The Pennsylvania Supreme Court has adopted a 'multiple trigger' approach, whereby, under primary insurance policies obligating the insurer to 'pay on behalf of the Insured all sums which the Insured shall become legally obligated to pay,' all stages of the disease process, from initial exposure through incapacitation, are deemed to be 'bodily injury' triggering coverage under all primary policies on the risk during the entire period in which the disease evolved.
Paul AlpLeslie Epley DavisThe Joint-and-Several Allocation Scheme
It is not uncommon for an insurer to issue successive liability policies to its policyholders. When a loss occurs at a finite temporal point, such as a car accident or factory explosion, the parties generally do not face any difficulty in determining which policies will be called upon to respond.
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