Post-acquisition cultural integration the case of Arcelormittal Essay

Post-procurement social reconciliation the instance of Arcelormittal - Essay Example The motivation behind the paper is to comprehend the discoveries of the past specialists regarding the matter. Diaries and papers from scholastic sources, for example, Emerald, PROQUEST and EBSCO Host have been sued for the examination. The spotlight for this examination on ArcelorMittal is advocated taking into account the various disappointments in global mergers because of social issues. The primary stream of writing depends on understanding the idea of mergers and acquisitions. An outline of the terms, the thought processes in mergers and the result of such mergers have been talked about. The second stream of writing is on the job of culture in acquisitions. In this area, the meaning of culture, the idea of national and authoritative culture, including the nation bunches and their worth framework have been examined finally while giving the various speculations. Under a similar area the cultural assimilation hypothesis and the idea of social cooperative energy has been featured. T he third stream of writing manages the administrative abilities and the etymological issues with regards to worldwide mergers. Mergers and acquisitions (M&A) is an outflow of a system that relates to the corporate division. It is fundamentally the administration of various procedures identifying with various capacities, for example, selling, purchasing or joining at least one organizations towards a shared objective. It assists with quickening development and accomplish cooperative energies.

Corporate Social Responsibility and Carroll Pyramid Essay Example

Corporate Social Responsibility and Carroll Pyramid Essay The worldwide money related emergency revealed numerous accepted practices beforehand unheard of. The quantity of individuals who lost their Jobs because of the monetary circumstance is horrifying. Strangely, this doesn't imply that worldwide companies are essentially languishing. The greater part of the set up organizations with branches everywhere throughout the world took the reason of the budgetary breakdown to profit. Out of nowhere, it was alright to lay off individuals on the affection of money related unhappiness. This implies a couple of individuals were profiting by the burdens of a thousand more. The issue of corporate social obligation introduces itself in this circumstance in that, the multi-partnerships are controlled by a leading body of governors. The leading group of governors is normally created ofa not many people that give orders. It is normal information that these companies utilize countless people in numerous parts of the economy. At the point when the benefits of these monstrous organizations neglect to arrive at a specific objective, the running expenses of the business must be checked. This is the reason, the couple of people at the top, not having any desire to lose, resort to terminating a few people. This is done as such as to keep up the benefits at a specific level. We will compose a custom paper test on Corporate Social Responsibility and Carroll Pyramid explicitly for you for just $16.38 $13.9/page Request now We will compose a custom article test on Corporate Social Responsibility and Carroll Pyramid explicitly for you FOR ONLY $16.38 $13.9/page Recruit Writer We will compose a custom article test on Corporate Social Responsibility and Carroll Pyramid explicitly for you FOR ONLY $16.38 $13.9/page Recruit Writer The issue is that when the entirety of the global organizations resort to terminating a couple of representatives, the net impact is that, countless people wind up losing their Jobs. Corporate social duty guarantees that companies the world over are occupied with different exercises that offer back to the network (Crowther and Rayman-Bacchu 172). Numerous exercises that are viewed as accommodating incorporate; sorting out exercises that try to include the network in such occasions as raising support for the eedy, occasions that look to assist the burden in the public arena and other comparative exercises. In the money related and corporate world, corporate social duty a given with a positive effect on execution. There are, be that as it may, a few factors that show the requirement for corporate social obligation. The principal factor is populace. The growing populace in creating districts will make bigger markets commanded by more youthful people with faulty access to the created universes way of life. Insights show that in excess of eighty five percent of the universes populace will ive in creating nations by 2025 (Crowther and Rayman-Bacchu 165). This presents a test to organizations looking to include themselves in corporate social duty, since obviously a ton of money related help will be required for these populaces. The subsequent factor is riches. In spite of the way that worldwide riches is rising, the salary hole has become more extensive, compromising common society. Seventy eight percent of the world can be named poor, with eleven percent in the white collar class, and just eleven percent can be named rich. Every single organization ought to endeavor to be nvolved in endeavoring to adjust this appropriation of riches. The pattern of the rich becoming more extravagant while the poor become more unfortunate ought to be killed, since it is exploitative for certain individuals to have so a lot, and others to have nothing by any means. The third factor is sustenance. There are a huge number of individuals who are malnourished, in the midst of a plenitude of food. Thousands kick the bucket of appetite consistently, while rich partnerships blow millions on extravagant occasions for their officials. It is vital for each organization to require some investment and retlect on the funds it spends on benefits tor its administrators, as thought about o that spent on helping the destitute in the public eye. While these advantages are crucial for representative inspiration, they ought not be taken over the edge to the detriment of the enduring masses. Training is another basic factor that ought to be considered in the plan of corporate social duty programs. Essential training is across the board, yet open doors for learning keep on escaping many. More than one hundred million kids are not in school, with ninety seven percent of these being in creating nations. One in each five grown-ups universally is uneducated, which are taggering fgures given the broad chances to learn accessible today. Corporate are confronted with the test of advancing instruction by setting up schools, and subsidizing instructive advancement programs. Instruction can likewise be supported by taking in assistants and students and allowing them a chance to gain proficiency with the stunts of the Job, which will empower them contend reasonably in the corporate world (Crowther and Rayman-Bacchu 169). Taking everything into account, this paper has demonstrated that corporate social duty is an essential component for nay business partnerships. It has been indicated that here are a wide range of regions wherein an organization may decide to center its corporate social obligation. The main region of center in corporate social obligation is concerning the earth. Different regions that ought to be considered in the improvement of corporate social duty programs are training, wellbeing, sustenance and business. Social duty venture joins speculators budgetary objectives with their commitment and devotion to factors that guarantee the prosperity of society, for example, natural well disposed practices, financial development and ustice in the public eye (Anderson 9). These components are parts of corporate social duty, yet additionally a demonstration of the moral guidelines of an organization. It is untrustworthy for certain people to possess so a lot and win such a great amount, to the detriment of other enduring citizenry. It is additionally dishonest for organizations to participate in naturally debasing practices that bring about ailments and death toll. It very well may be reasoned that Social corporate duty and the upkeep of high moral principles isn't an alternative however a commitment for all business. Works Cited Anderson, Jerry. Corporate Social Responsibility: Guidelines for Top Management. Westport: Greenwood Press, 1989. Print. Banerjee, Subhabrata. Corporate Social Responsibility: The Good, the Bad and the Ugly. Northampton: Eward Elgar Publishing, 2007. Print. Crowther, David and Rayman-Bacchus, Lez. Points of view on Corporate Social Responsibility. Burlington: Ashgate Publishing, 2004. Print. Werther, William and Chandler, David. Vital Corporate Social Responsibility: Stakeholders in a Global Environment. Carlifonia: Sage Publications, 2006. Print.

