While mold spores are live organisms, as opposed to man-made chemicals, nevertheless, the analogy to lead is powerful. The mold grows in the plenums, ductwork, and walls of buildings, flaking out or otherwise eventually dispersing into the air, like lead flakes from paint. In that case, the California Court of Appeals stated as follows. Words in an insurance policy are to be given their ordinary and popular meanings. Therefore, we look to the ordinary meanings of discharge, dispersal, release and escape.
Dispersal is a scattering, spreading, or distribution.
Release is a liberation, freeing or permitting to escape. Escape is a leaking or overflow. These terms taken together constitute a comprehensive description of the processes by which pollutants may cause injury to persons or property. Because the Employers Casualty Co. case involved the inhalation of sulphur dioxide fumes in the workplace as the result of welding certain materials, the court considered the applicability of the pollution exclusion, and it noted the fact that under the terms of the exclusion, discharge, dispersal, release, or escape did not require a discharge of the pollutants into the environment or outside the area of their intended use. It stated that the plain language of the exclusion militates against any such restrictive environmental construction in that it expressly refers to discharge, dispersal, release, or escape at a site.