In Kennedy v. Jefferson Smurfit Co., 147 N.J. 394, 688 A.2d 89 (1997), a divided Supreme Court determined that a manufacturer's negligent selection and use of defective packaging materials to facilitate the loading of its product onto the vehicle transporting its goods from the factory constitutes the commencement of loading that vehicle, and is therefore a covered act for purposes of omnibus loading/unloading liability coverage under that vehicle's policy. 147 N.J. at 401, 688 A.2d 89. In so finding, the Court distinguished our earlier decisions where defendants' alleged negligence resulted from negligent upkeep or defective premises, rather than active participation in the loading or unloading processes of the vehicles themselves. Id. at 401-03, 688 A.2d 89. The premises-liability cases deny coverage under the automobile policy for accidents occurring during loading and unloading activities because the accident arose not from the loading or unloading activities, but from the negligent acts of the owner of the premises where the accident occurred, prior to the loading or unloading of the vehicle. Id. at 401-02, 688 A.2d 89.