Triangular trade Essay Example For Students

Triangular exchange Essay Slaves and slave exchange has been a significant piece of history for an extremely prolonged stretch of time. In the long stretches of the British thirteen states in North America, slaves and slave exchange was a significant piece of its turn of events. It even carried on to right around 200 years of the United States history. The slave exchange of the thirteen provinces was a significant piece of the settlements just as Europe and Africa. So as to flexibly the thirteen states effectively through exchange, Europe built up the strategy for triangular exchange. It is alluded to as triangular exchange since it comprises of exchange with Africa, the thirteen provinces, and England. These three zones are ordinarily called the exchanges three legs. The main leg of this exchange was vendors from Europe carrying refined products to Africa to exchange for slaves. The dealers exchanged with boss and high position pioneers. The boss basically could and would exchange whomever they satisfied, there was no limitation with respect to who the slaves were. On the second leg of this exchange slaves were shipped toward the West Indies, this leg was known as the center entry. This part was terrible for the slaves. About half of the considerable number of slaves on one boat would not make it toward the West Indies as a result of ailment or fierce abuse. Several men, lady and kids were confined together for the majority of the excursion, every so often capable move a practically conventional sum. On the third leg of the excursion slaves were exchanged for sugar, molasses and different items. Those items were dispatched to Europe or other European states in the Americas. The slaves in the West Indies were then offered to whomever needed to get a few. After this entire procedure the cycle rehashed itself again and again, and this framework was utilized for quite a while. To flexibly the thirteen states adequately however exchange, Europe thought of the possibility of triangular exchange. Africa, the 13 provinces, and Europe were a piece of Europes development of triangular exchange. Taking all things together, this was an exceptionally cruel yet to some degree effective method of trade.Words/Pages : 367/24

Tidal Power (School of Mechanical, Materials and Manufacturing Essay

Tidal Power (School of Mechanical, Materials and Manufacturing Engineering) - Essay Example There are roughly 20 destinations over the reality where tidal force can be produced. This vitality is free, yet it tends to be dealt with some other force age plant as it is accessible just for 10-12 hours out of every days when tides streams. Catchphrases: Tide, tidal, turbines, floodgates, lock, banks, tidal wall, tidal ponds, tidal streams, Bulb turbine, Rim Turbine, Tubular turbine, Offshore Turbines, Vertical-Axis turbines and tidal blasts. One can without much of a stretch say or foresee that one thing happens each day twice, which is going back and forth of tide in sea (ocean). This can happen due to gravitational power of the Moon and Sun simultaneously pivot of Earth [3]. In view of tide colossal of measure of water moves and saddling it by certain methods can give a lot of vitality. This vitality gracefully is solid and abundant (everlastingly) and sustainable. The tides will proceed to recurring pattern, and the vitality is ready for whoever gets there first. It gives a particular bit of leeway over other sustainable sources that are not solid and unsurprising, for example, wind and sun based vitality. Yet, the principle concern is identified with changing over it into helpful type of intensity (power) and that isn't simple. Just around 20 destinations on the planet have been distinguished as conceivable tidal force stations [2]. Turbines: It is situated in water entries which are intended to change over the potential vitality of the distinction in water levels over the blast into motor vitality as quick moving water and than later changed over into rotational vitality by the sharp edges of the turbines and afterward into power by generators driven by turbines[1]. Various kinds of turbines utilized are Bulb turbine, Rim Turbine, Tubular turbine, Offshore Turbines and Vertical-Axis turbines [3][4]. The force accessible from the turbine at a specific moment is given by: Opening fitted with controlled entryways (Sluices): It is intended to pass enormous streams

