Saturday, December 28, 2019
1.Non-Proliferative Breast Disease. Non-Proliferative Breast
1. Non-proliferative Breast Disease Non-proliferative breast disease, the most common lesion, is associated with small increased risk or no effect (relative risk 0.9-1.6) (e.g., fibroadenoma, cysts). 2. Proliferative Breast Disease without Atypia Women with proliferative breast disease without atypia had about 1.5 to 1.9 fold increased risk (e.g., adenosis, intraductal papilloma). 3. Atypical Hyperplasia Atypical hyperplasia produced about a 3 to 5 fold higher risk of breast cancer. Pathology of Breast Cancer Breast cancers can be classified by different schemes. Each of these aspects influences treatment response and prognosis. Description of a breast cancer would optimally include all of these classification aspects, as well as otherâ⬠¦show more contentâ⬠¦Patients with a high score benefit from radiotherapy after excision, whereas those of low grade, whose tumor is completely excised, need no further treatment. (Williams, et al., 2013) Surgical Treatment Options of DCIS a. Mastectomy for Patients with DCIS Mastectomy is by far the most effective treatment available for DCIS if the goal is simply to prevent local recurrence. Most mastectomy series reveal local recurrence rates of approximately 1% with mortality rates close to zero. Mastectomy is an aggressive form of treatment for patients with DCIS. It clearly provides a local recurrence benefit but only an indemonstrable and theoretical survival benefit. It is, therefore, often difficult to justify mastectomy, particularly for otherwise healthy women with screen-detected DCIS, during an era of increasing utilization of breast conservation for invasive breast carcinoma. Mastectomy is indicated in cases of true multicentricity (multi-quadrant disease) and when a unicentric DCIS lesion is too extensive to excise with clear margins and an acceptable cosmetic result. Genetic positivity to one or more of the breast cancer associated genes (BRCA1, BRCA2) is not an absolute contraindication to breast preservation, but many patients who are genetically positive and who develop DCIS seriously consider bilateral mastectomy. (Kuerer, 2010) b. Breast Conservation for PatientsShow MoreRelatedSymptoms And Treatment Of A Diabetic Patient With Cancer Patients913 Words à |à 4 PagesAccording to American Cancer society individuals with stage 1 CRC have a 90% five year survival rate with only 12% five-year survival rate with individual with stage 4 CRC. Stage 4 is defined as cancer that has metastasized to distant organs that many include the liver. Current treatment for CRC involves the use of surgery, chemotherapy as well as radiation. Generally surgery is considered first line treatment for CRC in which the affected portion of the colon is removed. Since hyperglycemia inRead MoreBreast Cancer : A Complex And Heterogeneous Disease Caused By Genetic Mutations782 Words à |à 4 PagesBreast cancer is a complex and heterogeneous disease caused by both genetic and non-genetic risk factors. These factors include, mutations in breast cancer-associated genes 1 and 2 (BRCA1 and BRCA2) [1]; loss or aberrant expression of the est rogen receptor (ER) [2]; human epidermal growth factor receptor (HER2) overexpression [3] ; lack of ER, progesterone receptor (PR), and epidermal growth factor receptor (EGFR) expression[4] ; high levels of receptor for the insulin-like growth factor receptorRead MoreShort Non Coding Rnas Play : The Rna And Represses The Translation Process By Controlling Gene Expression1559 Words à |à 7 PagesAbstract: MicroRNAs are short non-coding RNAs play main role in human diseases; it deregulates the RNA and represses the translation process by controlling gene expression. Some deregulated miRNAs express deferentially such as mir-125b, mir-145, mir-155, and mir-21 leads for partition between cancer and normal tissues. miRNAs expression with particular cancer biopathologic features in breast, such as tumor stage, estrogen and progesterone receptor expression, vascular invasion, or proliferation indexRead MorePssc Research Paper780 Words à |à 4 Pagesand Generation of Human Cardiomyocytes from iPSCs Slide 1-23 1500 words Advances in Application of iPSC-derived Cardiomyocytes for Future Medicine -Modeling Inherited cardiomyopathy with human iPSC-derived cardiomyocytes The advent of iPS cell technology and improvements in protocols for cardiomyocytes differentiation open the door to using iPSC-CMs platform for disease modeling and toxicological assays in various cardiovascular diseases. To data, one of the most successful area in research applicationRead MoreAnalysis Of Nigella Sativa And Its Effects On The Treatment Of Cancer3007 Words à |à 13 Pageseffects that help explain its medicinal properties. More recently, Nigella sativa and its major active compound, thymoquinone, have become an area of interest in the treatment of cancer. As one of the leading causes of death, cancer is a dreadful disease with no known cure and treatments with high toxicity and expense. In an effort to find drugs with lower levels of toxicity, scientists have turned to naturally occurring compounds, and Nigella sativa has shown great promise. Numerous studies haveRead MoreDevelopment Of The Mammary Gland9524 Words à |à 39 PagesIntroduction 1. Normal mammary gland 1.1 normal mammary gland anatomies The normal breast sits on the chest muscle, consisting mainly of adipose tissue, also known as mammary fat pad. The mature mammary gland is composed of 15-20 lobes, which are each composed of smaller structure called lobules. Tiny Lactiferous ducts connect lobules to each other. (Fig. 1b) (Schneider and Bocker). A typical structure of duct is composed of a hollow lumen, enclosed by a layer of epithelial luminal cells that produceRead MoreNew Therapeutic Strategies For Ovarian Cancer1902 Words à |à 8 Pagescancer is the fifth leading cause of cancer-related deaths in females in the United States. It is anticipated that there will be about 22,280 new cases and 14,240 deaths due to ovarian cancer in 2016 [70]. Most patients present with advanced stage disease, contributing to the high death rate. Generally, these patients are treated with surgical resection followed by platinum-based chemotherapy [71]. A significant problem faced in treating these patients is the high rate of recurre nce associated withRead MoreHuman Kallikrein Related Peptidases ( Klks )8953 Words à |à 36 PagesCancer is the second leading cause of death with 14 million new cases and 8.2 million cancer-related deaths worldwide in 2012. Despite the progress made in cancer therapies, neoplastic diseases are still a major therapeutic challenge notably because of intra- and inter-malignant tumor heterogeneity and adaptation/escape of malignant cells to/from treatment. New targeted therapies need to be developed to improve our medical arsenal and counter-act cancer progression. Human kallikrein-related peptidasesRead MoreEssay On 20 Years Of Advancement In Healthcare Science1109 Words à |à 5 PagesHealthcare Science and Potential Future Developments Over the last twenty years there have been numerous important advances throughout healthcare science. These have allowed for improved diagnoses and more effective treatments lowering the prevalence of diseases. The first significant advancement discussed in this essay is The Human Genome Project (HGP), an international collaborative research program whose goal was to sequence and map all of the genes (known as the genome) contained within humans. ThisRead MoreOvarian Cancer Case Study837 Words à |à 4 Pagesimmunohistochemistry in 37 samples, DICER showed a significant upregulation in high-grade serous ovarian cancer. High DICER expression was associated with absence of lymph node metastasis and a low proliferation index. DICER expression did not correlate with disease free or overall survival (16). The authors did not comment on DROSHA expression by immunohistochemistry and, thus, did not comment on the association of DROSHA with clinical factors. Additionally, only high-grade serous EOC tumor samples were examined
Friday, December 20, 2019
Technology Replacing Man - 3081 Words
Technology Replacing Man It seems that there is no escape from technology in the modern world. In 2014, all fields of expertise are rapidly being replaced by technology. From automated phones systems, to even jobs in engineering, it seems that the increase of technology is causing a high price for many individuals in the United States and around the world. The increased use of technology in businesses nationwide have caused a wide spread of elimination of many jobs. According to converge.org, ââ¬Å"Global unemployment has now reached its highest level since the great depression of the 1930s. More than 800 million human beings are now unemployed or underemployed in the world. That figure is likely to rise sharply between now and the turns of the century as millions of new entrants enter the workforce find themselves without jobsâ⬠. This number in expected to increase dramatically in the next decade. Technology is making advancements in areas of expertise, some of which one would least expect. One of th ese areas is agriculture. Converge.com tells its readers that ââ¬Å"New breakthroughs in the information and life sciences threaten to end much of outdoor farming by the middle decades of the coming century. The technological changes in the production of food are leading to a world without farmers, with untold consequences for the 2.4 million people who still rely on the land for their survivalâ⬠. Convege.org states that ââ¬Å"A new generation of sophisticated computer-driven robots mayShow MoreRelatedModern Technology1463 Words à |à 6 Pages The debate of modern technology is one that reaches out to almost everyone in the modern era living in the United States, since it is a first world country, everybody living in the country at one point has interacted with a piece of modern technology. The evolution of technology in the last two decades has been exponentially fast, changing evolution of almost an entire generation in the way that they view things and interact with the world around them. Things such as virtual reality haveRead MoreAnalysis Of Peace And By Schumacher Writes981 Words à |à 4 Pagesput them into groups and label them depending on their wealthiest. Schumacher mentions some of the false solution that the system come up with as a solution to it , for example, the system think that technology would be the solution to their problem, to save them from the disaster. Thinking technology would lead them to peace. But the people that in ââ¬Å"theirâ⬠category is only the wealthy type of people. Th ey are still thinking individually and not including the ââ¬Å"poorâ⬠people; they are being greedy onceRead MoreManagement Alternatives For Replacing Human Workforce Essay1511 Words à |à 7 PagesManagement Alternatives to Replacing Human Workforce Management Alternatives to Replacing Human Workforce Uta Batts Fayetteville Technical Community College BUS 137 0001 FA Principles of Management Prof. Ray Walters November 14, 2016 Management Alternatives to Replacing Human Workforce Abstract In todayââ¬â¢s workforce, there is a silent fear lurking amongst blue and white collar workers alike. There is a worldwide threat of machines beating people out of jobs that many have invested timeRead MoreTechnology Is A Good Thing?1475 Words à |à 6 PagesTechnology will eventually replace most of humansââ¬â¢ current jobs. When and how will that come about? Is this a good thing or a bad thing? The answer to the latter question is technology replacing humansââ¬â¢ current jobs is a good thing. Some might say that technology would mass produce goods by focusing only on quantity and not quality. While that argument does have some merit, thereââ¬â¢s no denying the many more ways technology can better the world. Technology replacing human beings is a good thing becauseRead MoreThe Chinese Communist Revolution Was A Negative Impact On The Political And Economic Development Of China1393 Words à |à 6 PagesCommunist Revolution had both a negative and positive impact on the social development of China. In 100 C.E the women were controlled by their husbands. If the wife was unworthy to her husband, it was considered unnatural. The relationship between the man and woman was said to be destroyed and neglected (Document 7). In current communist china, the woman are given more opportunities to achieve their dreams and get equal rights they deserve. These rights include the same jobs that are available to menRead MoreThe Music Of Today s Generation1257 Words à |à 6 Pagestheir songs take you to a different time and place. You may perhaps close your eyes and envision yourself on the ship they sang about or feel the breaking heart of the man having to leave his love behind. They also sang about the turning of age and technology, how machines are helping man, but in return dehumanizing mankind and replacing them in the workforce. When I am attending a concert, there are certain criteria that I look for to determine if it was an excellent concert. Not only the music needsRead MoreThe Future Of Artificial Intelligence ( Ai )1572 Words à |à 7 Pages Jie Shi Liew LING 102 Mr Kevin Hensold-Speir November 11, 2016 What is the Future of Artificial Intelligence (AI)? A Prediction of Killer Robots Era While human are benefiting much from our 21st century Information Technology Revolution, technology revolution such as creation of robotics could be a disaster to our human race rather than a blessing. According to the world economic forum (Torkington, 2016), there are high potential of AI, robotics, nanotechnology and other socio-economicRead MoreAmerican Workers Are More Beneficial And Cost Efficient Than Machinery774 Words à |à 4 PagesMany American workers are at risk of losing their jobs to man-made machinery. One author, Adam Davidson,wrote ââ¬Å"Making It in America,â⬠and he argues that American workers are more beneficial and cost efficient than machinery. He uses his interview with Standard Motor Products employee, Maddie Parlier, to build his argument. Maddie is a low educated worker who was forced to take the job at SMP when she became pregnant her senior year of high school. Though she was quick and effective working the laser-weldingRead MoreMarketi ng Challenges1099 Words à |à 5 Pagesconsumer marketplace is known as the share economy. This paper will discuss how this new concept of the share economy has had an effect on the traditional economy and whether the shared economy is creating new value for the consumer or if it is just replacing existing business. The share economy concept involves individuals renting out their physical assets. For example, an individual who is looking to increase their monthly income has the option to increase their income by renting out their home. AnotherRead MoreA Thing Like Me, By Nicholas Carr1278 Words à |à 6 PagesTechnology Destroyed a World We Will Never See Technology, the advancement of knowledge and productivity through the application of tools, information, and techniques to create an effortless process, has ultimately lead to the declination of our society and our future. In ââ¬Å"A Thing Like Me,â⬠Nicholas Carr addresses the development of technology from the day it was created and how it initiated an immediate impact within the lives of humans leading to an unhealthy dependency. Carr establishes how technology
Thursday, December 12, 2019
Description about Human Resource Management Practices
