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                                                                     Exhibit 8.1


                        [KIRLAND & ELLIS LLP LETTERHEAD]


                               November 14, 2003


Norcross Safety Products L.L.C.
Norcross Capital Corp.
and the Guarantors set forth below
2211 York Road
Suite 215
Oak Brook, Illinois 60523


Re: Registration Statement on Form S-4


Ladies and Gentlemen:

         We are issuing this opinion letter in our capacity as special legal
counsel to Norcross Safety Products L.L.C., a Delaware limited liability company
(the "COMPANY"), Norcross Capital Corp., a Delaware corporation ("NORCROSS
CAPITAL" and together with the Company, the "ISSUERS"), and each of the
subsidiaries of the Company listed on Exhibit A attached hereto (the
"GUARANTORS" and together with the Issuers, the "REGISTRANTS") in connection
with the proposed registration by the Issuers of $152,500,000 in aggregate
principal amount of the Issuers' 9 7/8% Senior Subordinated Notes due 2011,
Series B (the "EXCHANGE NOTES") pursuant to a Registration Statement on Form S-4
filed with the Securities and Exchange Commission (the "COMMISSION") on November
14, 2003, under the Securities Act of 1933, as amended (the "ACT") (such
Registration Statement, as amended or supplemented, is hereinafter referred to
as the "REGISTRATION STATEMENT"). The Exchange Notes are to be issued pursuant
to an indenture (as amended and supplemented from time to time, the
"INDENTURE"), dated as of August 13, 2003, between the Issuers, the Guarantors
and Wilmington Trust Company, as trustee. The Exchange Notes are to be issued in
exchange for and in replacement of the Issuers' 9 7/8% Senior Subordinated Notes
due 2011 (the "OLD NOTES"), of which $152,500,000 in aggregate principal amount
are outstanding.

         You have requested our opinion as to certain United States federal
income tax consequences of participating in the exchange offer for Exchange
Notes described in the Registration Statement.

         On the basis of the foregoing, it is our opinion that the exchange of
the Old Notes for the Exchange Notes pursuant to the exchange offer will not be
treated as a taxable "exchange" for United States federal income tax purposes
because the Exchange Notes do not differ materially

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November 14, 2003
Page 2

in kind or extent from the Old Notes. The Exchange Notes received by a holder of
Old Notes will be treated as a continuation of the Old Notes in the hands of
such holder and, as a result, there will be no federal income tax consequences
to such holder as a result of such holder's exchange of Old Notes for Exchange
Notes.

         The opinion set forth therein is based on the applicable provisions of
the Internal Revenue Code of 1986, as amended; the Treasury Regulations
promulgated or proposed thereunder; current positions of the Internal Revenue
Service (the "IRS") contained in published revenue rulings, revenue procedures
and announcements; existing judicial decisions; and other applicable
authorities, all of which are subject to change, possibly with retroactive
effect.

         Unlike a ruling from the IRS, opinions of counsel are not binding on
the IRS. Hence, no assurance can be given that the opinion stated in the
Registration Statement will not be successfully challenged by the IRS or
rejected by a court. We express no opinion concerning any federal income tax
matter other than those discussed in the Registration Statement under the
caption "Material United States Federal Tax Considerations."

         We hereby consent to the filing of this opinion with the commission as
Exhibit 8.1 to the Registration Statement. We also consent to the reference to
our firm under the heading "Legal Matters" in the Registration Statement. In
giving this consent, we do not thereby admit that we are in the category of
persons whose consent is required under Section 7 of the Act or the rules and
regulations of the Commission.


                                               Very truly yours,



                                               /s/ Kirkland & Ellis LLP

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November 14, 2003
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                                    EXHIBIT A

Morning Pride Manufacturing L.L.C., a Delaware limited liability company

North Safety Products, Inc., a Delaware corporation

North Safety Mexico Holdings LLC, a Delaware limited liability company