Identify the Health / Medicine Problem Diabetes - 1375 Words

Identify the Health / Medicine Problem: Diabetes (Editing Sample) Content: IntroductionThe prevalence of diabetes has grown immensely over the years. According to the World Health Organization (WHO), over 400 million people have diabetes around the world (International Diabetes Federation 2015). This figure is projected to grow in the coming years. In the U.A.E, it is estimated that over a million people have diabetes. As noted by Abraham, (2015), 3% of all deaths reported in U.A.E are associated with diabetes. These statistics have forced the government to raise the alarm on the severity of diabetes. The U.A.E government is currently determined to fight the prevalence of diabetes through the help of various international bodies. Therefore, this paper will explore the issue of diabetes in U.A.E by focusing on the causes, solutions and the effectiveness of those solutions.Identify the problem:As noted earlier, the U.A.E has the highest incidence of diabetes that currently affects approximately 19% of the adult population (Abraham 2015). The f igure is according to the International Diabetes Federation that has collaborated with the U.A.E leadership to raise awareness on diabetes. Another study further estimates that by 2020 the percentage of adult population affected by diabetes is likely to increase to 35% (Rizvi 2016). The impact of such an increase is possible to cost approximately $8.5 billion if the prevailing trend persists. Studies have also shown that 70% of those who have diabetes are not in control of their medical condition. Such challenges are common, particularly among children and youths. Literature reveals that the number of deaths in the male population linked to diabetes is likely to increase to 17% and a whopping 32% among women (Saadi, et.al 2007).Causes:The incidences of diabetes are quite high in UAE. Most people in U.A.E who have diabetes are not aware of their medical condition, and thus they often seek for treatment when the condition has become severe. Saadi, et.al (2007), have identified five r easons that explain the high incidence of diabetes in the United Arab Emirates. The first cause that predisposes one to diabetes is obesity. Obesity is a condition associated with having excess weight due to unhealthy eating. Obesity is the leading cause of diabetes in most parts of the world. In U.A.E, for instance, approximately 60% of the population is considered obese due to excessive intake of food with high sugar and fat content. Based on recent research, about 36% of the UAE population are overweight (International Diabetes Federation 2015). Obesity is also a key contributing factor to various heart diseases.Secondly, physical inactiveness is also a primary cause of the prevalence of diabetes in UAE. As noted by Klautzer, Becker Mattke (2014), most people in the UAE rarely engage in physical exercise due to the hot weather condition. As such, the moderate activity rate predisposes them to diabetes since their bodies accumulate high sugar content. Physical exercises usually help the body to eliminate excess sugar in the blood and thus lowering the risk of developing diabetes. During physical exercises the body converts excess sugars to energy. The third cause of the growth in incidences of diabetes in UAE is the high intake of sugar diet among the population. Researchers report that most people in UAE prefer and often consume delicacies that have high sugar content. These delicacies often lead to the accumulation of sugar in the blood, and this increases the risk of developing diabetes.The fourth contributing factor of diabetes is smoking. The U.A.E is reported to have one of the highest numbers of smokers. As Klautzer, Becker Mattke (2014) note, smoking often speeds up the development diabetes. Habitual smokers are at a high risk of contracting diabetes. In Dubai, for instance, smoking is rampant in public places and social gatherings. The practice implies that nonsmokers are also prone to second-hand smoking, and this predisposes them to diabetes. Finally, as indicated by various scientific studies, Arabs, as well as a section of the world population, have an insulin resistance due to their genetic predisposition. As asserted by Imperial College London Diabetes Center (2011), a combination of the lifestyle aspects and the insulin resistance among most of the UAE population is a key contributing factor to the growth of diabetes incidences in the Middle Eastern country.Solutions:Some strategies are available that the government of UAE can utilize or has already used to fight the growth and prevalence of diabetes both among the adult and young population. First, the government in conjunction with Non-governmental institutions can raise awareness particularly among the adult population on the essence of healthy eating. As earlier mentioned, obesity results from the consumption of unhealthy foods such as junk foods and moderate physical activity. A study conducted in 2012 revealed that majority of the UAE population was aware of the potential effects of diabetes on their lives (Saadi, et.al 2007). However, the awareness differs across various social groups based on their education level. The study further revealed that the less educated population had little knowledge about their predisposition to diabetes about their lifestyle. As such, due to lack of awareness, the prevalence of diabetes is high among the less educated and low-income earners in UAE.Secondly, diabetes, obesity and other lifestyle diseases should be made a key public health priority in UAE. By doing so, the government will be in a position to put in place strong policy interventions to help curb the prevalence of diabetes. Good examples include policies that require employers to provide exercising amenities to their employees, a ban on foods with high-fat content in food joints and increased tax on sugary beverages and foods (Al-Maskari El-Sadig 2007). Though such policies may not be received well by a section of the population, they are likely to prevent the prevalence of diabetes. Finally, it is important to note that successful diabetes preventive effort should encompass both physical exercise and healthy eating. These efforts should be indoctrinated in the school curriculum since diabetes, and other lifestyle diseases are currently rampant among young adults and children. Teaching children and young adults the essence and benefits of healthy eating can help shape their lifestyle and thus they will be able to live a life devoid of health complication during their adult years. Physical exercise is an effective way of eliminating excess body fat and sugar. Recent researches conducted in UAE revealed that majority of the people that engage in physical activity still maintain unhealthy eating habits. As noted by Klautzer, Becker Mattke (2014) for physical exercise to be effective, it should go hand in hand with healthy eating habits.Effectiveness:Campaigns that raise awareness on diabetes and various lifestyle dise ases have proved useful in the reduction of diabetes in UAE (Klautzer, Becker Mattke, 2014). Ignorance is one of the key contributing factors of various lifestyle diseases. As noted earlier, the less educated are often less informed about their predisposition to diabetes as a res...