Question: Describe about the Human Resource Management Practices for Performance in Organisations. Answer: Literature Review The literature review is based on Human Resource Management practices for employees performance in Wesfarmers. Jiang et al., (2014) stated that Human Resource Management (HRM) refers to the policies as well as practices which are involved in carrying the human resources. This particular literature review reflects on some of the factors of HRM practices that assist in effecting the performance of the workers. The factors are recruitment and selection, compensation, performance appraisal and training (Rae, Sands Gadenne, 2015). These factors are vital for improving the performance of the employees within the organization to meet with organizational goals of Wesfarmers. Recruitment and Selection of Employees Kehoe and Wright (2013) stated that the HRM system consists of division of labour as well as specific jobs. In such a system, limited number of employee contribution exists. The employees policy specifies comprehensive rules concern progression of profession as well as compensation. Buller and McEvoy (2012) opined that recruitment and selection gives high retention to the employees. The objective of the professional recruitment strategy is to magnetize the right number of trained applicants as well as strengthen company brand within the labour marketplace. The recruitment and selection strategies should be resolute after job analysis highlights the necessary skills as well as abilities. Bratton and Gold (2012) argued that for the external recruitment of Wesfarmers, advertising media such as print, social media are to be considered. The major trends within recruitment are use of technology, development of HR responsibilities, recruitment in business and outsourcing of recruitment agen cies. Moscardo et al, (2013) opined that recruitment as well as selection fits in to add value to the HR procedures. The recruitment process is defined as the capability of the organization in order to supply new employees, remain the organization operating as well as improving the quality of human capital. The quality of process of recruitment is major driver for happiness of the managers with the services offered by the human resources. Robbins et al., (2013) stated that goal of this process is to locate the best recruitment sources, hiring process and keep the organization competitive within the marketplace. The recruitment procedure of Wesfarmers requires a strong sustain by enthusiastic recruitment software solution. Buller and McEvoy (2012) argued that many of the vendors offer various recruitment software solutions; therefore the organization requires choosing the right solution in order to meet the organizational goals. Compensations and benefits of the employees McCauley et al., (2013) stated that the researcher is searching for the factors that would affect the performance of the employee. Purce (2014) argued that one of the best ways for production of the Wesfarmers is reward package for the employees. This compensation strategy enables the economic manpower in order to maximize income in return of great effort (Bratton Gold, 2012). It also attempts to employee motivation with productivity as well as output of the organization. Intrinsic paybacks in terms of rewards as well as compensation enhance the performance of the employees to some degree. Kehoe and Wright (2013) stated that the employees are motivated when they are given monetary rewards directly for their presentation. Antonioli, Mancinelli and Mazzanti (2013) investigated that there is a positive association between compensation as well as work performance. Bratton and Gold (2012) argued that sometimes, there arises a gender differences in pay raises such as women receive higher pay than men. One of the reasons is reduced stereotyping. Antonioli, Mancinelli and Mazzanti (2013) suggested that worn has lower base pay and increase in higher pay is due to difference in amount of information available to the decision markers. Purce (2014) argued that when managers have limited information, then it tends to make stereotypical judgements. Equity theory of motivation asserts that the employee is equally treated in the organization. This theory is based on the idea that the individuals are motivated by fairness. Shields et al., (2015) suggested that higher is the individuals perception of equity, the employees are more motivated, and if it is vice versa, then they are de-motivated. Equity theory is totally based on principle that the employees should put forth a particular employment of effort that they feel contrasts fairly to the financial rew ards that they obtain. Performance appraisal of the employees Baskerville and Wood-Harper (2016) investigated that employees are developing positive attitudes when they receive high favourable outcomes. The level of financial rewards such as amount of pay that the employees receive is found to be pessimistically related to their income levels. The social rewards give a positive influence of the job performance. Buller and McEvoy (2012) opined that the management should implement a control system which should reduce cost of labour by increasing performance standards as well as maintenance of wages. Resistance in form of strikes, high rate of grievance are found to be costly for the firm in terms of productivity as well as quality. The companies are influencing the employees perception of fairness as well as pay their employees by developing a reward strategy (Antonioli, Mancinelli Mazzanti, 2013). Rensis Likerts Participative Decision Making Theory is used by the organization so that they can demonstrate the effect of the HRM on the employees pe rformance (Kehoe Wright, 2013). The employees should participate into decision making process so that they can take important decisions regarding any important situations. Wesfarmers performance appraisal considers the goals of the appraisal system such as to improve the productivity, improvement of personnel decisions such as promotion, change of job. Bratton and Gold (2012) opined that in order to develop the appraisal of system for the organization, an entrepreneur is required to consider size of their employees, goals of company, measure performance, increase in pay, communication of appraisal system as well as performance planning. Need theory complements on the statement that in which outcomes motivate people in order to contribute valuable inputs to the job as well as perform at high levels. Robbins et al., (2013) suggested that using this theory, the organizational management should motivate the employees to fulfil their needs and wants. Training of the employees According to Baskerville and Wood-Harper (2016), training can influence the performance of the employees by improving their skills, knowledge as well as development in abilities to do task. The findings of the author reveal that the training plan influences the commitment of the organization, knowledge of participants as well as organization based self-esteem. Jiang et al., (2012) indicated that the training influences the performance of the managers as well as employees. Similarly, Purce (2014) found that training program raises the employee morale as well as increases their overall performance. This program allows the employees in order to acquire greater competencies which are required in order to perform jobs effectively as well as accurately as per the organizational requirements. Antonioli, Mancinelli and Mazzanti (2013) opined that training is given four basic grounds for the new candidates such as it familiarizes to the mission, vision, rules as well as regulations of the company. The existing employees are trained in order to enhance the knowledge. It also takes place when there is requirement for any amendments; it comes up with the changes. Finally, when career growth becomes important for the organization, then training should be given so that the employees prepare to share their responsibilities of higher level job. Shields et al., (2015) argued that due to importance of training program, a trainer can encounter resistance from both employees as well as managers. In order to successfully develop training as well as development program of the organization, the management should provide a job description upon which the activities of employee training is built. Training is mainly provided to meet with basic competencies of the job, and it is to be done by the supervisor. Research Methodology Research Philosophy While conducting a research, the research philosophy deals with the nature as well as development of knowledge. Collection of secondary data and engaged into the data analysis in order to reply to the research questions helps in creation of new knowledge (Baskerville Wood-Harper, 2016). In order to address research philosophy in the study involves in awareness as well as formulating of assumptions (O'Leary, 2013). There are three philosophies that are used such as positivism, realism and interpretivism. For this particular study, interpretivism is to be chosen as a research philosophy as this work depends on optional information gathering and this strategy is the best to check the experiences and the background of Wesfarmers. The secondary information ought to be gathered effectively with utilizing this theory (Buller McEvoy, 2012). Aside from this, the mistakes in the information investigation are likewise moderated effectively. Research Approach There are two types of research approach for this study such as deductive and inductive approach. In this particular research study, inductive approach is used. It starts with the research questions, aims as well as objectives that are required to achieve during the research process. It is considered as perfect for this study as it relates the examination point with research questions and it helps the examiner to do useful investigation with the gathered information. Research Design Ritchie et al., (2013) stated that this is the design which structure the scientific work for the study. It also gives direction of the research. The method which is chosen to do the data analysis will affect the results as well as concludes on the findings of the research. Most of the researchers are interested in getting the result through reliable observations which help them to understand the research topic as well as research questions. It is the course of action of the conditions to gather the information investigation of the information in such a methodology such, to the point that it expects to consolidate centrality to the motivation behind examination with the theoretical framework in the process (O'Leary, 2013). Mainly, there are three types of research design processes such as exploratory, explanatory as well as descriptive. In this particular study, descriptive research design is perfect as it helps to conclude the findings of the study. Utilization of this examination outline empowers to pick up data on the qualities of the specific individual to do the basic business work (Baskerville Wood-Harper, 2016). Through use of this specific examination plan, distinctive task variables are cleared and justifiable. Data collection procedure and methods Data collection procedure Mainly, there are two kinds of data collection procedures like quantitative and in addition qualitative methodology. The quantitative methodology includes the gathering of information that is putting the examination in formal too rigid technique. The qualitative methodology depends on the techniques for subjective assessment of suppositions and additionally states of mind (Ritchie et al., 2013). Utilizing this approach, the investigator can do inside and out examination on the exploration point and do analysis on the gathering data from publicly available sources like case studies of Wesfarmers, websites of the company and many others. In this specific exploration concentrate on, the information is dissected utilizing the subjective information accumulation methodology to comprehend the HRM practices for employees performance in Wesfarmers. Data collection method In this particular study, secondary data collection method is used. The data are collected by means in order to overcome with difficulties to gain access to the managers with a sample group those have approaches pertaining to the research questions. The data for the secondary data are collected from the publicly available sources like case studies of Wesfarmers, websites of the company, press articles, financial reports of the company, journals, published interviews and news releases. Ritchie et al., (2013) identified some of the benefits of the secondary data collection method are much of the data are available within public domain. Due to selection of public cases on the company, the cases ensure the validity of the data as well as findings. As the data are open to the public scrutiny, therefore they are of high standard (O'Leary, 2013). It is the skill of the experts that the annual reports of the company are offered of high quality which gives high-quality HRM strategies of the c ompany. References Antonioli, D., Mancinelli, S., Mazzanti, M. (2013). Is environmental innovation embedded within high-performance organisational changes? The role of human resource management and complementarity in green business strategies.Research Policy,42(4), 975-988. Baskerville, R. L., Wood-Harper, A. T. (2016). A critical perspective on action research as a method for information systems research. InEnacting Research Methods in Information Systems: Volume 2(pp. 169-190). Springer International Publishing. Bratton, J., Gold, J. (2012).Human resource management: theory and practice. Palgrave Macmillan. Buller, P. F., McEvoy, G. M. (2012). Strategy, human resource management and performance: Sharpening line of sight.Human resource management review,22(1), 43-56. Jiang, K., Lepak, D. P., Han, K., Hong, Y., Kim, A., Winkler, A. L. (2012). Clarifying the construct of human resource systems: Relating human resource management to employee performance.Human Resource Management Review,22(2), 73-85. Jiang, K., Lepak, D. P., Hu, J., Baer, J. C. (2012). How does human resource management influence organizational outcomes? A meta-analytic investigation of mediating mechanisms.Academy of management Journal,55(6), 1264-1294. Kehoe, R. R., Wright, P. M. (2013). The impact of high-performance human resource practices on employees attitudes and behaviors.Journal of management,39(2), 366-391. McCauley, C. D., Derue, D. S., Yost, P. R., Taylor, S. (2013).Experience-driven leader development: Models, tools, best practices, and advice for on-the-job development. John Wiley Sons. Moscardo, G., Lamberton, G., Wells, G., Fallon, W., Lawn, P., Rowe, A., ... Renouf, M. (2013).Sustainability in Australian business: Principles and practice. Wiley-Blackwell. O'Leary, Z. (2013).The essential guide to doing your research project. Sage. Purce, J. (2014). The impact of corporate strategy on human resource management.New Perspectives on Human Resource Management (Routledge Revivals),67. Rae, K., Sands, J., Gadenne, D. L. (2015). Associations between organisations motivated workforce and environmental performance.Journal of Accounting Organizational Change,11(3), 384-405. Ritchie, J., Lewis, J., Nicholls, C. M., Ormston, R. (Eds.). (2013).Qualitative research practice: A guide for social science students and researchers. Sage. Robbins, S., De Cenzo, D., Coulter, M., Woods, M. (2013).Management: the essentials. Pearson Higher Education AU. Shields, J., Brown, M., Kaine, S., Dolle-Samuel, C., North-Samardzic, A., McLean, P., ... Plimmer, G. (2015).Managing Employee Performance Reward: Concepts, Practices, Strategies. Cambridge University Press.
