Case Commentary

Fire captain keeps benefits for alcohol disorder linked to workplace PTSD

WSIAT kept workers compensation entitlement for a retired fire captain’s alcohol use disorder, but refused wage loss benefits after retirement because he had not shown he probably intended to keep working.

A work related psychological injury can continue to affect workers compensation entitlement long after the employee leaves the workplace. Decision No. 385/26, 2026 ONWSIAT 846 also shows why post retirement wage loss is a separate question.

The worker was an Ontario fire captain who had spent 24 years in fire services and experienced repeated traumatic incidents. WSIB accepted PTSD as compensable in 2020. It later accepted alcohol use disorder as a secondary condition connected to the psychological injury.

The employer challenged that secondary entitlement. WSIAT rejected the appeal. The panel found that the work related PTSD had directly contributed to increased alcohol use and the need for treatment. The alcohol use disorder therefore remained compensable on an aggravation basis.

The worker brought a different appeal. He had retired at age 60 and sought loss of earnings benefits after retirement. The Tribunal accepted that his PTSD and alcohol use disorder prevented him from working when he retired. That was only part of the test.

To receive post retirement wage loss, the worker also had to show on a balance of probabilities that he probably intended to continue working after retirement. He had considered possibilities such as cross border trucking, but the record did not establish a real plan to work. Earlier WSIB records also recorded him saying that he was not planning other employment after retirement.

The Tribunal therefore dismissed the worker's appeal. His alcohol use disorder remained compensable, but he was not entitled to loss of earnings benefits after November 1, 2021.

For employers and workers compensation decision makers, the case separates medical incapacity from economic loss. A compensable condition can remain serious enough to prevent work without automatically establishing that retirement caused ongoing wage loss. The worker still has to prove that employment income would probably have continued but for the injury.

The case also reinforces that secondary psychological or substance use conditions should be assessed through their actual relationship to the compensable injury. The fact that alcohol use may have existed independently does not end the analysis if the workplace injury materially worsened it and created additional treatment needs.

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