The General Average Act from the York Antwerp Rules - Free Essay Example

GENERAL AVERAGE General Average Act from the York Antwerp Rules is defined as à ¢Ã¢â€š ¬Ã…“Any extraordinary sacrifice or expenditure intentionally and reasonable in time of peril for the purpose of preserving the property imperilled in common maritime adventureà ¢Ã¢â€š ¬Ã‚  Terms to be considered Extraordinary Sacrifice or Expenditure Intentional Reasonable Peril Common maritime adventure EXTRAORDINARY This can be seen as something very unusual or remarkable, something that normally doesnà ¢Ã¢â€š ¬Ã¢â€ž ¢t happen. Now a loss must be à ¢Ã¢â€š ¬Ã‹Å"extraordinaryà ¢Ã¢â€š ¬Ã¢â€ž ¢ before it can be considered under general average. This is declared in York Antwerp Rules rule A and in the Marine Insurance Act section 66(2). This been said, losses made from ordinary voyage incidents cannot therefore bring about general average. It isnà ¢Ã¢â€š ¬Ã¢â€ž ¢t always easy to draw a line between extraordinary and ordinary, it all depends on the facts of the case. Example of cases: SociÃÆ' ©tÃÆ' © Nouvelle dà ¢Ã¢â€š ¬Ã¢â€ž ¢Armement v. Spillers Baker In 9171, the French barque Ernest Legouve was towed from Ireland to England across the Irish Sea during the First World War in order to reduce the danger of enemy submarines. The extra cost on towage wasnà ¢Ã¢â€š ¬Ã¢â€ž ¢t allowed as general average after taking the case to court because the risk of attack from the U-boats isnà ¢Ã¢â€š ¬Ã¢â€ž ¢t something extraordinary for a time of war. Robinson v. Price A ship had a leak and would sink without constant pumping out of the water. The ship used up all the fuel (coal) supplies she had because of this situation. On a usual voyage, this wouldnà ¢Ã¢â€š ¬Ã¢â€ž ¢t have been the case. So the shipà ¢Ã¢â€š ¬Ã¢â€ž ¢s spars and cargo had to be used as fuel in order to complete this voyage. This incident wasnà ¢Ã¢â€š ¬Ã¢â€ž ¢t a usual on the voyage therefore the cost of the spars and cargo used was allowed in general average. SACRIFICE OR EXPENDITURE Sacrifice can be defined as the act of letting something valued go for the sake of something considered as more important or worthy. Also, expenditure can simple be seen as money spent. Sacrifice in the context of general average revolves around cargo being jettisoned or used (most times used as fuel) in the voyage and expenditures on services or supplies. For this to be allowed as general average, this must happen in time of real danger (peril) or imminent risk of danger. Example of cases: The case Robinson v. Price previously discussed were the cargo was used as fuel in time of peril to keep water out of the ship to avoid sinking will definitely allow general average claims. Watson v. Firemanà ¢Ã¢â€š ¬Ã¢â€ž ¢s Fund Sophie Frankel in 1922, had a cracked steam pipe. Steam escaped from the fracture overheating the cargo (rosin) which gave off a vapour. The master confused the vapour for smoke and concluded that the hold was on fire. Steam was now put into the hold da maging the cargo and the cargo was damaged. General average wasnà ¢Ã¢â€š ¬Ã¢â€ž ¢t allowed on the sacrifice because there wasnà ¢Ã¢â€š ¬Ã¢â€ž ¢t any real danger. INTENTIONAL Something intentional can be seen as something deliberate, consciously done on purpose or something done voluntarily. The sacrifice or expenditure made must be voluntarily, and not a situation one couldnà ¢Ã¢â€š ¬Ã¢â€ž ¢t control. Taking an illustration of a fire incident on board. Any damage caused from the water used to extinguish the fire will be allowed under general arrange because the act of using the water was voluntary. The damage caused from the fire will be considered as partial average as the fire was an accident. But any damage caused from the smoke will not be allowed as general average since the smoke cannot be extinguished. Any voluntary act must be that of the master or authorised by him. Losses that come from an act forced on the master wonà ¢Ã¢â€š ¬Ã¢â€ž ¢t be allowed as general average Example of cases: Athel Line v. London and Liverpool Insurance In 1944 during the war, the Athelbeach and the Athelqueen were to take molasses from West Indies to the United Kingdom. Because of the fear of attack, they joined other vessels to form a convoy. The convoy commodore received a signal from the Admiralty that another convoy had been attached earlier, so he ordered the convoy back to Bermuda. Athel line vessels later made the voyage without the convoy. The cost incurred from the delay and deviation werenà ¢Ã¢â€š ¬Ã¢â€ž ¢t allowed as general average because from the defence regulations, the Admiralty and commodore has authority over the masters of the vessels and even the ship owners. Their acts werenà ¢Ã¢â€š ¬Ã¢â€ž ¢t voluntary but forced. It was a legal duty to obey the commodore. REASONABLE Something reasonable can also be seen as something sensible, having sound judgement or logical. Sacrifice or expenditure must also be reasonably made to be covered under general average. And unreasonably expensive way of solving a problem will certainly not be allowed as general average. If the masterà ¢Ã¢â€š ¬Ã¢â€ž ¢s act is done in the interest of all on the voyage, first considering life (crew and passengers), and then the vessel and cargo, then losses incurred will be allowed as general average even if the act is hazardous From The Seapool a ship at anchor was suddenly attacked by a gale and was faced with the risk of breaking her back and losing her propellers. The master engage in a very risky manoeuvre which was actually designed to get the ship out to sea and not exactly for a situation like this. All to avoid the gale. Though master was successful, the ship and pier were damaged. The decision the master made was reasonable enough and the losses made was allowed as gene ral average. PERIL Peril can be seen as serious danger, or an immediate risk or hazard. Every intentional and reasonable sacrifice must only be made in time of real danger for losses to be allowed as general average. If the master is wrong about a peril and takes an action, any losses generated from this act will not be considered under general average. Example of cases: Looking at a previously discussed case of Watson v. Firemanà ¢Ã¢â€š ¬Ã¢â€ž ¢s Fund in 1922, ità ¢Ã¢â€š ¬Ã¢â€ž ¢s clear that the reason why the losses made from the damaged cargo were not allowed as general average was because the danger which prompted the master to act didnà ¢Ã¢â€š ¬Ã¢â€ž ¢t exist. No real danger. The danger doesnà ¢Ã¢â€š ¬Ã¢â€ž ¢t really have to be immediate but it has to be real enough and also the possibility of it happening, very high. Like in this next case Vlassopoulos v. British and Foreign MI Co The vessel involved was taken to port to fix a fouled propeller. If that propeller wasnà ¢Ã¢â€š ¬Ã¢â€ž ¢t brought in for repair, it would have caused a problem or failed during a voyage. And the possibility of that happening was very high. A potential danger was avoided so therefore, the resulting expenses for the repair is allowable as general average. COMMON MARITIME ADVENTURE Any expenditure or sacrifice must be made for the safety of a common maritime adventure before it can amount to general average. Looking at the common maritime adventure, two conditions are considered. Firstly, sacrifices or expenditures made after an interest has been brought to safety cannot be allowed as general average. Case: Royal Mail Steam Packet v. English Bank of Rio de Janeiro A ship ran aground and a valuable but light weighted cargo of specie was removed into a lighter all for the purpose of preserving the cargo. Taking it that the cargo of specie got damaged. It was concluded that that specific cargo couldnà ¢Ã¢â€š ¬Ã¢â€ž ¢t come under general average because it didnà ¢Ã¢â€š ¬Ã¢â€ž ¢t contribute in any way to the refloating of the ship. Secondly, the ultimate success of the adventure is very important when considering general average. Case: Chellew v. Royal Commission for Sugar Supply A ship incurred port refuge expenses. And both the ship and ca rgo were lost, never making it to the discharge port. In this situation where no form of success was made, no claim in general average can be made in respect to those expenses made. REFERENCE Simon Baughen (2012) Shipping Law, 5th edition, Oxon: Routledge. Robert Grime (1991) Shipping Law, 2nd edition, London: Sweet Maxwell Limited https://www.google.co.uk/webhp?sourceid=chrome-instantion=1espv=2ie=UTF-8#q=sacrifice+meaning [12 Aug 2014].