Wednesday, December 4, 2019
An Analysis on a Mcdonalds Advertisement Essay Example For Students
An Analysis on a Mcdonalds Advertisement Essay Analysis on the McDonalds advertisement We have recently been studying the McDonalds advertisement where they have stated that they are helping Aussie families and the future sports stars of tomorrow. They tell us that they are hand in hand with Australian families, but they only say that because they want more families to go to their local McDonalds store. But are they really helping the sports stars. Yes of course they are but they arenââ¬â¢t really helping out as much as they say. Yeah they do sponsor teams but really I am sure that they only do it for the advertisement on the jerseys. Did you notice that after most sports game most coaches have a McDonalds voucher to give out. That is another way how McDonalds thinks that they are helping young sports stars; by giving these vouchers out they are encouraging the young participants but they are also showing them the way to unhealthy food. This makes them work harder just so they can get McDonalds. They use informal and colloquial language to persuade people of various communities to go and buy this unhealthy food so they can support their sons/daughters/relatives or really anyone that is participating in sport, so that they can support their dreams and their goals for their future goals. Also because they want to make sure that these kids can have a proper life, not one that is totally messed up because no one was there to help them reach their dreams and goals. They believe that they are giving something back to the community by helping the young stars of tomorrow. They figure that by helping people think that they are doing the right thing but really they are leading the children down the path of unhealthy food which may end up leading to being obese or even having diabetes which isnââ¬â¢t a good life for anyone. I am sure that you wouldnââ¬â¢t want to be a young adult with diabetes, obese or have a serious heart condition. I am sure that the answer to that is no. I think that the McDonalds advertisement team should really think about what they are leading people to before they publish any real advertisement in the future.
Thursday, November 28, 2019
Admission_Essay an Example of the Topic Admissions by
Admission Essay When I look back at my college days and reminisce the times when academic requirements are piling up at my study table, I can't help but give myself a pat at the back for a job well done. Having to keep up with exams week is no easy feat and being a student is a lot hard. Now that I already am a professional, I thought my passion for knowledge is long gone. I have with me the skills i need to land a decent job. However, working for an engineer consulting firm that designs irrigation and draining networks and does researches for water resource has fanned my dying passion for knowledge. There is much to learn once you open your eyes to possibilities. Need essay sample on "Admission Essay" topic? We will write a custom essay sample specifically for you Proceed Perhaps the most important thing that I learned while working at the firm is that there is much to be done for the safety of the workers who do the rigorous jobs at the construction sites. For the last eight months I have also served at a construction company as a coordinator which enabled me to fully understand the need for health safety in industrial sites. It is their health that is compromised in every job that they do. Since man is the most valuable resource, it is deemed significant that we take care of that resource for the benefit of both the workers and the company. It is for the well being of both parties that we need to protect. This has fueled my passion to pursue Master of Science in Industrial Hygiene. This serves as my primary motivation for applying in this university. Since my bachelors degree is in the field of agronomy and plant breeding, I have come to realize the importance of the environment for everyone. Now that our planet is in the verge of environment degradation, this has further amplified my interest in taking care of the environment and the people who live in it. This interest takes anchor on the fact that even the field of agriculture also does harm to the environment and the people, thus, damaging the health humans as well as animals. Furthermore, I want to capitalize on my interest and my newly found passion for me to explore other fields of study. It is of my understanding that gaining knowledge is a process that goes way beyond college graduation. It is a life long quest that I would daringly take for the pursuit of knowledge itself. I aim to further polish my skills as a professional and be adept with Industrial Hygiene for in reality, we do not lose our passion for knowledge. We learn new things each day. There is much to learn in the real world, but more often than not we have to equip ourselves with proper tools for us to be more effective in what we do. I look forward to hone my knowledge in this university. The will dare to face the challenges of the academe once more for the purpose of enriching my knowledge. Learn more: What makes you the right candidate?Admission EssayCase of Exxon Mobil vs EPA References Quintcareers. (2007). Writing the Successful College Application Essay. Date retrieved November 7, 2007. http://www.quintcareers.com/college_application_essay.html
Sunday, November 24, 2019
Fiscal Policy in the US essays
Fiscal Policy in the US essays Real plans for real people. This was the coined theme for the Bush campaign back in September. As far as I can see with his tax cut plan in doesnt involve real people. It may just depend on your definition of the term, but the real people of America are the middle class, hard working families. Bushs tax plan is now said to be $1.6 trillion over a ten year period of time. Most of this money will go to the upper brackets, the better off. Granted they do pay the most money, but then when you think about it, why do they need the cut? Can they not afford to pay their taxes? In this economic time of a feared recession our government should be doing everything in their power to avoid this situation. Having a prolonged tax cut does nothing to help the economy now. By the time the money is given back we and more than likely to have already succeeded this economic down low. The economist will tell you the in order to dodge this the money must be given back now. If the money is given back earlier there is a better chance of people spending it and stimulating economic activity. When looked at by this point of view I most definitely agree with Laura DAndrea Tyson when she said, Bush wants a large tax cut for political reasons, not economic ones. When Robert J. Barro discuses how he thinks the tax cut will stimulate investment and growth, increase incentives to work and save, and lower the amount of money Congress can spend, I find myself disagreeing with him. As said earlier Bushs tax cut will do very little, if anything, to help stimulate growth. Ten years is a very long time. As for increasing the incentive to work and save, I find it hard to want to save my money when they take it away for taxes. If you want to give an incentive to save, why not turn to VATs instead of income taxes? I know this would be an almos ...
