In People v. Guest (1986) 181 Cal.App.3d 809, the court rejected a claim "that section 12022.7 is unconstitutionally vague because one cannot tell from instance to instance what injuries will be considered significant or substantial enough to constitute great bodily injury." (Id. at p. 811.) The court explained: "The orthodox test under the United States or California Constitutions for unconstitutional vagueness is whether the statute '"either forbids or requires the doing of an act in terms so vague that men of common intelligence must necessarily guess at its meaning and differ as to its application, violating the first essential of due process of law."' However, 'a statute is sufficiently certain if it employs words of long usage or with a common law meaning, "notwithstanding an element of degree in the definition as to which estimates may differ."' As we have stated . . . , 'We are persuaded by the long acceptance of "great bodily injury" as a term commonly understandable to jurors that it has not acquired a technical legal definition requiring in the absence of special circumstances a clarifying instruction.' While the defendant may be correct in that an 'I know it when I see it' standard is applied to injuries under section 12022.7 , men of common intelligence can apply these words of long usage to discern what injuries they are forbidden to inflict under pain of enhancement. . . . Section 12022.7 is constitutional." (People v. Guest, supra, 181 Cal.App.3d at pp. 811-812.)