The Evaluation of the Success of the European Monetary Union Free Essay Example, 2250 words

The Euro has managed to play a less external parity as compared to the various currencies that it eliminated. The introduction of the euro quickly transformed the European financial markets. For instance, government bonds were rapidly integrated into the bond market. A notable record of the growth of the corporate market was that of 1999 when an impressive rise of 300% was recorded in euro-denominated issuances. From 1999, the proportion that the euro acquired in the total outstanding international debt securities has been steadily rising from 21% to 31%. It is estimated that approximately a quarter of the entire foreign exchange reserves are currently in Euros (Chang, 1999 p. 18). Although the dollar is still regarded as the world s most vital currency, the euro has grown favorable to take second place, and the trend is expected to increase in the near future. The aspect of the European Monetary Union that has generated the worst publicity is the stability and growth pact. Contrary to the popular belief, the aspect was not part of the original plan that was created at the Maastricht Treaty. We will write a custom essay sample on The Evaluation of the Success of the European Monetary Union or any topic specifically for you Only $17.96 $11.86/page Recently, five European countries were subjects of the excessive deficit procedure. Only Greece, whose deficit ratio in 2004 was 6%, had a deficit ratio that was marginally above 3%. The treaty that gave birth to the European Monetary Union points out that, what really matters is the maintenance of the government's financial position.

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The Effects Of Caregiving On Stress And Immune Function

Caregiving In addition to disasters, chronic stress can also arise from changes in employment, social relationships, or financial condition. One well-accepted model of chronic stress is the burden of providing long-term care for someone with Alzheimer’s disease or other forms of dementia. Learning, memory, and cognitive function progressively decline in these patients, sometimes even to the point that the patient may no longer recognize his or her spouse. Many Alzheimer’s patients require constant care for years before they die. From the time of diagnosis, about half of the patients live for another seven to eight years, which creates a tremendous amount of strain on the caregiver who watches a loved one continue to deteriorate. Caregiving also makes it difficult to establish or continue supportive social relationships outside of the home and may create changes in employment or financial status. Janice Kiecolt-Glaser and her colleagues (1991) studied the effects of caregiving on stress and immune function and found that caregivers were more depressed and had poorer immune function than a control group of people with similar age, sex, and martial status. The effect of chronic stress on the immune system also likely accounted for why caregivers were also less likely to produce a sufficient number of antibodies to protect them against the flu virus after receiving a flu vaccination (Kiecolt-Glaser, Glaser, Gravenstein, Malarkey, Sheridan, 1996). Marriage Although beingShow MoreRelatedCaregiver Stress Essay1521 Words   |  7 PagesASC 4126 – The AIDS Pandemic Caregiver Stress Caregivers are those people who provide assistance to other people who are unable to perform certain activities on their own because of a physical disability or chronic illness. 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In the early stages, the most common symptom is difficulty in remembering recent events. When AD is suspected, the diagnosis is usually confirmed with tests that evaluate behavior and thinking abilities, often followed by a brain scan if available

Images of Blood in Faulkners Light in August Essay

Images of Blood in Faulkners Light in August Blood is considered by many to be one of the most important ties between human beings; it is therefore frequently used as an image that defines a character or a relationship between characters in a novel. For example, a prince might be defined by his royal blood, or a weak man described as having thin blood. Close friends may be blood brothers, or families may have a blood feud. In William Faulkners Light in August, the image of blood permeates the themes of sexuality, race, and religion. Blood is common to all of these themes: it is evident in reproductive cycles and births, it is a medium for the genetic passage of†¦show more content†¦During the experience, he ate most of the tube of toothpaste, and was caught by the would-be lovers when he vomited (Faulkner 122). Aside from associating the sex act with disgust and vomit, he developed the impression that the male is meant to incite fear in his female partner, and this idea influences his sexual encounters over the years. When Christmas first learns about menstruation from the boys he associates with as a young teen, he is disgusted by the thought of the physical ceremony, which is not a mental state, but physical, actual, to be discerned by the sense of smell and even of sight (Faulkner 185). Had the boy relating this information to Christmas not given him a graphic, tangible idea of the process of menstruation, Christmas would not have listened (Faulkner 185). However, once convinced of the possibility that the boys claim is true, Christmas performs his own ceremony, killing a sheep to immerse himself in the smell, sight, and feel of its blood: He found the flock in a hidden valley and stalked and killed one with the gun. Then he knelt, his hands in the yet warm blood of the dying beast, trembling, dry-mouthed, backglaring. Then he got over it, recovered. He did not forget what the boy had told him. He just accepted it. (Faulkner 185-186) The blood of the sheep providesShow MoreRelated Religious Symbols and Symbolism in Faulkners Light in August1555 Words   |  7 PagesReligious Symbolism in Light in August  Ã‚  Ã‚   William Faulkner’s, Light in August has many references to Christianity. He employs a great deal of religious symbolism in all of his characters. These parallels seem very intentional, even though, Faulkner himself says he did not do it purposely. The Christ story is one of the most popular stories invented and it seems right that at some point someone is going to write similar to it. William Faulkner says he did not put the Christian parallels inRead More Comparing Faulkners Light in August and James Portrait of a Lady2862 Words   |  12 PagesComparing William Faulkners Light in August  and Henry James Portrait of a Lady Light in August   and Portrait of a Lady are two novels which embodies within them, life affirming morals. Authors like William Faulkner and Henry James possess the art of making the reader learn by experiencing for themselves.   William Faulkner uses the technique of introspection as well as by showing how characters and their actions can affect one another. Henry James also shows that a character’s actions and decisionsRead MoreGenius Photography Notes: Right Place, Right Time3837 Words   |  16 Pagesunder my helmet. I held my cameras high over my head...and told myself, â€Å"I am just going to dry my hands on that boat.† Capa omaha beach1  Capa reached the landing craft, but as he hauled himself on board, there was an explosion that covered him in blood and feathers. The feathers had come from the sailors’ blown apart kapok jackets. Making his way across the bloody deck, he reached the engine room and dried his hands by the engine’s warmth.  Ã¢â‚¬Å"...put fresh film in both cameras. I got up on deck againRead MoreViolence on Television Does Not Impact Behavior Essay3474 Words   |  14 Pagesthe brutal rape and murder of a child by their parent? Perhaps the news contributes more than just an insightful knowledge of events. Perhaps Columbine copycats and school bomb threats may never have arisen if the entire world hadnt witnessed the blood-soaked terrors via cable television. An early study performed by Liebert and Baron in 1972 concedes that the willingness of a child to harm another child is increased by the intake of violence-charged television programming. Cartoon superhero con tributors