Thursday, November 21, 2019
ASSIGN2_SMT Coursework Example | Topics and Well Written Essays - 500 words
ASSIGN2_SMT - Coursework Example es out by the soilââ¬â¢s own weight, new sediment fails to replenish the loss casing a loss of 4 feet of land at the mouth of Mississippi every 100 years. 8. Thousands of miles of web like navigation canals are responsible for destroying 10% to 30% of the marshes. These canals are also responsible for an unknown percent of land loss because they cut off marshes from natural water flow, opening them up to salt water intrusion and erosion. 9. Salt water from the Gulf moves inland through canals and waterways killing fresh water plants that canââ¬â¢t stand the salt. As the plants die, the soil their roots hold together is eroded away, destroying marshes and wetlands. 12. From 1932 to 2000, Louisiana lost nearly 2,000 square miles of land bringing Gulf of Mexico near to the residentââ¬â¢s backyards. If nothing is done to stop the current situation, geologists predict an additional 7,000 miles of land could disappear by 2020. 13. New Orleans should not be built again. The coast line of New Orleans is very dangerous and it will soon be destroyed again because the city is protected by the levees which contribute to land loss. 21. Hurricane Katrina occurred because some levees in New Orleans were replaced with walls approximately 2 feet thick to widen the canal which fell during the hurricane (Hurricane Katrina Relief, 2010). 22. The nature or Hurricane Katrina changed dramatically from 28 to 29 August. Studies suggest that this change in nature from tropical storm to a category 5 and then back to category 3, is directly associated with the land fall in Louisiana (Richard D. Knabb, 2005). 25. It is said the damage done by Hurricane Katrina could have been avoided. The state was aware of the intensity of the hurricane and should have taken measures to avoid the death of 1,300 people. It is said that the military lacked cooperation with the Homeland Security and other relief agencies (Fox news, 2006). 26. It is not possible to prove that global warming caused Hurricane
Wednesday, November 20, 2019
Israel, Iraq and the USA in Middle East Politics Analysis Essay
Israel, Iraq and the USA in Middle East Politics Analysis - Essay Example Religious issues have also been a constant cause of conflict in these regionsâ⬠.1 These problems of the region do not originate solely from the Middle East countries alone, as external interventions have contributed largely in the past and prevailing affairs in the region. These intervening outsiders do interject because of vested interest in the oil sources. Interventions of countries like the United States of America and Russia among others have led to the unending squabble and unrest in the region. In most cases, the intruders could easily set the Arabs up in arms as regions like in Israel had internal religious disparities between Christians and Arabs/Muslim. Focusing on middle East and the US relation, this paper will not only seek to unravel the relationship between these three countries, but will also deliberate on their contribution to the politics of the middle east. The Middle East has for a long time now suffered from Socio-economic and political problems. The problems in this region blossoms from the citizens of the region, as well as other countries. The interventions have both exacerbated uprisings, and led to loss of millions of lives in wars and unrest. Other than the resources that entice external countries, terrorist groups that thrive in the Middle East have attracted global attention as countries join hands in fighting terrorism. The mere mention of the word terrorist instills fear to any country or individual, as many countries have experienced terrorist attacks in the past. The relationship between Iraq, Israel and USA emanate from either of those connecting factors. Iraq Iraq has been for a long time pivotal in shaping of the Middle East politics. Other than the recently known invasion by the United States of America, Iraq has experienced decades of political and social economic issues. Baker, Shareen and Ismael3 demonstrates clearly and precisely the events of the American invasion in detail. They analytically reveal the causes of the invasion, the economic, social and political factors that are wrapped around the history of Iraq. The most empirical purpose or invasion of Iraq by the US militia emanated from the belief that Iraq was a terrorist country, a factor that led to the invasion in the attempts to wipe out terrorism completely both in Iraq and other targeted nations. All middle east countries that were suspected to condone the development of terrorist groups. This invasion, religious fanaticism and the long time conflicts with the neighbouring countries acted as pivotal determinant factors concerning the countryââ¬â¢s political stature and its effects in the region.i Before and after t he cold war, America and the Russian governments sought to control the oil and water sources in the Middle East. These resources became an issue of conflict in the region leading to numerous political upheavals. Since the times of imperialism, America had convinced Muslims to adopt secular methods of governance and legal systems in order for modernization to take place in the Middle East. Reforms to the former Sharia government and legal systems became a fundamental issue when the secular methods failed (Cleveland and Marti). These reforms led to lengthy political squabbles for many years to the present time. Israeli also played a major role in the politics of Iraq as its neighbor and the fact that Israel collaborated with the Americans in the Anti-Arab movements. This relationship connects the three countries in a
Monday, November 18, 2019
Information Security Physical Security models Essay
Information Security Physical Security models - Essay Example It achieves this by describing steps followed to achieve security goals of an institution. Security models are great tools in evaluating the security in place. Gregory (2010) outlines information various security models that have been developed such as the following: The Bell-LaPadula model is evidently a notable achievement in computer security. Several other models followed suit, with either improvements on their predecessors or variations. The Harrison-Ruzzo-Ullman (HRU) is an example of a general model in comparison to the Bell-LaPadula model which captured confidentiality aspects of access control. There emerged other models such as Chinese Wall model, the Biba and Clark-Wilson models that were more integrity based as well as the Information flow and non-interference models that centered on perfection. All these models were developed to safeguard information and information systems from leakages, unauthorized access and rights violation. However, the above models are more software based rather than physical. Threats to physical security involve disruption of services, theft, malicious physical damage, unlawful leakage and loss of system reliability. In any case, however, similar to general information security, physical security calls for a layered defense model. A layered security model will emanate from the perimeter and zero in on the asset; in this case, information. Layered security models will serve to achieve: deterrence, delaying, detection, assessment and response in a bid to fulfill the security objective. A physical security model must, therefore, be able to address the above threats efficiently and comprehensively. According to the US Army Field Manual 3-19.30 (2001, January 8) physical security is that part of physical measures designed to ensure the safety of personnel; to thwart unlawful access to equipment, the installations
Friday, November 15, 2019
People Donating To Charity Health And Social Care Essay
People Donating To Charity Health And Social Care Essay There is varied outlook among people about donating to charity. This research is focused on understanding peoples attitudes towards donating for charity. An attitude questionnaire was prepared and surveyed among people. Simple percentage analysis was used to study the survey results to research on attitude difference among people of different age group, gender and environment. Also, their personal opinion about charity, charity channel and preference of charity organization was collected and studied. Results were produced in graphical and tabular forms and it is observed that people in the age group above 35 are more likely to donate than younger generation, women are more interested to donate than men, many people prefer to donate in person rather than donating online and some people are least interested to donate because of their ignorance about charity organisations. With Malice toward none, with charity for all, with firmness in the right, as God gives us to see the right, let us strive on to finish the work we are in, to bind up the nations wounds. [5] -Abraham Lincoln The research is mainly focused to find out what people think about charity and to understand the reason why many people donate for charity as well as why many people do not donate to charity. Different Charity attitude among different age group, gender and location is studied in this research to make judgements about charity awareness among people. Preference about charity channel is studied to understand which channel has reached many people and which channel is weak in promotion. The research conducted by www.ageuk.org.uk[4] supporting aged people states that 10.3 million people in the UK are 65 and over, and this is set to rise to over 16.4 million by 2033.They say the cause might be due to hearing loss, dementia and incontinence. They are striving hard to help people to be medically fit. They request people to support their research by funding and other research works which are related to age related illness. Volunteering is also a part because he/she is contributing a help even though the person could not contribute financially. It could be administrative work, arranging a stall or helping people in the way they feel like without profit except for the love with their heart and soul. There are much more related to charity for the people who couldnt support themselves either by their family or relatives. The list goes on whether it is a disease, environmental funding, disaster or which is affecting the people lives. Assessment of analysis showed that majority of the people have donated for charity at least once whereas less than 35% of the people have not donated yet due to various reasons. The results also stated that main reasons provided by the particular age group for not donating to charity includes being a student, laziness, did not start earning and so on. Also many have mentioned that they are not aware of the procedure in making donation to charity. This study also examined that majority of the people are interested in donating for aged , child youth and disabled sectors than other part of the charity sectors. The survey also showed the results crossed with gender and crossed with age along with general statistics. And also shows the channel that most of the people prefer for donating to charity and how frequently they do. Literature Review NCVO (National Council for Voluntary Organisations) and CAF (Charity Aided Foundation) jointly conducted an analysis in December 2010[3] UK Giving 2010 An overview of charitable giving in the UK, 2009/10 which states that the proportion of adults in the UK giving to charity increased by 2% and reached 56% which was 54% in 2008/09 and the same UK giving 2011 conducted on December 2011[2] states that it increased to 2% more and reached 58% in 2010/11. Methodology Online survey method has been followed in gathering the results. A list of questionnaire mentioned below has been prepared and online survey has been designed with the help of quicksurveys.com and the survey link has been promoted through Facebook for collecting the results. Online survey link: http://tolu.na/VWLdXK The results were analysed using simple statistical method. Percentage analysis method is used to convert the answers into statistics. C:UsersSureishDesktopPDRMimagesPicture2.png Figure : Methodology Flow Diagram List of questionnaire Have you ever donated to charity? Any reason for not donating to charity? How long have you been donating for charity? Through what channel you will make the donation? To which charity category you have donated? (Select at least one) Do you regularly donate to a charity? Enter the name of the Charity you have donated (At-least one) Any reason in donating for Charity? How often do you donate for charity? Findings Charity Donation Behaviour General Statistics Below table and graphs shows the general statistics on whether people have donated for charity (Yes/No) Total Respondents: 41 Result Total (%) Count Yes 65.85% 27 No 34.15% 14 Table : Charity Donation Behaviour General Statistics Graph : Charity Donation Behaviour General Statistics Charity Donation Behaviour Crossed with: Gender Below table and graphs shows the statistics on whether people have donated for charity (Yes/No Crossed with: Gender) Total Respondents: 41 Result Total (% ) Count Male 100% (31) Female 100% (9) Yes 67.5% 27 64.52% 20 77.78% 7 No 32.5% 14 35.48% 12 22.22% 2 Table : Charity Donation Behaviour Crossed with: Gender Graph : Charity Donation Behaviour Crossed with: Gender Charity Donation Behaviour Crossed with: Age Below table and graphs shows the statistics on whether people have donated for charity (Yes/No Crossed with: Gender) Total Respondents: 41 Result Total (%) Count 18 34 100% (33) 35 54 100% (6) 55 + 100% (1) Yes 67.5% 27 60.61% 20 100% 6 100% 1 No 32.5% 14 39.39% 14 0% 0 0% 0 Table : Charity Donation Behaviour Crossed with: Age Graph : Charity Donation Behaviour Crossed with: Age Donation Frequency General Statistics Below table and graphs shows the general statistics on how often people donate for charity Total Respondents: 27 Result Total (% ) Count Weekly 0% 0 Bi Weekly 0% 0 Monthly 37.04% 10 Bi Monthly 3.7% 1 Quarterly 11.11% 3 Half-Yearly 7.41% 2 Annually 22.22% 6 Rarely 18.52% 5 Table : Donation Frequency General Statistics Graph : Donation Frequency General Statistics Channel used General Statistics Below table and graphs shows the general statistics on the major channels through which donations are made. Total Respondents: 27 Channel Total (%) Count Charity Website 18.52% 5 In Person 66.67% 18 Social Networking (like Facebook) 3.7% 1 Other, please specify 11.11% 3 Table : Channel used General Statistics Graph : Channel used General Statistics Other includes Volunteering work NGO or in person shops Charity Sector General Statistics Below table and graph shows the general statistics to which charity sector people shows more interest in donating. Charity Sector Total (%) Count Aged 51.85% 14 Animals 11.11% 3 Armed Ex-Services 3.7% 1 Children Youth 59.26% 16 Community 0% 0 Culture Heritage 0% 0 Disabled 48.15% 13 Education Training 18.52% 5 Employment, Trades Professions 0% 0 Environment 11.11% 3 Family 0% 0 Health 25.93% 7 Hearing Impairments 7.41% 2 Hospices 3.7% 1 Hospitals 7.41% 2 Housing 0% 0 Human Rights 11.11% 3 Learning