¶ 1 In this insurance coverage declaratory judgment action, the Municipality of Mt. Lebanon, Pennsylvania (“Mt. Lebanon”) appeals the trial court’s grant of judgment on the pleadings in favor of Ap-pellee Reliance Insurance Company (“Reliance”). 1 Upon a thorough review of the record, we reverse.
¶ 2 This action arises out of underlying litigation commenced by Henry and Shirley Kersten (“the Kerstens”) аgainst Mt. Lebanon and Columbia Gas Company of Pennsylvania, Inc. (“Columbia Gas”). The Kerstens’ complaint included counts sounding in negligence and gross negligence and claimed damages in excess of $300,000. In their complaint the Kerstens averred that Mt. Lebanon and/or Columbia Gas:
created and/or failed to remedy dangerous conditions to the main fеed gas line and associated gas lines located within the vicinity of the [Kerstens’ home], including ... installing and/or maintaining a manhole directly over a gas line such that the gas line was left completely unsupported and suspended in air.
(Kersten Complaint, 4/1/99, attached as Exhibit B to Appellant’s Complaint, at 2-3.) They further alleged the negligence of Mt. Lebаnon and/or Columbia Gas in failing to inspect, maintain, and repair the gas line and in failing to comply with applicable standards and ordinances regarding the “inspection, maintenance, supervision, location and tests of gas lines, gas distribution systems and/or sewer lines and manholes.” (Id. at 5.) According to the complaint, in 1998, “a tree, whose roots hаd secured themselves around a portion of the gas line, uprooted, and created stress on the fine” causing “a rupture to that portion of the line left unsupported and severely corroded within the sewer manhole.” (Id. at 3.) As a result, “the gas from the ruptured line entered the sewer system and traveled into the [Kerstens’] property, and a fire ensued.” (Id.)
¶ 3 In addition to the allegations of negligence set forth above, the complaint in-
(f) failing and omitting to do and perform those things necessary in order to avoid an unreasonable risk of harm to [the Kerstens’] property;
(g) failing to take actions and precautions which wоuld have prevented the damages to [the Kerstens’] property ...; and
(h) otherwise failing to use due care under the circumstances.
(Id. at 5.)
¶ 4 In response to the Kerstens’ action, Mt. Lebanon sought insurance coverage from Reliance pursuant to a commercial general liability policy (the “policy”). Reliance denied coverage and refused to defend the underlying litigation on the basis of the “Total Pollution Exclusion” which was included as an endorsement to the policy. Mt. Lebanon instituted this action, seeking a declaration that Reliance had a duty to defend and to indemnify it against the Kerstens’ claims. Mt. Lebanon moved for partial judgment on the pleadings and Reliancе cross-moved for judgment on the pleadings. The trial court granted Reliance’s motion and this timely appeal followed.
¶ 5 Mt. Lebanon raises three averments of error: 2
1. Whether the trial court erred in concluding that Reliance had no duty to defend Mt. Lebanon when the underlying complaint contains allegations which potentially fall within the scope of coverage provided by the policy?
2. Whether the trial court erred in granting a motion for judgment on the pleadings when there are disputed issues of material fact such that the moving party is not entitled to judgment as a matter of law?
3.Whether the trial court erred in holding that the “total pollution exclusion” is ambiguous with respect to whether natural gas is a pollutant and, therefore, еrred in holding that coverage was excluded under this provision?
¶6 Our scope and standard of review in appeals of a grant or denial of a motion for judgment on the pleadings is well-settled. This Court applies the same standard as the trial court and confines its consideration to the pleadings and documents properly attached thеreto.
Lewis v. Erie Insurance Exchange,
¶7 Interpretation of an insurance contract is a matter of law.
See Madison Const. Co. v. Harleysville Mut. Ins. Co.,
¶ 8 In interpreting the language of a policy, the goal is “to ascertain the intent
¶ 9 When construing a policy, “[w]ords of common usage ... are to be construed in their natural, plain and ordinary sense ... and we may inform our understanding of these terms by considering their dictionary definitions” and where “the language of the [policy] is clear and unambiguous, a court is required to give effect to that language.”
Id.
at 606-608,
¶ 10 Under
Madison,
we must determine whether the specific substance at issue is a pollutant within the meaning of the particular insurance contract.
Id.,
The pertinеnt inquiry is not ... whether the policy’s definition of “pollutant” is so broad that virtually any substance, including many useful and necessary products, could be said to come within its ambit. Rather, guided by the principle that ambiguity (or the lack thereof) is to be determined by reference to a particular set of facts, we focus on the specific product at issue.
Id.
Moreover, when the question is one of contract interpretation, public policy arguments are irrelevant.
Id.
at. 611, n. 8,
¶ 11 Finally, under
Madison,
we must determine whether the requisite causation has been demonstrated.
Id.
at 610-613,
¶ 12 Using this methodology in
Madison,
our Supreme Court аffirmed the trial court’s grant of summary judgment based, in part, on its determination that the substance at issue in that case, a concrete curing compound called “Euco Floor Coat”, was a pollutant.
Id.
at 607-608,
¶ 13 This Court employed this analysis in two recent decisions considering whether pollution exclusion provisions contained in insurance contracts precluded coverage for poisoning allegedly caused by lead-based paint.