SENIOR FLASHBACK Essay Example For Students

SENIOR FLASHBACK Essay Time to Say GoodbyeBy Jamie WarrenThe future stretches before me, waiting for me to create the work of art that will become my life. We have entered an age for celebration, an era to memorialize who we were, who we are and who we will eventually become. Celebrate this milestone greater then all the others, for it is the time we have spent here in our high school careers that will always be held close to heart. Graduation is two weeks away, which for most of us does not seem possible. As we look back at these past four long but fulfilling years, there are some things that we shall never forget. Its hard to believe that at one point we were little freshmen entering into these doors, with no idea what was in store for us. Four years have passed since that first day, and we have made decisions that will frame our futures. After years of studying, filling out applications, scholarships, and taking tests, we are now thrown into the real world, where there are seldom retakes, second chances are only a memory of yesteryear, and honor codes are the way of life. As freshman, we came home from school with the mentality that we were no longer children, but rather had entered into a new stage of life.Everything seemed different and new; we werent the big kids on campus anymore. We no longer were the persons being looked up to, but rather were the persons looking up to an entire school of older students. We remember joining our firsts clubs, going to dances, and having Orientation days. ? Does wise fool mean anything to you? ?Junior year we had our first taste of authority; we had become upperclassmen. We gained new responsibilities and had to step it up in school. Times had surely begun to change. The days of complaining about dress codes and school sweaters had transformed into days chock-full of drudgery. College was in the near future, and things such as the SATs were on the horizon. We had our first prom, and some of us were in the midst of our first loves. As we look b ack on our high school careers, we shall take into consideration that most of the fondness incorporated with our time here is because of firsts. During our high school days, we underwent new and trying experiences. We fell in and out of love, grew to adults, and encountered trying times. We learned that we are neither invincible nor free from suffering, and bad things do happen to good people. Our times here can all be considered a learning experience, during which we discovered the value of friendship and the importance of individualism. At last, we have approached a knot in the path of life, the closing of one door and the opening of another. As seniors, we are facing the conclusion of our days here at Cross and the beginning of the rest of our lives. You may never again see those who are sitting next to you today, however you will always remember the tears you cried, the hugs you have shared and the smiles you have exchanged. As we face the conclusion of our youth and embark on our new journey into adulthood, we will confront innumerable challenges. This is not a time to dread, but rather it is a period of wonderment, an era of questioning, and a time for the fulfillment of dreams. When we face difficult times in college and life thereafter, we can always look back on our memories from high school. We will always cherish the thoughts of our firsts, classes, friends, and sports teams. .ud864e194576b6ae53c7f9f914b95a005 , .ud864e194576b6ae53c7f9f914b95a005 .postImageUrl , .ud864e194576b6ae53c7f9f914b95a005 .centered-text-area { min-height: 80px; position: relative; } .ud864e194576b6ae53c7f9f914b95a005 , .ud864e194576b6ae53c7f9f914b95a005:hover , .ud864e194576b6ae53c7f9f914b95a005:visited , .ud864e194576b6ae53c7f9f914b95a005:active { border:0!important; } .ud864e194576b6ae53c7f9f914b95a005 .clearfix:after { content: ""; display: table; clear: both; } .ud864e194576b6ae53c7f9f914b95a005 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .ud864e194576b6ae53c7f9f914b95a005:active , .ud864e194576b6ae53c7f9f914b95a005:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .ud864e194576b6ae53c7f9f914b95a005 .centered-text-area { width: 100%; position: relative ; } .ud864e194576b6ae53c7f9f914b95a005 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .ud864e194576b6ae53c7f9f914b95a005 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .ud864e194576b6ae53c7f9f914b95a005 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .ud864e194576b6ae53c7f9f914b95a005:hover .ctaButton { background-color: #34495E!important; } .ud864e194576b6ae53c7f9f914b95a005 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .ud864e194576b6ae53c7f9f914b95a005 .ud864e194576b6ae53c7f9f914b95a005-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .ud864e194576b6ae53c7f9f914b95a005:after { content: ""; display: block; clear: both; } READ: Shakespeare's Othello - The Motivations of Iago in EssayAll of our friends and teachers, who had made the transition into high school an easier one, shall yet again aid in this life metamorphoses. Remember, Your only successful when you reach your unreachable goals. Set your goals higher than you can reach, if you can already reach your goals then your not really reaching for anything at all.