Disabilities SEN 3.7% 1 Medical Research 18.52% 5 Medical Welfare 14.81% 4 Mental Health 7.41% 2 Overseas Aid 7.41% 2 Religious 14.81% 4 Rescue Services 3.7% 1 Social Welfare 7.41% 2 Sport Recreation 0% 0 Visual Impairments 3.7% 1 Other, please specify 3.7% 1 Total Respondents: 27 Table : Charity Sector General Statistics Graph : Charity Sector General Statistics Charity Sector Crossed with: Gender Below table and graph shows to which charity sector people shows more interest in making donations (Crossed with: Gender). Category Total (% ) Count Male 100% (20) Female 100% (7) Aged 51.85% 14 45% 9 71.43% 5 Animals 11.11% 3 5% 1 28.57% 2 Armed Ex-Services 3.7% 1 0% 0 14.29% 1 Children Youth 59.26% 16 55% 11 71.43% 5 Community 0% 0 0% 0 0% 0 Culture Heritage 0% 0 0% 0 0% 0 Disabled 48.15% 13 50% 10 42.86% 3 Education Training 18.52% 5 20% 4 14.29% 1 Employment, Trades Professions 0% 0 0% 0 0% 0 Environment 11.11% 3 15% 3 0% 0 Family 0% 0 0% 0 0% 0 Health 25.93% 7 30% 6 14.29% 1 Hearing Impairments 7.41% 2 10% 2 0% 0 Hospices 3.7% 1 0% 0 14.29% 1 Hospitals 7.41% 2 5% 1 14.29% 1 Housing 0% 0 0% 0 0% 0 Human Rights 11.11% 3 15% 3 0% 0 Learning Disabilities SEN 3.7% 1 5% 1 0% 0 Medical Research 18.52% 5 15% 3 28.57% 2 Medical Welfare 14.81% 4 10% 2 28.57% 2 Mental Health 7.41% 2 10% 2 0% 0 Overseas Aid 7.41% 2 10% 2 0% 0 Religious 14.81% 4 20% 4 0% 0 Rescue Services 3.7% 1 5% 1 0% 0 Social Welfare 7.41% 2 5% 1 14.29% 1 Sport Recreation 0% 0 0% 0 0% 0 Visual Impairments 3.7% 1 5% 1 0% 0 Other 3.7% 1 0% 0 14.29% 1 Total Respondents: 27 Table : Charity Sector Crossed with: Gender Graph : Charity Sector Crossed with: Gender Charity Sector Crossed With: Age Below table and graph shows to which charity sector people shows more interest in making donations (Crossed With: Age). Total Respondents: 27 Charity Sector Total (% freq col) 100% (27) 18 34 100% (20) 35 54 100% (6) 55 + 100% (1) Aged 51.85% 14 65% 13 16.67% 1 0% 0 Animals 11.11% 3 10% 2 16.67% 1 0% 0 Armed Ex-Services 3.7% 1 5% 1 0% 0 0% 0 Children Youth 59.26% 16 60% 12 66.67% 4 0% 0 Community 0% 0 0% 0 0% 0 0% 0 Culture Heritage 0% 0 0% 0 0% 0 0% 0 Disabled 48.15% 13 50% 10 50% 3 0% 0 Education Training 18.52% 5 20% 4 16.67% 1 0% 0 Employment, Trades Professions 0% 0 0% 0 0% 0 0% 0 Environment 11.11% 3 5% 1 33.33% 2 0% 0 Family 0% 0 0% 0 0% 0 0% 0 Health 25.93% 7 20% 4 50% 3 0% 0 Hearing Impairments 7.41% 2 0% 0 16.67% 1 100% 1 Hospices 3.7% 1 5% 1 0% 0 0% 0 Hospitals 7.41% 2 10% 2 0% 0 0% 0 Housing 0% 0 0% 0 0% 0 0% 0 Human Rights 11.11% 3 5% 1 33.33% 2 0% 0 Learning Disabilities SEN 3.7% 1 0% 0 16.67% 1 0% 0 Medical Research 18.52% 5 10% 2 50% 3 0% 0 Medical Welfare 14.81% 4 15% 3 16.67% 1 0% 0 Mental Health 7.41% 2 10% 2 0% 0 0% 0 Overseas Aid 7.41% 2 5% 1 16.67% 1 0% 0 Religious 14.81% 4 5% 1 50% 3 0% 0 Rescue Services 3.7% 1 5% 1 0% 0 0% 0 Social Welfare 7.41% 2 5% 1 16.67% 1 0% 0 Sport Recreation 0% 0 0% 0 0% 0 0% 0 Visual Impairments 3.7% 1 0% 0 16.67% 1 0% 0 Other 3.7% 1 5% 1 0% 0 0% 0 Table : Charity Sector Crossed with: Gender Graph : Charity Sector Crossed with: Gender Survey Result -Reason for donating We live a good life, so some money can get to people who have nothing. People have to help each other if government is not capable. To Help. Can claim back on tax. To help thalassemia children. Mainly when feeling generous, but if its for something like the Poppy Appeal or Help for Heroes its because I strongly believe in their causes and know the money does reach the soldiers. To help fellow beings. I find happiness in helping the needy. Poor children education. Survey Result -Reason for not donating Dont know. Laziness I guess. But I have the desire to donate. Till now I didnt have any opportunity to donate meant that I didnt get any information to donate but am keen interested in that and we have organised a camp like taking the orphanage students to kishkintha which is a theme park in Chennai and our teams name is vizhigal. I have recently started working. Being a student I dont have cash to donate. Didnt get a chance. I am not getting enough income to donate to charity. Not yet came across a chance to do. Conclusion Looking at the results more than 65% of the people shows interest in donating to charity at least once and less than 35% havent donated due to various reasons mentioned above. The research also concluded that the people with age above 35 are much interested in donating to charity and the age group between 18 and 34 are least interested due to various reasons such as they have just started their work or they are still student and do not have enough money for providing donations. Recommendations The awareness in explaining the benefits and procedure in donating to charity needs to be increased as the research results states that the younger age group (between 18 and 34) are not aware of what procedure to follow for making donating to charities. Donation through internet is an easy way to reach out people in all age group especially young generation. Online promotions of charity organisation will definitely change the donation behaviour of people when the opportunities to give are plenty and easy.
Wednesday, November 13, 2019
The Observation of Savage Peoples (1800) :: Essays Papers
The Observation of Savage Peoples (1800) Synopsis Joseph-Marie Degerando was a revolutionary, French philosopher who transcribed one of the original guidelines for the study of anthropology in the year 1800 titled, I: Societe des Observateurs de lââ¬â¢Homme in French, and translated into English as, The Observations of Savage Peoples. According to the author of the introduction and translator of his work into English, F. C. T. Moore, Degerandoââ¬â¢s guidelines were a ââ¬Å"capital work of anthropologyâ⬠(Moore, U of CA Press. p. 2). Whether Degerando provided the most accurate guidelines for the study of humans is argued; however, his work was certainly influential as it served as a foundation for the science of anthropology. In fact, Moore declares there are consistent similarities between the anthropological recommendations of Degerando and those practiced by modern day anthropologists (Moore, U of CA Press. p. 4-5). Although Degerandoââ¬â¢s work is considered one of the earliest influential works serving as a foundation for the field of anthropology, the work was not successful at the time of its publication. Many reasons for its failure are speculated within reviews of the text which offer both criticism and approval. Moore provides an extensive overview of the history of the text in his introduction to The Observations of Savage Peoples, as well as an assessment of its success and failures at the time of its publication. Also, the article, ââ¬Å"Disappearing Savages? Thoughts on the Construction of an Anthropological Conundrumâ⬠by John W Burton, also offers some criticism of Degerandoââ¬â¢s text. The inspirations of Degerando to write such guidelines in the year 1800 are numerous. At the time of its publication, Degerando was part of a new found society in France in 1799, the Societe des Observateurs de lââ¬â¢Homme. This society was formed in coincidence with increased interest in primitive peoples. We find in Mooreââ¬â¢s text, ââ¬Å"False Beginnings: early nineteenth century episodes in the human sciencesâ⬠, an exert describing the intentions and purpose of the society from the journal, Magasin Enyclopà ©dique, In taking the name Socià ©tà © des observateurs de lââ¬â¢homme, and the ancient motto ââ¬ËGnothi seautonââ¬â¢, Know thyself, the society has devoted itself to the science of man, in his physical, moral and intellectual existence; it has called to its observations the true friends of philosophy and moral reality, the deep metaphysician, the practical doctor, the historian, the traveller, the student of the nature of language, the educationalist. In this way, man, followed and compared in the different scenes of life, will become the subject of research the more useful as it is free from passion, prejudice and excessive systematization.
Sunday, November 10, 2019
Radon Gas Case Study Essay
OBJECTIVE: Build a simple ionization chamber that is capable of detecting fairly low levels of radiation BACKGROUND OF THE STUDY Radon is a cancer-causing gas. It comes from the natural breakdown of uranium in soil, rock and water and gets into the air you breathe. These radioactive materials ââ¬Å"decayâ⬠into lighter elements, emitting energetic sub-atomic particles in the process, and one of those lighter elements is Radon. Since radon is a noble gas, it is chemically inert and doesnââ¬â¢t stay bound in the solid the way itââ¬â¢s parent did. It diffuses right through solids and ends up floating freely in the air. Being a noble gas, radon is fairly harmless, itself. You breathe in some radon with every breath but then you breathe it right back out, since it isnââ¬â¢t chemically active or electrically charged. But radon has a short half-life of only about four days, meaning that about half of it will decay within four days, producing new, even lighter radioactive isotopes of other elements like polonium, lead, and bismuth. Those isotopes keep decaying, until a stable isotope of lead is reached. These radon ââ¬Å"daughtersâ⬠are not noble gasses like radon, they are usually ionized when they are produced, and they will readily stick to anything nearby, like healthy lung tissue. They typically have an even shorter half-life than radon and quickly decay inside the lung, kicking out energetic alpha and beta particles that can cause tissue damage and potentially trigger lung cancer. This unfortunate chain of events is due to the decay chain including a noble gas. Radon gas is considered to be the second leading cause of lung cancer. It can get into any type of building ââ¬â homes, offices, and schools ââ¬â and result in a high indoor radon level. But, we are most likely to get your greatest exposure at home, where we spend most of our time. It typically moves up through the ground to the air above and into your home through cracks and other holes in the foundation. Any home traps radon inside, where it can build up. Any home may have a radon problem. This means new and old homes, well-sealed and drafty homes, and homes with or without basements. These are examples where you can find the noble gas: 1. Cracks in solid floors 2. Construction Joints 3. Cracks in walls 4. Gaps in suspended floors 5. Water supply It breaks down into solid radioactive elements called radon progeny. Radon progeny can attach to dust and other particles and can be breathed into the lungs. As radon and radon progeny in the air break down, they give off alpha particles, a form of high-energy radiation that can damage our health. Radon daughters will stick to just about anything they encounter, so they are easily collected by drawing air through a dusting cloth with an ordinary fan. After collecting the daughters for about an hour or two, the radiation being emitted from the cloth due to the further decay of the collected radioactive isotopes can be measured with a simple ionization chamber made from an empty coffee can, a single Darlington transistor, and a digital voltmeter. The deceivingly simple ion chamber is quite sensitive and can detect radon daughters in buildings with radon concentrations below the ââ¬Å"action levelâ⬠recommended by health authorities. A simple ionization chamber is nothing more than a metal can with a wire inside. When a radioactive particle passes through the air in the chamber, many of the molecules of air are ionized, having electrons knocked loose from the outer atomic shells. Applying a positive voltage on the outer can relative to the internal wire, causes these ions to be attracted to the wire and the free electrons to be attracted to the interior wall of the can. This movement of charge is a tiny current that may be amplified to detect the rate at which ions are being generated, and thereby the rate that radioactive particles are passing through the can. The chamber will be detecting mostly betaà particles. BACKGROUND OF THE STUDY Copper is an essential element for all known living organisms, including humans. You need a small amount of copper in your diet to stay healthy. On average, most people will eat and drink about 1,000 micrograms ( à ¼g) of copper per dayââ¬âdrinking water normally contributes approximately 150 à ¼g per day. Levels of copper found naturally in ground water and surface water are typically very lowââ¬âabout 4 à ¼g of copper in one liter (L) of water or lessââ¬âhowever, drinking water may contain higher levels of copper, usually as a result of flowing through copper pipes. High levels of copper can occur if water that is corrosive comes in contact with copper plumbing and copper-containing fixtures. Many factors can make water corrosive for copper pipes: dissolved salts and minerals, bacteria, and suspended solids, such as sand, sediment, and rust. The level of copper in drinking water increases with the corrosivity of the water and the length of time it remains in contact with the plumbing. If the copper level gets too high, the water may have a metallic taste and you might notice blue or blue-green stains around sinks and plumbing fixtures. It will be highest in the morning because the water will have been exposed to the pipes overnight. If you are being served by a public water system, the owner of the utility will have results ofà copper sampling, which is a process that has been done in parts of the water-distribution system. In this chemistry science fair project, you will investigate another possible factor in making water corrosive for copper ââ¬â the pH of the water. You will test the theory that acidic water is more corrosive for copper pipes than non-acidic water. In the procedure, dingy copper pennies will be placed in either plain water or in water with acetic acid (vinegar). You may know that newly minted pennies have bright, shinny copper but over time the copper and air react and the pennies build up a layer of copper oxide on them. The copper oxide is the dull, dark coloration on well-used pennies. In this experiment, if the water is corrosive enough to strip off the copper oxide then you will see the progress of the reaction by watching the pennies go from dull and dingy to bright and shiny. The pennies get shiny because the copper oxide is being stripped off by a reaction, which results in increasing levels of copper in the liquid. Unfortunately, water that is corrosive slowly eats away at the pure copper, as well as at the copper oxide. For houses with corrosive water systems, this can result in elevated levels of copper in the drinking water. On a purely practical level, houses with corrosive water systems might find that their copper pipes are springing leaks, and that the whole house needs to be re-piped with plastic pipes! To measure the amount of copper present in the solutions that are used to clean the pennies, you will perform a color-based chemical test. The chemicals for the test are contained in a small tablet, which is dissolved in water. When the tablet is dissolved, the solution turns reddish-orange. If no copper (or very small amounts of copper) is present, the solution remains reddish-orange. If copper is present, the solution will turn blue.
