Tammy Smith — ADJ1718407, ADJ1209790, ADJ1447715

Tammy Smith sustained two cumulative trauma injuries; the dispute was a contribution/reimbursement proceeding among successive insurers (ICNA, Georgia Pacific self-insured, and American Automobile Insurance Company administered by Allianz). A workers' compensation arbitrator issued a February 28, 2020 Findings, Award and Order apportioning permanent disability one-third to the first injury's carrier and two-thirds to the second, while holding that apportionment did not apply to temporary disability or medical treatment. Georgia Pacific and Allianz each sought reconsideration, challenging reliance on the AME reports and the arbitrator's failure to address issues and to allocate liability for temporary disability and medical treatment. The Appeals Board found the record inadequate—no arbitration transcript was filed and exhibits were not properly identified and admitted per Hamilton—and also found the arbitrator erroneously believed joint and several liability precluded division of liability in a contribution proceeding. The Board rescinded the decision and returned the matter to the arbitrator to create an adequate record and decide all issues.