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There have, in recent years, been several cases dealing with exposure to physical conditions, such as lead paint, asbestos or pollutants, over extended periods of time, and the issue of whether one, or more than one, coverage limit was or could be applicable under the particular circumstances. As will be seen, the results in these cases are highly dependent upon the specific language of the policies at issue. More specifically, as will be demonstrated, in those decisions that have held that the coverage was limited—either to the per occurrence limit, rather than the aggregate limit, or to a single policy, rather than multiple successive policies—the policies contained specific noncumulation or anti-stacking clauses, or provisions clearly and specifically defining all bodily injury and property damage resulting from continuous or repeated exposure to the same general conditions to be the result of one occurrence. Where such provisions are absent from the policy, the opposite result may obtain, as was the case in a recent Court of Appeals decision discussed later.

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