Sanchez, Rigoberto

Rigoberto Sanchez, a pipe fitter, sustained an industrial injury on September 16, 2014, to his left leg, left knee, left hip, and reproductive system/testicles. The WCJ found applicant temporarily disabled from September 26, 2014 through October 11, 2017 and awarded temporary disability indemnity, denying defendant's request for credit for overpayment. Defendant sought reconsideration arguing the urological PQME's recommendation that applicant be placed 'close to a bathroom' did not constitute a real work restriction supporting temporary disability for the period June 1, 2016 through September 13, 2017, since employers are legally required to provide reasonable bathroom access. The Board denied reconsideration, holding that under Huston, the employer's failure to show modified work was available and offered entitled applicant to temporary disability indemnity. The PQME's bathroom-proximity restriction was a valid work restriction, and there was no evidence of a written return-to-work offer accommodating it.