Friday, November 8, 2019
Young Childrens Symbolic Behaviour Essays
Young Childrens Symbolic Behaviour Essays Young Childrens Symbolic Behaviour Essay Young Childrens Symbolic Behaviour Essay This assignment is about Young Childrens Symbolic Behaviour: theories of representation. It consists of an observational study carried out on one particular childs development in various areas of provision which supports mode of representation. I am however aware of the other forms of representational modes in the setting.Ã The summarised observations will be based on the weekly tasks which are clearly labelled in the appendix session. Before I move on to the main part of the essay, I will give a brief biography and reasons for choosing this particular child. I will move on to discuss different theorist research about representation and the implications of early childhood practices.Ã I will then make references in connection to the findings of the observations through the various forms of the childs representations. Photographs and samples of the childs form of representation will be included. I will demonstrate the role of the adult in this area throughout. This assignment will be concluded by demonstrating why it is important for all children regardless of who they are, to have the opportunities in representing themselves through various forms and media.Ã Symbolic Representation is whereby children represent their world and play in different and various ways such as language, feelings thoughts and understanding. According to Gardner (1983p304), during childhood children acquire certain basic understanding of symbolic activities and systems and which during school age, having achieved some basic competence in symbolization the child goes on to acquire higher level of skills in certain culturally valued domains. These symbolic behaviours and representation emerges as schemas during early childhood. Schema has been described as patterns of early repeatable behaviours Athey (1990p128). In observation 3(p15-16). Target child was demonstrating a high level of symbolic representation with actions. She performed these actions by putting food on a plate, pretend sprinkling salt on the food and offering it to the people (her peers) for lunch. This demonstrates Piagets notion that thought consists of internalized and co-ordinated actions schemas (Piaget 1959p357-386) in Athey (1990p128). Target child displayed transporting schema as well as pilling and moving food from one place to another as The Froebel Education Project termed as action representation of the dynamic aspects of object and events.. Nutbrown (1994) in Smidt, (1998p111) said the early years educator can, through observations identify the schematic interest and nourish it with worthwhile curriculum content The research of theorist such as Piaget, Bruner and Vygotsky has helped practitioners to explore presentation Bruce (1987p66). They also contributed towards the understanding and development of presentation and symbolic behaviours. Observation 2(p12-14) shows how target child represents her play symbolically by using her imagination of sitting on a donkey and riding it. This Piaget in Ginsbury Opper (1988p70) termed as appearance of the semionitic function which means children uses objects in representing something else which is not present. This observation also identifies Bruners enactive, iconic and symbolic mode of representation. Target child did replace the action with an image and used appropriate language in describing her play. Bruce (1987p66) Vygotsky on the other hand talked about the theory of actual development which links in to where target child initiated her own imaginary play without the help of an adult or peer Bruce (1987). Children represent themselves in various ways. Target childs preferred representation is mark making, which Matthews (2003p74) termed it as Visual representation and expression. Samples of these mark making can be found on (p24). Her representation in this observation (observation 4p19) reflects Matthews (2003pg27) idea about how first and second generation mark-making gestures are organised together and undergo transformation.
Wednesday, November 6, 2019
Iliad essays
Iliad essays Nine years after the Trojan War, the Greeks capture and rob a town allied with Troy called Chryse. The Greeks capture a pair of slaves named Chryseis and Briseis during this battle. The leader of the Greeks, Agamemnon, takes Chryseis as a prize, and the greatest Greek warrior Achilles takes Briseis. Apollo is prayed to by Chryses (father of the slaves) for the return of his daughters and sends a plague to the Greek camp. Agamemnon tries to find out the cause of the plague so he contacts the prophet Calchas. He finds out that Chryseis was the cause so he gives up his slave and takes Briseis from Achilles. Achilles becomes angered with this action and refuses to fight in the war. He strongly wishes that the Greeks become destroyed and ask his mother Thetis (sea-nymph) to enlist the services of Zeus (king of Gods). The Trojans and Greeks cease fire with each other but the Trojans breach the treaty so Zeus came to their assistance. Now the Greeks suffered greatly without the support of Zeus and Achilles refusal to fight. Also the great Greek warrior Diomedes proved fruitless. Some major battles occur for several days including Hector and Ajax, and Paris and Menelaus. The Greeks were forced back by the Trojans to protect their ships. Greeks get some hope when one night Diomedes and Odysseus get information about the plans of the Trojans. The next day several Greek commanders become wounded and the Trojans break through the Greek ramparts advancing all the way to the boundary of the camp and setting fire to a ship. Greeks felt that defeat was coming on because they would be stranded at Troy without the ships. Meanwhile, Achilles showed concern for his fellow Greeks and agreed to a plan by Nestor that allowed Achilles good friend Patroclus to go in his armor to battle for him. The presence of Patroclus proved helpful for the Greeks since the Trojans were pushed away from the ships and back to the city wall s. Hector soo...
Monday, November 4, 2019
ILM Level2 Understanding training & coaching in the workplace Assignment
ILM Level2 Understanding training & coaching in the workplace - Assignment Example This need is called by the changes in the regulatory sphere of utility provision and collaboration with contractors, whose activities require more knowledge to ensure services to people. Training is called when employees are not able to perform a certain job due to the lack of knowledge, skills or experience. Hence, training is a necessary predisposition for successful accomplishment of work tasks (Elnaga & Imran, 2013). Another reason for training need is the new or changed job procedures, effective implementation of which depends on the level of skills and knowledge of employees. Thus, for Government Utility the need in training is called by the changes in the regulatory sphere of utility provision and collaboration with contractors, whose activities require more knowledge to ensure services to people. Training need is also viewed as the gap between where an individual is now and where organization wants to see it. For the company it is necessary to establish whether there is knowledge, skills or attitudinal gaps (Training and development toolkit, 2015). It is also important that the training environment would be evaluated, where SWOT analysis is a useful tool to apply, as it advocates strengths, weaknesses, opportunities and threats of training development. As workplace training is important for the modern knowledge-based environment, it helps employees to develop those skills and knowledge required in an organization. For that purpose, there are different methods of workplace training, such as mentoring and coaching, on the job training, video conferencing and collaborative tools, business television, e-learning and learning management systems (Workplace training, 2015). As the modern technology has influenced greatly the way employees can obtain knowledge and skills, web-based training provides employees a
Friday, November 1, 2019
RECONSTRUCTION Essay Example | Topics and Well Written Essays - 1250 words
RECONSTRUCTION - Essay Example ecause the radical Republicans did not agree with President Abraham Lincoln and Andrew Johnson on softer terms of bringing back the South to the Union. The Liberal Republicans were of the opinion that those whites who had not held onto the ideologies of the union should not have had their rights restored. It was still during the civil war that President Abraham Lincoln made plans to reconstruct the Union. The president first made sure that the union armies conquered the large sections of Tennessee and that this state was under the control of the national government. After this is when he moved to put his plan into action. From his second inaugural address, it was clear that Abraham Lincoln thought it better to approach the matter soberly and not punish the south. His plan focused on all including the South that had born the battle. In 1863, Abraham Lincoln appointed Andrew Johnson to govern the state of Tennessee to serve as a model state for the south. The president then asked the voters of Tennessee to at least have 10% of them taking an oath to uphold the constitution. When this oath was taken, all persons save for the highest officers in the confederate army would be pardoned for their contribution to the war. The rights of the citizens would also be restored except for the slaves. The president also required that the states that would be reconstructed to ratify the Thirteenth Amendment. This amendment abolished slavery. This, the president called it the ââ¬Ënew birth of freedom.ââ¬â¢ He was however worried that this would not be received well by the whites in the south. He was of the opinion that, just like the white people, the black people were American citizens (Murrin 463) Due to the differences in ideology between Lincoln and the congress, in July 1864, there was the first direct clash. The congress passed the Wade-Davis bill and adjourned shortly after passing the bill. For Lincoln to continue with his reconstruction plan, he vetoed it by failing to
Wednesday, October 30, 2019
Biologic Manufacturing and the FDA Essay Example | Topics and Well Written Essays - 500 words
Biologic Manufacturing and the FDA - Essay Example Biologics combined with radioactive components are considered biologics, while biologics combined with non-radioactive components are drugs. While most analyses of the U.S. Food and Drug Administration (FDA) focus on the agency's authority to decide which new treatments reach the American marketplace, the FDA plays a regulatory gatekeeper role at another key point in the biological development process. In reviewing investigational new drug applications (INDs), the FDA determines which experimental therapies, vaccines, and other biological products advance from preclinical through clinical development to the licensing phase (Mark). Biopharmaceuticals are licensed under Section 351 of the Public Health Service Act (Mark)and in specific sections of the Food, Drug and Cosmetic Act. To obtain marketing approval for a new biologic, an applicant submits a biologics license application (BLA) (Koan and Ellis). The BLA must permit agency reviewers to make four principal determinations: The growth media falls under Federal food, Drug and Cosmetic Act (the act) and hence, controlled by the same, specifically, if the media is derived from any protein, a label stating the possibility of the media as an allergen should be stated.
