JANET LIPSON vs. DAVID'S BRIDAL, THE HARTFORD INSURANCE COMPANY, NATIONAL FIRE & MARINE/AMERICAN COMMERCIAL CLAIMS ADMINISTRATION, TRAVELERS INSURANCE COMPANY

The Appeals Board affirmed the arbitrator's decision denying Hartford's petition for contribution. Hartford sought reimbursement from Travelers and ACCA for bilateral upper extremity injuries sustained by the applicant, Janet Lipson, while employed by David's Bridal. The arbitrator found insufficient evidence to establish a cumulative trauma injury beyond the period insured by Hartford, as Travelers' coverage ended before Lipson's employment and ACCA's coverage began later. The Board adopted the arbitrator's reasoning that medical reports lacked sufficient analysis to define a second cumulative trauma period for which other insurers would be liable.