An employee who was injured while attempting to rescue a person in distress at his employer’s job site was acting within the course and scope of his employment and, therefore, entitled to workers’ compensation, the Commonwealth Court held in Pipeline Systems, Inc. v. WCAB (Pounds), __ A.3d __ (No. 1577 CD 2014, filed July 7, 2015). On July 29, 2010, Franklin Pounds was working for his employer, Pipeline Systems, Inc., installing pipes at a sanitation plant. A plant employee fell into a nearby concrete pit, prompting Pounds and his co-workers to rush to the scene. Pounds descended a ladder into the pit and discovered the plant employee was deceased. As Pounds climbed out of the pit he was overcome by methane gas and fell approximately 20 feet to the ground. Pounds sought workers’ compensation for his injuries, which Employer contested as not work-related. The WCJ granted Pounds’ claim petition, holding that he was within the course and scope of employment when he was injured. The WCAB affirmed.
A unanimous Commonwealth Court panel affirmed in an opinion authored by Senior Judge Colins. In holding that Pounds’ injuries were compensable, the Court applied Section 601(a)(10)(ii) of the Workers’ Compensation Act, 77 P.S. §1031(a)(10)(ii), which provides benefits for an employee who, “while in the course and scope of employment, goes to the aid of a person and suffers injury” while “