Monday, October 28, 2019
The movie ââ¬ÅJose Rizalââ¬Â Essay Example for Free
The movie ââ¬Å"Jose Rizalâ⬠Essay The movie ââ¬Å"Jose Rizalâ⬠is all about our National Hero Dr. Jose Rizal ââ¬â Hislife and works, his struggles in order to free his countrymen from abuse, until his death under the hands of the Spaniards who occupied our country for a very longtime. Most of the scenes of the film took place during Rizalââ¬â¢s imprisonment at Dapitan wherein he meets Taviel, a Spanish officer, who will eventually defend him on his trial in court. During their meeting, Taviel asks Rizal everything about him and his works through various questions. Every answer that Rizal brought out from his mouth made Taviel realize that Rizal was indeed an innocent man. On the course of their conversation, Rizal talks about the making of his Two Novels ââ¬Å"Noli Me Tangereâ⬠and its sequel ââ¬Å"El Filibusterismoâ⬠which are both anti-Spanish Novels that depicts how the Spaniards rule the Philippines and how the rights of the Filipinos were abolished. Rizal portrayed himself on the said Novels ââ¬â as Crisostomo Ibarra on ââ¬Å"Noli Me Tangereâ⬠and as Simeon on ââ¬Å"El Filibusterismo. â⬠Going through with the movie, while Rizal is telling his story to Taviel, the scene on the movie switches from his life story then to his portrayal on his Novels. Sometimes the scene gets very difficult to follow because of the sudden switches during the scenes on the movie most especially during the time that his first novel was on the process of writing. Rizal, a brave and a man of his word, was never afraid whatever theconsequences he may suffer because of his writings that are against the friars and also to Spaniards. His goal was to free the Philippines from the unjust government of Spanish colony. In summary, the movie talks mostly of Rizalââ¬â¢s life until his death and the creation of his great novels. The actors and actresses who acted on the movie did a great job presenting how it was during Rizalââ¬â¢s time even though the said events in Rizalââ¬â¢s life were just written in books.
Saturday, October 26, 2019
Graduation Speech -- Graduation Speech, Commencement Address
Good evening everyone. My name is Toyota Moko, and I am an international student from Japan. As the first-ever international student speaker on commencement, I am very honored to be here tonight to be given this opportunity to speak on behalf of the graduating class of the 2003. Born and grew up in Tokyo where speaking English was absolutely absent in my eighteen years of life, one day the life-changing experience came to me. When I was fifteen-years-old, the summer of 1998, I came to America for the very first time for the home stay program through my high school. The three weeks I spent in Snohomish have brought me a wonderful encounter with my American family. John, Margo and Jennifer Turner have truly become my second family away from home. Despite the fact that I was a stranger from Japan, the Turner family treated me as if I was a part of their family, even though I had spoken broken English. During these three weeks, I was exposed to many cultural differences between America and Japan, and I was especially moved by the American people and its society where one is able to not only accept, but mutually respect and honor multicultural background and heritage. Coming from homogeneous country of Japan, this to me was a very fresh insight, and I still remem ber how it struck me. After I came back to Japan, I kept in touch with my American family via e-mail. And they invited me to stay with them if I were to study at the college. I spent years preparing for my study abroad, and with the great help of the Turner family, Ms. Joy Fitzpatrick who is the international student program coordinator, and my parents, I entered America as an international student on March 11, 2001, only one week after my high school graduation in Japa... ...y just few weeks ago on May 17. My grandfather was full of ambition and care for his family, and he especially loved me as his granddaughter. I was able to make this speech because I do believe that my grandfather will be sitting in the first row and listening to my speech at this very moment. He kept his promise to be alive until I have become twenty years old, so it is now my turn to promise him to carry on his spirit and all the knowledge and wisdom he had taught me. And more than anybody else, this honor goes to my dearest Turner family and my parents and family in Japan for making it possible for me to experience this incredibly astounding journey in America. Congratulations class of 2012! From the bottom of my heart, I wish all of you a shining future! Thank you for having me this special moment. Arigatougozaimasita! (Japanese: "Thank you very much.")
Thursday, October 24, 2019
Iliad :: Literary Analysis, Homer
The Iliad Comparison and Contrast of Achilles and Hector When audiences read Homerââ¬â¢s Iliad, we find that this epic tale is centered around the Greek and the Trojan War. We notice in this tale, that Achilles of the Greeks and Hector of the Trojans carry the title of greatest warrior for their perspective armies, both men are an inspiration for their countrymen in this battle. Each man shows us their strengths and weaknesses, which we will use as points of comparison and contrast between the two heroic men. When reviewing the two men, we find that there are actually very few comparison points. However the common points we do find are critical in describing the characters of both men. One major comparison is that both men are warriors and known as fierce fighters. Agamemnon describes Achilles as ââ¬Å"the most violent man alive (pg. 123).â⬠Achilles himself describes Hector as ââ¬Å"man-killing Hector (pg. 126)â⬠. Another key similarity is that for both men, their fates are influenced by the Gods. Achilles was very angry with Agamemnon because of the situation with the priestââ¬â¢s daughter. Achilles vowed to Agamemnon that he would no longer follow him in battle, bringing home a pittance of the spoils while Agamemnon always brought home the lions share. Agamemnon answered back that he would give back the priests daughter but in return for his loss, he would take Achilles spoil, Briseis. Achilles is gripped with rage and strongly considers killing Agamemnon on the spot, ââ¬Å"should he draw the long sharp sword slung at his hip, thrust through the ranks and kill Agamemnon now? ââ¬â or check his rage and beat his fury down (pg. 124 ââ¬â 125)?â⬠Although still extremely angry, Achilles listens to the voice of Athena and pulls back his fury, ââ¬Å"â⬠¦a man submits though his heart breaks with fury. Better for him by far. If a man obeys the gods theyââ¬â¢re quick to hea r his prayers (pg. 125).â⬠For Hector, his godly influence is Zeus. He is even described as ââ¬Å"dear to Zeus (pg. 141).â⬠He constantly prays to Zeus and seeks his guidance. He curses his brother Paris to Zeus because he blames Paris for causing the war between Troy and the Achaeans, ââ¬Å"let the earth gape and swallow him on the spot! A great curse Olympian Zeus let live and growâ⬠¦that man ââ¬â if I could see him bound for the House of Death, I could say my heart had forgot its wrenching grief (pg.
Wednesday, October 23, 2019
Assess The Roles Of Different Agencies Essay
There are three different agencies of socialisation. The family, the education system and the media. These all have different roles in socialisation. The family effects people in their younger years, before they attend school. It teaches children the appropriate behaviour for their gender. A childââ¬â¢s behaviour is also influenced by how they observe their parents. Parents are influential in shaping basic values such as manners. Margnet Meed (1934) said parents are significant others who receive respect on their opinions and values from the children. Norms differ between families but the family teach children how to address family members, how and where to eat and sleep and the difference between good and bad behaviour. The roles in the family are quite limited and adults have more roles. There are also positive and negative sanctions in the family. These sanctions are informal in the family. Some positive sanctions include facial expressions, verbal approval and physical rewards . Some negative sanctions include being grounded, smacked or disapproval through language. Bernstein suggested that there are differences in how we learn to use language based on the social class of our family and Haralambos and Holborn (2000) claimed that compared to working-class families, middle-class parents emphasise high achievement at school and reward success. Another agency of socialisation is the education system. This teaches us the knowledge, skills and attitudes needed for later life. Jackson (1968) said hidden curriculum is things we learn from the experience of attending school, such as dealing with strangers. It teaches us the historic knowledge of our societies past and the geographic knowledge of our society and other societies. It also teaches us the values of our society. For example, getting good grades and qualifications and that we should work hard for those qualifications. Bowles and Gintis (2002) said there is a correspondent between school norms and work norms . There are positive sanctions in the education system such as gaining grades and qualifications, prizes, praise and encouragement. Parsons (1961) (functionalist) claims that in families children are taught slightly different norms and values meaning some children may be allowed to do things others are not. Bowles and Gintis (1976) (Marxist) claims that schools teach children that the most intelligent get the best results. There are negative sanctions as well such as detention, exclusions, failure to achieveà qualifications and having a bad reputation. The media is the third agency of socialisation. This agency is an unusual agency of socialisation and the relationship is impersonal. The media can expose their values onto us but it is uncertain as to what extent. The media is also very powerful in supporting or marginalising certain values. The norms of the media has a boundary. They can publicise acceptable and unacceptable forms of behaviour and they can also reinforce perceptions of expected behaviours. Some positive sanctions of the media include celebrities such as Kate Middleton and Cheryl Cole, who are always shown at their best. Whereas the negative sanctions are very criticizing and show unflattering pictures. Potter (2003) suggested thereââ¬â¢s short term effects of the media, such as learning about new ideas and places, imitation of things that weââ¬â¢ve seen on TV, such as styles of hair and clothes and desensitisation, where our emotional reaction to things such as violence and poverty is lowered because of the constant and repeated exposure. Potter (2003) also suggested thereââ¬â¢s long term effects such as consumerism, where the repeated exposure of lifestyles and desirable consumer goods, suggests that happiness is something that can be bought. Fear when the media show negative and violent events which may also lead to people overestimating things, and agenda-setting where the media can determine how things will be debated, for example, immigration. This all shows that the agencies of socialisation are very important in forming and shaping young people and that if these agencies are misused or used in a certain way, there will be consequences in how young people may act in their adult life. Not only does each agency effect the values, norms, roles, behaviour, knowledge and sanctions of people, but they also effect each other, for example, the media, if viewed too much or too seriously, may effect someoneââ¬â¢s education as they may learn less or pay less attention, or the family as they may be rude to other family members, more disrespectful or they may be less social.
