Everardo Morales — ADJ20483896

Applicant Everardo Morales, a cook, sustained admitted industrial injury to his skin and psyche on January 3, 2025, when a steam oven exploded, causing burns to 18% of his body. The WCJ awarded 52% permanent disability including psychiatric impairment, finding the injury was catastrophic under Labor Code section 4660.1(c)(2)(B). Defendant sought reconsideration, arguing the burns were not catastrophic (healing in 19 days with topical care) and thus psychiatric impairment could not increase the PD rating. The Appeals Board granted reconsideration, rescinded the F&A, and remanded, finding the record inadequate because the QMEs failed to distinguish between a direct psychiatric injury (not barred) and a compensable consequence psychiatric injury (barred unless an exception applies). The Board provided extensive guidance on the Wilson analytical framework, emphasizing that the threshold question is whether the psychiatric injury was directly caused by the industrial event or arose as a compensable consequence of the physical injury.