of ‘suitable employment’. The matter should be referred back to the Arbitrator for a proper determination of Ms Woolsey’s entitlement to compensation for partial incapacity on and from 2 August 2002, being the date that the Arbitrator found her to be partially incapacitated. The parties should be given the opportunity to file evidence relevant to this issue.
DECISION
The decision in this matter is as follows:
· The decision of the Arbitrator that “the Respondent pay the Applicant weekly compensation at the rate of $334.12 from 2 August 2002 under s40 of the Workers Compensation Act. Such weekly payments to continue in accordance with the provisions of the Act” is revoked.
· The matter is referred back to the Arbitrator to determine the amount of the worker’s entitlements to compensation under section 40 of the Workers Compensation Act 1987, in accordance with these reasons.
Dr Gabriel Fleming
DeputyPresident
2 February 2004
I CERTIFY THAT THIS IS A TRUE AND ACCURATE RECORD OF THE REASONS FOR DECISION OF DR GABRIEL FLEMING, DEPUTY PRESIDENT OF THE WORKERS COMPENSATION COMMISSION.
ASSOCIATE
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