See Fayette County Hous. Auth. v. Hous. and Redev. Ins. Exc.,
¶ 14 In
Lititz,
a mother sued the owners of her rental property on behalf of her
¶ 15 In
Fayette County Housing Authority,
this Court sitting
en banc
addressed the issue of whether lead-based paint was a pollutant within the meaning of a pollution exclusion clause.
Fayette County Hous. Auth.,
¶ 16 To resolve the present case, we must apply the analysis mandated by Madison to the facts at hand. In this case, the substance in question is natural gas. The total pollution exclusion in the Reliance policy 3 states:
¶ 17 This insurance does not apply to:
(1) bodily injury or property damage which would not have occurred in whole or in part but for the actual, alleged or threatened discharge, dispersal, seepage, migration, release or escape of pollutants at any time.
The policy further states:
Pollutants means any solid, liquid, gaseous or thermal irritant or contaminant, including smoke, vapor, soot, fume, acids, alkalis, сhemicals or waste material....
¶ 18 The policy does not define either irritant or contaminant. As our Supreme Court has noted, “[w]ords of common usage in an insurance policy are to be construed in their natural, plain and ordinary sense, and we may inform our understanding of these terms by considering then-dictionary definitions.”
Madison,
¶ 19 In contrast to
Madison,
the record in the present case, consisting of the pleadings and documents properly attached thereto, reveals no such information. Indeed the only information before us con
¶ 20 Instead, Reliance argues that natural gas is “dangerous” аnd that “its harmful effects are well-known.” (Appellees’ Brief, at 16.) The definition of pollutant, however, does not speak in terms of danger or harmful effects, but instead requires the court to determine whether in the context of this particular factual situation natural gas is an irritant or a contaminant.
¶ 21 Reliance’s central argument is that the primary component of natural gas is methane gas, relying on
O’Brien Energy Systems, Inc. v. American Employers’ Insurance Company,
¶ 22 To deem any substance that may have harmful effects under certain circumstances to be unambiguously a “pollutant”
per se
would be to create the “absurd” result that Justice Cappy warned of in his dissent in
Madison. Madison Constr. Co.,
¶ 23 Mt. Lebanon also argues that preclusion of coverage in this situation by invocation of the total pollution exclusion is inappropriate because it is contrary to the reasonable expectations of the parties. Once again, the record beforе us discloses no such information.
¶ 24 Accordingly, we hold that Reliance has failed to carry its burden of proving that natural gas unambiguously is a pollutant as defined in the policy. 6 We cannot agree, therefore, based on the record before us that Reliance’s right to succeed is certain and the case is so free from doubt that trial clearly would be a fruitless exercise. On that basis, we hold the trial court erred in granting judgment on the pleadings in favor of Reliance and, accordingly, we reverse.
¶ 25 Mt. Lebanon’s argument that the trial court further erred in holding Reliance had no duty to defend provides an independent basis for our reversal of the trial court’s grant of judgment on the pleadings. Mt. Lеbanon argues that the underlying complaint sets forth allegations sounding in tort that potentially fall within the coverage of the policy. (Appellant’s Brief, at 14.)
¶ 26 Again, both parties direct our attention to
Madison,
where our Supreme Court held, under the facts of that case, that the insurer had no duty to defend.
¶ 27 Mt. Lebanon argues that the trial court failed to consider adequately whether any of the Kerstens’ claims are truly independent under
Madison.
We agree. The only information of recоrd in the present action regarding the Kerstens’ claims in the underlying litigation is found in the complaint, which contains numerous sweeping allegations of negligence. Even if we were to assume, which we do not, that natural gas unambiguously meets the definition of a pollutant under the policy, it remains to be seen at this stage of the litigation whether the Kerstens hаve made claims that truly are independent of Mt. Lebanon’s use of natural gas. Until it can be conclusively determined that all of the Kerstens’ claims against Mt. Lebanon fall outside of the scope of coverage of the policy, Reliance has a duty to defend Mt. Lebanon against all claims potentially within the scope of the policy.
See General Accident Ins. Co. of America v. Allen,
¶28 In the present case, Reliance has failed to carry its burden of proving that natural gas unambiguously is a pollutant as defined by the policy. Accordingly, the trial court erred in entering judgment on the pleadings in favor of Reliance. Moreover, the trial court further erred in concluding based upon the record before it that Reliance had no possible duty to defend Mt. Lebanon. We hold, therefore, that the trial court erred as a matter of law in granting judgment on the pleadings in favor of Reliance. Accordingly, wе reverse.
¶29 Judgment reversed. Jurisdiction relinquished.
Notes
. Nominal Appellees Henry and Shirley Kersten, the homeowners who filed the underlying litigation, did not participate in this appeal. The Insurance Environmental Litigation Association, however, filed an amicus brief in support of Reliance.
. We have paraphrased Mt. Lebanon's aver-ments of error.
. The policy is included in its entirety in the reproduced record. Contrary to Rule 2173 of Pennsylvania's Rules of Appellate Procedure, hоwever, Appellant has failed to number the pages of the reproduced record separately. This, combined with the fact that the policy itself is voluminous and not consecutively paginated, makes accurate citation to the particular policy provisions impossible. This is precisely the concern underlying Rule 2173 and we remind counsel of its importance.
. 42 U.S.C. § 9601(33).
. 35 P.S. § 6020.103.
.Having reached this conclusion, our inquiry ceases without reaching the issue of causation between the pollutant and the injury.