Larry Bulman v. HHS - Influenza, left Shoulder Injury Related to Vaccine Administration (SIRVA) (2023)

Larry Bulman, a 76-year-old man, received an influenza vaccine on September 25, 2018. He filed a petition alleging a Shoulder Injury Related to Vaccine Administration (SIRVA).

Initially, the case was handled as a potential Table claim, but it was determined that Mr. Bulman could not preponderantly establish that his pain began within 48 hours of vaccination, a key element for a Table SIRVA claim.

The case was then transferred to an individual docket to assess entitlement under an off-Table, causation-in-fact theory. Mr.

Bulman's medical records indicated he first reported left shoulder pain approximately three months after vaccination, on January 22, 2019, with a diagnosis of rotator cuff tendonitis. He claimed immediate pain after the vaccine that worsened over days, but his first medical visit to discuss shoulder pain was three months later.

Petitioner's expert, Dr. Natanzi, opined that the vaccine caused SIRVA through an inflammatory response and that delayed treatment is common.

Respondent's expert, Dr. Abrams, argued that calcific tendonitis or idiopathic frozen shoulder were more likely causes and that the temporal relationship between vaccination and reported pain was not medically acceptable for SIRVA.

The Chief Special Master denied entitlement, finding that Mr. Bulman failed to establish a medically acceptable temporal relationship between the vaccination and his injury (Althen prongs two and three).

The court also noted that alternative explanations like calcific tendonitis, supported by Dr. Abrams, undermined the claim that the vaccine was the cause.

The case was decided on the record without a hearing.