CAROL ANN MCDONNELL, CAROL ANN PONCE vs. VAN CAN COMPANY, ZENITH INSURANCE COMPANY, STATE COMPENSATION INSURANCE FUND

Zenith Insurance Company sought reconsideration of an arbitration decision that denied its contribution claim against State Compensation Insurance Fund. Zenith argued the arbitrator erred by not finding cumulative injuries and that subsequent employment aggravated the applicant's permanent disabilities. The arbitrator recommended reconsideration, acknowledging evidence of cumulative trauma but finding the initial analysis inadequate regarding dates and causation percentages. The Appeals Board granted Zenith's petition, rescinded the original decision, and remanded the case for further proceedings on the cumulative trauma issue to determine liability sharing between insurers.