concurring.
I agree with the result in this workers’ compensation case, but I disagree with the majority’s interpretation of ORS 656.245(1). Specifically, I disagree with the majority’s conclusion that any contribution by a work-related injury to a claimant’s current condition could be a material factor in the need for medical services “without regard to the amount of its contribution so long as the injury is a fact of consequence regarding the claimant’s condition.” 208 Or App at 570. In my view, the majority’s definition of the statutory term is not helpful. The majority has simply substituted for the term “material” an equally imprecise concept, “fact of consequence.” I also do not consider the majority’s citations to dictionary definitions of “material” and to other provisions in chapter 656 particularly helpful, especially in light of a long line of cases that have grappled with the phrase and that I consider to be elucidating.
*572I agree with the majority that determining the meaning of the phrase “in material part” is a matter of statutory interpretation. 208 Or App at 568.1 also agree with the majority that the phrase “in material part” is not defined in ORS 656.245(1) or in any other part of the Workers’ Compensation Act. 208 Or App at 569. That said, in my view, the case law sheds considerable light on the meaning.
It is well established in the case law that a “major” contributing cause is one that is the primary cause (more than 50 percent) of the need for treatment or disability. Cummings v. SAIF, 197 Or App 312, 105 P3d 875 (2005); Dietz v. Ramuda, 130 Or App 397, 882 P2d 618 (1994), rev dismissed, 321 Or 416 (1995). In contrast, the meaning of the term “material contributing cause” is not so succinctly settled. In Olson v. State Ind. Acc. Com., 222 Or 407, 352 P2d 1096 (1960), the Supreme Court said:
“Reduced to its simplest form ‘arising out of as used in the act means the work or labor being performed was a causal factor in producing the injury suffered by the workman. It need not be the sole cause, but is sufficient if the labor being performed in the employment is a material, contributing cause which leads to the unfortunate result.”
222 Or at 414 (citations omitted; emphasis added). That case is regarded as having established “material contributing cause” as the standard of proof of medical causation applicable to original injury claims. Since Olson, numerous decisions have addressed the adequacy of proof necessary to satisfy the material contributing cause standard. See, e.g., Lorentzen v. Compensation Dept., 251 Or 92, 97, 444 Or App 946 (1968) (Medical “testimony that the exertion could have been ‘the straw that broke the camel’s back’ and that it ‘contributed to a degree’ is a manner of expressing the materiality of the exertion as a contributing factor.”); Jordan v. SAIF, 86 Or App 29, 33, 738 P2d 588 (1987) (evidence that claimant continued to suffer same symptoms from time of injury to time of aggravation was sufficient to establish that primary injury was material contributing cause of worsened condition). However, there is no single formulation of the requirement; “material” causes have been variously described as “precipitating,” Summit v. Weyerhaeuser Company, 25 Or App 851, 856, 551 P2d 490 (1976) (“material contributing cause” means something more than a minimal cause; it need not be *573the sole or primary cause, but only the precipitating factor); as “causing] at least a part” of the claimant’s condition, Kassahn v. Publishers Paper Co., 76 Or App 105, 110, 708 P3d 626 (1985) (evidence that primary injury “caused at least a part of claimant’s present, worsened condition” sufficient to establish that primary injury was material contributing cause); as a “but for” cause, see, e.g., Taylor v. SAIF, 75 Or App 583, 706 P2d 1023 (1985) (even though claimant’s obesity predisposed her to back problems, her condition requiring treatment did not exist until the 1981 injury, which was thus a material contributing cause of her condition); Lobato v. SAIF, 75 Or App 488, 706 P2d 1025 (1985) (although weight gain was probably sole cause of worsening, primary injury remained material contributing cause of worsened condition because claimant would probably not have experienced back difficulties as a result of his weight gain if not for the compensable injury); as a “moderate” cause, Wilkerson v. Davila, 88 Or App 298, 299, 744 P2d 1331 (1987) (evidence that primary injury was “moderate” contributor to subsequent condition sufficient to establish material contributing cause); as a “significant causal factor,” Havice v. SAIF, 80 Or App 448, 451, 722 P2d 742 (1986) (evidence that primary injury was “significant causal factor” was sufficient to satisfy claimant’s burden of proof on aggravation claim that primary injury was material contributing cause); and as a “direct” cause, Aetna Casualty Co. v. Robinson, 115 Or App 154, 158, 836 P2d 1362 (1992) (claimant satisfied material contributing cause standard by proving that condition is the direct result of his injury). This court’s case law has long established that a “material” cause is a cause that fits somewhere between a “minimal” cause and the only or “primar/’ cause. See Van Blokland v. Oregon Health Sciences University, 87 Or App 694, 698, 743 P2d 1136 (1987) (compensable injury need not be sole cause or most significant cause of need for treatment, but only “material contributing cause”); Cardwell v. SAIF, 6 Or App 175, 486 P3d 587 (1971) (testimony suggesting that work activity was a minimal rather than a material contributing cause of death not sufficient to meet claimant’s burden of proof of material contributing cause); Summit, 25 Or App at 856.
Dictionary definitions are equally unhelpful. Black's Law Dictionary 998 (8th ed 2004) defines the term “material” *574as “|h]aving some logical connection with the consequential facts. * * * Of such a nature that knowledge of the item would affect a person’s decision-making; significant; essential.” A “material cause” is defined in Webster’s Third New Int’l Dictionary 1392 (unabridged ed 2002) as “something out of which something is made or comes into being.” “Material” is defined as “being of real importance or great consequence : SUBSTANTIAL <found a ~ difference between the two things> <a ~ point of order> <made a ~ correction <a ~ correction.” Id. Thus, dictionary definitions place the possible meanings of the term “material” somewhere within range of “having some logical connection,” to “significant; essential.”
The narrow question presented here is whether, in light of what ORS 656.245(1) and the cases and dictionaries reveal, a “minor” cause can be a material one. I would hold that the answer is yes. A “minor” cause is a cause of lesser importance than a major cause, see Webster’s at 1439 (“minor” defined as “being the less important of two things”), but that does not mean that it is only a “minimal” cause in producing a need for treatment. Dr. Rask, the only physician who offered an opinion on causation, wrote that claimant’s compensable knee injury was a material cause of claimant’s need for treatment, albeit a “minor” one. Contrary to the board’s view, I would conclude that the two descriptions are not mutually exclusive and that Rask’s opinion is not internally inconsistent and is sufficient to satisfy the “material cause” standard of proof.
I therefore concur in the majority’s disposition to remand this case to determine whether the material or major contributing cause standard applies to this request for medical services under ORS 656.245(1).