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To prove medical causation, the claimant must show that the work-related activities either caused or contributed to his disability as a matter of medical fact.

To prove medical causation, the claimant must show that the work-related activities either caused or contributed to her disability as a matter of medical fact.

Application of this test was further broadened in Appeal of Briggs, 138 N.H. 623 (1994), in which the plaintiff conceded a pre-existing injury to his knee, but sought coverage for- exacerbation of that injury suffered while at work.

Appeal of Anheuser-Busch Co., 156 N.H. 677, 680 (2008) (quotations omitted); see also Appeal of Briggs, 138 N.H. 623, 626-28 (1994); Kacavisti v. Sprague Electric Co., 102 N.H. 266, 269-70 (1959).

Appeal of Briggs, 138 N.H. 623, 631 (1994); Appeal of Bergeron, 144 N.H. at 684.

A cumulative trauma injury often “may develop gradually, and with the presence of some pain,” resulting in “an acute manifestation occurring on a particular day which is so intolerable that it prevents the claimant from working.” Appeal of Briggs, 138 N.H. 623, 627 (1994).

Co., 143 N.H. 478, 480-81 (1999); Appeal of Briggs, 138 N.H. 623, 631 (1994).

at 635; see also Appeal of Briggs, 138 N.H. 623, 629 (1994) (workers’ compensation).

Unlike discrete injuries, cumulative traumas are not compensable until the date the disability arises, see Appeal of Briggs, 138 N.H. 623, 631 (1994), because it is not possible to identify a single event, occurring at a particular date and time, that caused the injury.

In declining to apply Briggs, the board stated, in pertinent part: [T]he claimant argued that [Appeal of Briggs, 138 N.H. 623 (1994),] requires the date of injury to be determined from April 1996.

As for the legal causation as stated in [Appeal of Briggs, 138 N.H. 623, 645 A.2d 655 (1994)], the Board was faced with the fact that the claimant did not treat with Dr. Sterns from April 18, 1986 until he saw Leo M. Kinney,- D. O. on April 21, 1994, when he was self-employed as a carpenter.

“Regardless of the presence of a pre-existing degenerative condition, an accidental injury within the meaning of the workers’ compensation law need not be traumatic or dramatic, but rather may arise from routine activities that result in an unexpected effect.” Appeal of Briggs, 138 N.H. 623, 627, 645 A.2d 655, 658 (1994).

Wausau argues that the injury is a cumulative trauma injury, and therefore the date of injury is the date Hudson was unable to continue working.

We have stated in workers’ compensation cases that cumulative trauma does not become disabling until the injured worker is unable to continue working.

Unlike a determination of medical causation, for example, that by its nature lies solely in the province of medical experts, see Appeal of Briggs, 138 N.H. 623, 629, 645 A.2d 655, 659 (1994), a claimant may be able to establish through lay testimony that travel outside the local area was warranted.

Appeal of Briggs, 138 N.H. 623, 629, 645 A.2d 655, 659 (1994) (board erroneously relied solely upon claimant’s work performance and lack of absenteeism to determine medical causation and did not cite medical evidence as support).

A disability which is causally related to cumulative work-related stress may constitute a compensable injury under New Hampshire’s workers’ compensation law.

Here, the board’s holding that the claimant has not established that he is currently disabled goes to the question of medical causation; namely, whether a work-related activity has caused his perceived disability as a, matter of medical fact.

Accordingly, the decision of the board is reversed and the claimant’s case is remanded for a determination of causation.

“The legal causation test defines the degree of exertion that is necessary to make the injury work-connected.” Appeal of Briggs, 138 N.H. 623, 628, 645 A.2d 655, 659 (1994).

(quotation and brackets omitted); see Appeal of Briggs, 138 N.H. 623, 628, 645 A.2d 655, 659 (1994).

To show that his injury “arose out of employment,” the claimant bore the burden of proving that either his act of bending under the towel machine or cumulative work-related stress to his back, see Appeal of Briand, 138 N.H. 555, 559, 644 A.2d 47, 49-50 (1994), probably caused or contributed to his disability under a two-pronged test.