Cybercrime and The Need of IT Security †MyAssignmenthelp.com

Question: Discuss about the Cybercrime and The Need of IT Security. Answer: Cybercrime and the need of IT security professional Cybercrime is an unlawful commotion concerning computer and network. There are certain fraud cases that may impose by the criminal activities. Internet-connected activities are susceptible to crime and guide to unfair treatment as efficiently as the common corporal crimes. IT security persons are the responsible people who can take care of those problems and create a solution to the people. IT professionals need to so efficient so that they can tackle every situation for the cybercrime victimization. IT professionals use antivirus software and install certain server to strengthen the security policy of the device (Kshetri 2013). IT professionals have done their best to provide the best security in the professional field of work to migrate the cybercrime issues. Role of computer forensic Computer forensic investigates on solving the cybercrime to mitigate the hacking or terrorism process through the computer. They are not only working over this but also maintain the resolving process of crime like murder, organized crime, tax evasion, drug smuggling, robbery cases and terrorism. The roles of computer forensic are Collecting criminal evidence. Technological support to analyze the matter. Law enforcement. Retrieve information. Take the efficient step to mitigate the process. Expertise technique to solve the case. Computers have been usually well-known for being used in committing a crime but as the position has twisted and forensics has the periphery of using computer forensics to grasp criminals who considered not being an impression when committing definite crimes (Grabosky 2015). Important of IT security policies There are some acts that imposed over the cybercrime policies. By imposing those acts a South African government can do their best to prevent this kind of situations. Under the provision sections of 2(1), 3(1), 5(1), 6(1) or 7(1) (a) or (d) any person has found guilty for the cybercrime issues. Most of the cases are intentional and they doing this cybercrime for the need of getting extra money by cheating. These all are the unauthorized manner from the personal point of view to trespass their personal data by the immoral process of entering. In case of computer program interference subsection 5(2) is being implemented in case of data storage contemplated by the section of 6(2). As the federal manner of constitution, the South African government has imposed the article 239 so that these cases can be mitigated. Some of the cases passwords, access codes are being hacked so that they can access personal data for to acquire and use those documents for the unethical use (Tsikrika et al. 20 17). A restricted computer system must be implemented so that no one can get into the personal data and acquire that. This is a safety policy imposed by the South African government for mitigating the cyber crime-related issues. Any individual who contravene the provisions of section 3(1) or (2), 4(1) or (2), 5(1), 6(1) or 7(1) is predisposed on conviction to a fine or to incarceration for a phase not more than 10 years or to in cooperation a fine and such incarceration. This is being implemented under the section of 275 Criminal Procedure Act. These policies are important to get control over the situation as South Africa has become the third highest cybercrime victimized nation. As the technological variety and innovativeness has imposed in the modern era of presentation thus with that process cybercrime has also created a web for the computer and devices. Cybercrime attack on NHS The cybercrime affect on NHS had devastated the technological barrier of UK cyber crime department. All the patient documents had lost and the doctors and surgeons were not found any evidence from the earlier report (Ganeshkumar, Arivazhagan and Sundaram 2013). They were not derived the more and that technological vulnerability of situation on that point of time had made an imperial attack on the NHS. In December it was reported that virtually all NHS trusts were using an outdated adaptation of Windows for which Microsoft had congested provided that security updates in April 2014. For that reason, an old system has introduced and created problems for the hospitals. All those important and relevant data were not found due to that cybercrime attack. References Fahey, E., 2014. The EU's cybercrime and cyber-security rulemaking: mapping the internal and external dimensions of EU security.European Journal of Risk Regulation,5(1), pp.46-60. Ganeshkumar, K., Arivazhagan, D. and Sundaram, S., 2013. Strategies of cybercrime: Viruses and security sphere.J. Acad. Indus. Res,2(7), pp.397-401. Grabosky, P., 2015. Organized cybercrime and national security. InCybercrime Risks and Responses(pp. 67-80). Palgrave Macmillan UK. Kshetri, N., 2013. Cybercrime and cyber-security issues associated with China: some economic and institutional considerations.Electronic Commerce Research,13(1), pp.41-69. Smith, R.G., Cheung, R.C.C. and Lau, L.Y.C. eds., 2015.Cybercrime Risks and Responses: Eastern and Western Perspectives. Springer. Tsikrika, T., Akhgar, B., Katos, V., Vrochidis, S., Burnap, P. and Williams, M.L., 2017, February. 1st International Workshop on Search and Mining Terrorist Online Content Advances in Data Science for Cyber Security and Risk on the Web. InProceedings of the Tenth ACM International Conference on Web Search and Data Mining(pp. 823-824). ACM.

The Use of Recycled Materials in Highway Construction an Example of the Topic Science and Technology Essays by