Tuesday, October 22, 2019
The decision in Durham Tees Valley Airport Ltd v BMI Baby Ltd The WritePass Journal
The decision in Durham Tees Valley Airport Ltd v BMI Baby Ltd The decision in Durham Tees Valley Airport Ltd v BMI Baby Ltd IntroductionPart 1: The decision in Durham Tees Valley Airport Ltd v BMI Baby Ltd1.1 Facts of the case and terms of the contract Part 2: Discussion of the caseà à 2.1 A balancing actà à à à à à à à à à à à à à à à à à à à à à à à à ConclusionBibliographyà 1.0à à à à à à à à à Journals2.0à à à à à à à à à Books3.0à à à à à à à à à CasesRelated ââ¬Å"The case of Durham Tees Valley Airport Ltd v BMI Baby Ltd [2010] EWCA Civ 485 illustrates how the court must tread a very fine line, when determining whether or not an agreement has sufficiently certain terms to be enforceable. With reference to key cases and academic commentary, critically discuss this statement.â⬠Introduction Contract law abhors uncertainty and it is a well-accepted rule of commercial law that for an agreement to be enforceable its terms must be sufficiently certain and complete for the courts to elicit the meaning of an agreement[1] . Both vagueness[2] and incompleteness[3] disable an agreement from being binding and will often, unless the court makes use of remedial measures to, inter alia, imply reasonable meaning into the contract or clarify the meaning of a word, be fatal to the contract as a whole[4]. The classic case which is usually cited to demonstrate this principle is G Scammell Nephew Ltd v Ouston[5] where an agreement which provided for the acquisition of goods ââ¬Å"on hire-purchaseâ⬠was so vague as to prompt Viscount Maugham to observe that: ââ¬Å"it is impossible to conclude that a binding agreement has been establishedâ⬠[6]. The tension between finding a contract to be uncertain and attempting to satisfy the settled will of parties to an agreement and encour age commerce without undue restriction has led Professor Macneil to warn that the quest to identify settled principles in this area of contract law is but a ââ¬Å"foolââ¬â¢s errandâ⬠[7]. Cases in this area, as Ewen McKendrick rightfully observes, are dependent on their facts and the courts are chiefly concerned with whether there is a sufficiency of evidence to justify a conclusion that a settled and binding agreement has indeed been concluded[8]. Unsurprisingly perhaps English courts have been criticised as being unduly restrictive which makes the judgement in Durham Tees Valley Airport Ltd v BMI Baby Ltd[9] a notable and welcome decision as it goes against the grain of the perception of English contract law by overturning on appeal a decision of Davis J in the Chancery court which held that a contract which imposed an obligation on BMI Baby to base and fly aircraft from an airport but which was unclear about the objective criteria relating to the performance of that obligation regarding passenger numbers was incapable of having a term implied and therefore was struck down[10]. The Court of Appeal allowed the appeal and unanimously found in favour of allowing the contract to stand: the judge at first instance had erred in construing the contract as being void for uncertainty[11]. This essay will critically discuss the above statement by examining the case itself in detail in part 1 before embarking upon a discussion of the ba lancing act involved in resolving uncertainty in contractual terms in part 2. The statement is justified in asserting that such cases as the instant one require a delicate balancing act and this observation is validated by the case law[12]. Part 1: The decision in Durham Tees Valley Airport Ltd v BMI Baby Ltd 1.1 Facts of the case and terms of the contract The brief facts are that an agreement was concluded between Durham Tees Valley Airport (hereafter DTVA) and British Midland Regional Limited (hereafter BMRL) in April 2003 which provided for BMRL to provide two B737 aircraft to operate exclusively from DTVA for a period of ten years[13]. This agreement was subsequently transferred to BMI Baby by virtue of a Novation and Variation Agreement (NVA) executed on 23 December 2005. As Lord Justice Patten, who delivered the leading judgement, observes ââ¬Å"both sides accept that the Base agreement created a binding contract but they differ on how it should be construedâ⬠[14]. The defendants contended that the agreement granted them a right without an obligation while the airport argued that the agreement constituted a continuing obligation. The decision at first instance, delivered by Davis J, proceeded, without any notable discussion, on the assumption that the contract was unenforceable due to uncertainty[15]. The bulk of the first instance judgement was concerned with the attempt to imply a term into the NVA agreement to hold the contract to be enforceable and thus hold BMI Baby to the obligation[16]. As Treitel observes the court has a discretion as to whether or not a term can be implied into a contract using the standard of reasonableness[17]. Judge Davis pointed out that the NVA lacked any specification as to the number of flights required and as Lord Justice Patten points out, ââ¬Å"it is this which is said to be fatal to its enforceabilityâ⬠[18]. A leading case in the area of implied terms under the standard of reasonableness is Hillas Co Ltd v Arcos where the timber sold was said, ambiguously, to be of ââ¬Å"fair specificationâ⬠. This is a typical example of terms which come to the very heart of a contract[19] being expressed in vague or uncertain ways and requiring the construction of the court to crystallise an obligation. Lord Justice Patten fundamentally disagreed with the first instance judge at this stage, arguing that it ââ¬Å"was wrong to regard the addition of a term as to the minimum number of flights as being necessary for the enforceability of the NVAâ⬠[20]. The judge had thus proceeded on an assumption of uncertainty and then attempted to imply a term into the NVA agreement which, mistakenly, he thought had a material bearing on the enforceability of the contract[21].à The key elements of the contract were obviously in place and both parties considered that a binding contract was in place despite their differing interpretations. The real question, as Lord Justice Patten correctly identifies, is whether or not the airline was in fact flying its aircraft not the number of flights[22]. Upon this analysis BMI Baby had fulfilled the obligation and thus they could be held accountable: ââ¬Å"BMIB is not required to do the impossibleâ⬠as Lord Patten concluded[23]. His lordship found sufficient evidence that certainty existed in the contract without resort to any implied terms: ââ¬Å"This makes it unnecessary in my judgement for DTVAL to rely upon an implied term that BMIB would operate the aircraft in a way that was reasonable in all the circumstances. The NVA includes sufficient terms to enable the court to determine whether BMIBââ¬â¢s obligations have been broken.â⬠[24] Part 2: Discussion of the caseà à 2.1 A balancing actà à à à à à à à à à à à à à à à à à à à à à à à à The decision in Durham Tees Valley Airport Ltd v BMI Baby Ltd[25] is a good illustration of the fine balancing act which must be undertaken in cases which attempt to resolve the uncertainty of contractual terms in terms of sufficiency. At the most general level there is a clear tension between the certainty rule and the reluctance of courts to strike down legally enforceable agreements. Striking a balance between these two opposites is difficult and has obvious implications not only for individual agreements but indeed the sanctity of contract in society. Lord Wright in Hillas Co Ltd v Arcos Ltd observed: ââ¬Å"Businessmen often record the most important agreements in crude and summary fashion; modes of expression sufficient and clear to them in the course of their business may appear to those unfamiliar with the business far from complete or precise. It is accordingly the duty of the court to construe such documents fairly and broadly, without being too astute or subtle in finding defectsâ⬠.[26] These comments were endorsed recently in Scammell v Dicker[27] where Rix LJ emphasised that for a contract to be void for uncertainty the bar should be set very high: ââ¬Å"For to occur ââ¬â and it very rarely occurs ââ¬â it has to be legally or practically impossible to give to the parties agreement any sensible contentâ⬠[28]. On a more specific level the court, when dealing with a question such as in the instance case, must first address whether the terms of the contract are enforceable or not. The price, quality and quantity, as Lord Patten has identified, are key measures of a contract where objective criteria exist[29]. Each case evidently turns on its facts and there is a lot of gray area here which underlines just how fine the balancing exercise is. The answer to the question of just what is necessary for a contractââ¬â¢s enforceability appears to be inextricably linked with what would constitute a breach of contract. In the instant case the minimum number of flights was something which was within the discretion of BMI Baby and so not something which compromised the terms of the contract concerning the aircraftââ¬â¢s ââ¬Å"operationâ⬠. There are some features of the instant case which render it particularly problematic: the length of the contract and the ââ¬Å"degree of discretion given to the airlineâ⬠[30]. However, Lord Justice Toulson observes that it is not impossible to imagine facts on the borderline which would have rendered the case even more difficult[31]. Conclusion à In conclusion the statement to be discussed is correct in identifying that the decision in Durham Tees Valley Airport Ltd v BMI Baby Ltd[32] is an apt illustration of the fine line which must be negotiated in deciding whether an agreement has sufficiently certain terms to be enforceable. As noted above there is a tension between allowing commercial agreements to stand and finding them void for lack of certainty. The court in Hillas Co Ltd v Arcos Ltd[33] emphasises the duty the courts have in allowing business agreements sometimes hastily drawn up to stand without being too clever with syntax. Each case turns upon its facts and there clearly can be cases which would stretch the balancing act even further than the instant case. As it stands the judge at first instance fell victim to the subtleties of this area of law and misinterpreted a term of the NVA contract which was within the discretion of BMI Baby. The Court of Appeal thus overturned his decision and made a decision of pr incipal which demonstrates that Professor Macneilââ¬â¢s observations may not be as accurate as previously thought[34]. Bibliography à 1.0à à à à à à à à à Journals Lawrence, Mark (2010) ââ¬ËGrounded obligationsââ¬â¢ New Law Journal 160(7421), 837-838 2.0à à à à à à à à à Books Macneil, Ian (2001) ââ¬ËBiographical Statementââ¬â¢ in D Campbell (ed) The Relational Theory of Contract: Selected Works of Ian Macneil Sweet Maxwell: London Mckendrick, Ewan (2005) Contract Law: Text, Cases and Materials Oxford Uni Press: Oxford at p.148 Treitel, G.H. (2007) The Law of Contract Sweet Maxwell: London at p.52 3.0à à à à à à à à à Cases Durham Tees Valley Airport Ltd v BMI Baby Ltd [2010] EWCA Civ 485 Durham Tees Valley Airport Ltd v BMI Baby Ltd [2009] EWHC 852 à Hillas Co Ltd v Arcos Ltd (1932) 147 LT 503 Perry v Suffields Limited [1916] 2 CH 187 Scammel and Nephew Ltd v Ouston [1941] AC 251 Scammell v Dicker EWCA Civ 405 [1] Treitel, G.H. (2007) The Law of Contract Sweet Maxwell: London at p.52 [2] Scammel and Nephew Ltd v Ouston [1941] AC 251 House of Lords [3] Perry v Suffields Limited [1916] 2 CH 187 [4] Chitty, Joseph (2008) Chitty on Contracts Thomson Reuters: London at p.223 para 2-139 [5] [1941] AC 251 [6] Scammel and Nephew Ltd v Ouston [1941] AC 251 per Viscount Maugham at p.257 [7] Macneil, Ian (2001) ââ¬ËBiographical Statementââ¬â¢ in D Campbell (ed) The Relational Theory of Contract: Selected Works of Ian Macneil Sweet Maxwell: London [8] Mckendrick, Ewan (2005) Contract Law: Text, Cases and Materials Oxford Uni Press: Oxford at p.148 [9] [2010] EWCA Civ 485 [10] [2009] EWHC 852 [11] Durham Tees Valley Airport Ltd v BMI Baby Ltd [2010] EWCA Civ 485 [12] Hillas Co Ltd v Arcos Ltd (1932) 147 LT 503 [13] Durham Tees Valley Airport Ltd v BMI Baby Ltd [2010] EWCA Civ 485 per Lord Justice Patten at para 11 [14] Ibid at para 11 [15] Durham Tees Valley Airport Ltd v BMI Baby Ltd [2010] EWCA Civ 485 per Lord Justice Patten at para 46 [16] Lawrence, Mark (2010) ââ¬ËGrounded obligationsââ¬â¢ New Law Journal 160(7421), 837-838 [17] Treitel, G.H. (2007) The Law of Contract Sweet Maxwell: London at p.52 [18] Durham Tees Valley Airport Ltd v BMI Baby Ltd [2010] EWCA Civ 485 per Lord Justice Patten at para 57 [19] Such as quantity, quality or price [20] Durham Tees Valley Airport Ltd v BMI Baby Ltd [2010] EWCA Civ 485 per Lord Justice Patten at para 59 [21] The number of flights was something which was for the discretion of the airline; [22] Durham Tees Valley Airport Ltd v BMI Baby Ltd [2010] EWCA Civ 485 per Lord Justice Patten at para 59 [23] Ibid [24] Ibid at para 61 [25] [2010] EWCA Civ 485 [26] Hillas Co Ltd v Arcos Ltd(1932) 147 LT 503 per Lord Wright at p.504 [27] EWCA Civ 405 [28] Ibid at para 30 per Rix LJ [29] Lord Justice Patten gives the example of a tenancy agreement under which the tenant agrees to pay a reasonable rent [30] Durham Tees Valley Airport Ltd v BMI Baby Ltd [2010] EWCA Civ 485 per Lord Justice Toulson at para 91 [31] Ibid at para 90 [32] [2010] EWCA Civ 485 [33] (1932) 147 LT 503 [34] Macneil, Ian (2001) ââ¬ËBiographical Statementââ¬â¢ in D Campbell (ed) The Relational Theory of Contract: Selected Works of Ian Macneil Sweet Maxwell: London
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