In Owens-Illinois, Inc. v. United Ins. Co., 138 N.J. 437, 650 A.2d 974 (1994), the Court took pains to discuss and ultimately approve the trial court's conclusion that "an 'injury in fact' triggering coverage under the insurance policies occurs on the inhalation of asbestos fibers and continues up to and including manifestation of an asbestos-related disease." Owens-Illinois, supra, 138 N.J. at 445, 650 A.2d 974. Expanding on that statement, the Court concluded that, there is insult to tissue upon inhalation, and the insult continues during the residency, and obviously bodily injury occurs during the entire period of time, up to and including the date of manifestation of the disease. The "overwhelming weight of authority" elsewhere acknowledges the progressive nature of asbestos-induced disease, and affirms that "'bodily injury' occurs when asbestos is inhaled and retained in the lungs.". . . . We are satisfied, like most American jurisdictions, that medical science confirms that some injury to body tissue occurs on the inhalation of asbestos fibers, and that once lodged, the fibers pose an increased likelihood of causing or contributing to disease.Id. at 454, 650 A.2d 974. The District Court held that, "under New Jersey law the progressive nature of asbestos-related property damage triggers every policy on the risk from installation to removal." Owens-Illinois, supra, 138 N.J. at 455, 650 A.2d 974. In Owens-Illinois, the underlying liability for which the insured sought coverage was both bodily injury and property damage resulting from its installation of Kaylo, an insulating product that contained asbestos. In adopting the "continuous-trigger theory," the Court rejected two more limited alternatives: "the exposure theory" and "the manifestation theory." 138 N.J. at 449-51, 650 A.2d 974. The Court also rejected any rule whose only rationale was to maximize coverage. Id. at 452, 650 A.2d 974. Under the continuous-trigger rule, "the continuous period from exposure to manifestation" is the "occurrence" that triggers coverage. Id. at 450, 650 A.2d 974. Exposure is defined as "the date on which the injury producing agent first contacts the body." Id. The "conceptual underpinning" of the theory "is that injury occurs during each phase of environmental contamination--exposure, exposure in residence (defined as further progression of injury even after exposure has ceased) and manifestation of disease." Id. at 451, 650 A.2d 974. In Owens-Illinois, Inc. v. United Ins. Co, the New Jersey Supreme Court adopted the so-called "continuous trigger" standard, holding that in fixing the time of occurrence of an environmentally related injury, the injury must be regarded as occurring "during each phase of environmental contamination--exposure, exposure in residence (defined as further progression of injury even after exposure has ceased), and manifestation of disease." Owens-Illinois, supra, 138 N.J. at 451, 650 A.2d 974. Although Owens-Illinois dealt with asbestos-related personal injuries, the Court expressly noted that the continuous trigger theory also applied to environmental contamination cases: Property-damage cases are analogous to the contraction of disease from exposure to toxic substances like asbestos. Like a person exposed to toxic elements, the environment does not necessarily display the harmful effects until long after the initial exposure. Id. at 455, 650 A.2d 974.