In Gomez v. Casa Sandoval (2003) 68 Cal.Comp.Cases 753, the Workers Compensation Appeals Board (WCAB) held that in successive injury cases an apportionment of liability must be made by the WCAB, setting the specific percentage of liability of all carriers, which will also set CIGA's (California Insurance Guarantee Association) liability for any now-insolvent carrier. In Gomez, the WCAB relied on Labor Code sections 3208.2 and 5303, prohibiting merger of multiple injuries and requiring separate findings of fact and awards for each separate injury. Labor Code section 3208.2 provides: "When disability, need for medical treatment, or death results from the combined effects of two or more injuries, either specific, cumulative, or both, all questions of fact and law shall be separately determined with respect to each such injury, including, but not limited to, the apportionment between such injuries of liability for disability benefits, the cost of medical treatment, and any death benefit." Labor Code section 5303 provides in relevant part: "There is but one cause of action for each injury coming within the provisions of this division. ... No injury, whether specific or cumulative, shall, for any purpose whatsoever, merge into or form a part of another injury; nor shall any award based on a cumulative injury include disability caused by any specific injury or by any other cumulative injury causing or contributing to the existing disability, need for medical treatment or death." The WCAB reasoned: "The requirement of separate findings of fact for each injury supports the conclusion that between or among successive injuries, there is no 'other insurance ... available to the claimant or insured' under Insurance Code section 1063.1(c)(9). In successive injury cases, the liability is not joint and several among or between carriers, but rather, awards are made for the convenience of the applicant, with a single carrier to provide benefits subject to subsequent apportionment of liability, as required by Labor Code sections 3208.2 and 5303. The result is no different where CIGA has been joined on behalf of an insolvent carrier. This approach is required because case law has established that section 3208.2 is concerned with the sharing of loss by employers, and not with the apportionment of benefits between the employer and the injured worker." (Gomez, supra, 68 Cal.Comp.Cases at p. 760.)