The Use of Recycled Materials in Highway Construction Introduction Today's world is faced with various emerging and challenging issues such as acceleration of world population which is increasingly facilitating the amounts and types of wastes generation during the production and consumption processes. There has been waste disposal crisis globally due to creation of non degradable or non decaying wastes, attributed to the growing consumer behavior. In response to this challenge, one of the solutions is the process of recycling the wastes into more useful products through research and innovation practices. Need essay sample on "The Use of Recycled Materials in Highway Construction" topic? We will write a custom essay sample specifically for you Proceed This has brainstormed individuals, private organizations and highway agencies to develop and implement wastes application through analyzing the feasibility, performance, and environmental suitability of reuse of the wastes and more so in highway construction. Highway construction is an expansive project but use of waste products in this industry makes the undertaking a cost-effective process, thereby ensuring safe and economic use of waste materials (Horan, Gifford, 2001, 9). Commonly used recycled materials One of the waste materials widely used in highway construction is recycled plastics. Virgin polythene is used as an additive or component to asphalt concrete and asphalt cement additive. When sandwich bags and plastic trash are recycled, a recycled low density polyethylene resin is obtained that is used to manufacture both cement and concrete asphalts in form of pallets. Recycled plastic can also be used in the manufactured of Portland cement concrete through use of recycled high density polyethylene which replaces fine aggregate with light weight concrete. After application of these recycled plastics in the construction process, flexural toughness of the concrete increase, compressive strengths are maintained and impact resistance of the concrete improves generally. Guardrail, a product of recycled wood and plastics has been brought forth to replace block in construction of guardrail posts. This facility is cheaper compared to the use of conventional block materials. The end product is also of high quality because they increase resistance against damage and deterioration, thus achieving reduction in overall life cycle cost. Noise pollution has also emerged in the processes of production around the globe, causing health, brain and social problems. To evade this, noise walls made from recycled rubber and plastics have been developed. The shell of the wall is made of thermosetting, a byproduct of glass and polyester. The fill section of the wall is composed of ground, rubber tires and recycled plastics (Tibbets, 2002, 12). In the developed and industrialized nations, glass is one of the waste products released in high quantities. It is later recycled to cullet, a component in the glass manufacturing industry. In the construction field, glass can be used as an aggregate in the asphalt pavements or asphalt base courses which satisfactorily serve the normal conventional pavement functions. Glass cullet has been approved for characteristics such as permeability, gradation, compaction, durability, specific gravity, thermal conductivity, and their strength and workability as an aggregate in the construction processes. In addition, recycled glass is being used in the manufacture of glass beads which are used as traffic control devices (Tibbets, 2002, 14). According to Carpenter (2001, 19), "the combustion process is common and widely used in production and in the day to day activities. This happens mostly during coal combustion which releases wastes like fly ash, bottom ash and combined ash. Among other residues, ash is produced, especially when municipal solid wastes are burnt or depending on the type of coal burnt". This ash is characterized by different physical and chemical aspects of toxicity and leaching ability. When coal containing sulfur is burnt, sulfur dioxide is released. This calls for use of scrubbers to reduce the amount of sulfur dioxide used. Bottom ash or slag is larger with heavier particles that are found at the bottom of hopper after the combustion process, and complies with environmental standards of toxicity. Bottom ash has sufficient engineering properties and uses. It has been used as aggregate for light weight concrete, sandblasting abrasive and as an abrasive in pavement deicing products and materials. Combined ash is the product of mixing both fly and bottom ashes, which are placed in landfills. Depending on the type of plant and coal source, it physically includes gradation, specific gravity and loss on ignition. Combined ash is used as partial fine aggregate replacement in the asphalt concrete mixes. Fly ash contains higher percentage of heavy metals such as cadmium and lead, leachate and other acidic components. In highway construction, incinerator residue is used as a partial aggregate substitute in the asphalt concrete base course. The performance of the substitute is equal to the conventional asphalt pavements (Carpenter, 2001, 21). Ash can also be used in stabilized and unstabilized bases and sub-bases as an aggregate, because the original components are aluminium oxide, iron oxide, calcium oxide and silicon oxide. In the process of highway construction, coal fly ash can be used as mineral admixture to Portland cement concrete, road base stabilization, roller compacted concrete and soil stabilization. Ponded fly ash has also performed well as a component in stabilized aggregate base course. This kind of ash is first sluiced into a disposal pond. Tests have shown that this experimental mix outperforms conventional mix and the rutting rate is significantly lower. Results from the various applications show that cement-treated ash produce higher density and compressive strengths compared to conventional soil cement. Leaching tests upon cement-treated ash have shown compatible and accommodative levels of cadmium, lead and copper that meet legal drinking water specifications of various agencies (Foster, 2008, 13). Highway related applications show a wide use of crumb rubber modified asphalt, which has good performance and environmentally friendly. Recycled rubber tires in combination with recycled plastics are recently being employed in making of noise walls' lightweight fill, channel slope protection, sub grade insulation and as an additive to the Portland cement concrete pavement. Ground scrap tires are also used in manufacturing Portland cement concrete. This happens when scrap tires are processed by removing the loose steel and fibers, which are finally ground. The ground rubber then acts as a substitute for fine aggregate. However, when high amount of rubber is used, the flexural and compressive strengths decrease. Gravel surfaced roads in most times experience severe deterioration in seasons of spring thawing because of frost penetration from beneath. To counteract this scenario, tire chips have acted as effective insulation layers against the frost. Its performance has been approved by use of resistivity gauges, groundwater monitoring wells, weather station and thermocouples. Recycled tires can also be used to make blocks for constructing retaining walls and landscaping. Through recent technology, scrap tires can be converted into a form for making stakes or poles. The tires are split and flattened, rolled in a spiral fashion and finally form almost solid log of reinforced rubber material (Foster, 2008, 15). Carpet industries around the world also produce carpet waste fibers. These fiber wastes have been incorporated in the manufacture of alphalt pavements and Portland cement concrete. Recycled fibers obtained from old carpets can also be used for concrete reinforcement, when the fibers are mixed with concrete in standard drum mixer. Flexural and compressive strengths comparison between concrete free of fibers and concrete with a percentage of virgin polypropylene fibers indicate good appreciable effects markedly handle the issue of compressive strengths. The toughness indices indicate that the more the amount of carpet used, the higher the concretes energy absorption abilities. On this same field, waste nylon fibers can be used to reduce the level of plastic shrinkage cracking. This is performed when the fibers are packed in water soluble bags and latter added to fresh concrete in the time of mixing. There is no observed or suggested difference from the conventional concrete with reference to flexural and compressive strengths. Increased addition of nylon fibers into Portland cement concrete panels proportionately reduces the plastic shrinkage and heating. This is because when nylon fiber is used in construction and heating panels, the rate of radiation increases and thus helps in prevention of cracking. Recycled fibers have also been proved to be increase efficiency when used in dense graded asphalt mix and polymer modified. Tests made on these include resilient modulus test, indirect tensile strain, lottman stripping tests and indirect tensile stress. According to these tests, there is no appreciable deviation from the performance of commercially available fibers. In the real application, addition of asphalt is primarily required to coat the surface area of those fibers compared to the thickness of the fiber films (Allen, 1998, 10). Another waste known as roofing shingle waste can be used in the make of asphalt pavements. When they are added to dense graded mixes, they result to a reduction in optimum content of neat binder, develop and enhance the ability to densify under compaction, increasing the component of plastic strain in permanent deformation measurements. It also reduced cold tensile strengths, of which the impact was determined by the type of shingle waste and grade of asphalt cement. However addition of more roofing shingle wastes reduced the potentiality for thermal tracking. The same material can be used in stone matrix asphalt mixes, which results to an admirable content of neat binder content. Shingles are ground uniformly to resemble coffee grounds and then added to drum mix plant to undergo a recycling process for the construction of asphalt pavement. So far, no pavement construction performance has been reported or detected since the recycling process commissioned. Old roofing material is also applied when making asphalt cold patch, which lasts three months more than the conventional cold patch material (Allen, 1998, 22). Flue gas desulphurization waste is another common waste. In the highway construction network, it is used in stabilized road bases to act as an embankment and pavement material. It is trusted to make dry weight of great early strength and high sulfate resistant Portland cement. So far, there is no any evidence of physical deterioration associated with the use of the waste as waste embankment. According to current researches, some materials have been categorized to compose the best set of wastes to use in highway construction. Such materials include rubber tires, recycled plastics, roofing shingle wastes, glass, carpet fibers, municipal solid waste combustion ash, blast furnace, steel slags, coal ash byproducts, fly ash, FGD waste and bottom ash (Horan, Gifford, 2001, 11). In larger part of the world, there is an increasing concern on the public, federal government, state regulators and industries to explore, invent and develop the use of recycled materials in the highway environment. Although this is an historical process, it is still new in the developing countries. The use, management and regulation of recycled materials is usually jurisdictional, a role attached to state transport and environment agencies. Most of the by-product materials are generated in the transport sector, municipal sector, industrial sector and mining sector. The wastes released from the transport sector include reclaimed asphalt and Portland cement concrete pavements, street sweepings, dredge materials and excess fill. Materials from industrial sector include blast furnace slag, nonferrous slags (phosphate, copper, and zinc), steel slag, coal combustion residues (fly ash, boiler slag, bottom slag, and flue gas desulphurization wastes), kiln dusts (lime-kiln and cement), baghouse dusts (smelters and asphalt plants), slags and foundry sands. Materials from municipal sector include biosolids, scrap tires, waste glass, wood waste, roofing shingle scrap, wastewater sludge ash, petroleum contaminated soils, municipal solid waste combustor residues, demolition and construction debris. Materials from the mining sector include quarry waste, mill tailings and phosphogypsum. These materials are used to replace conventional ones in fabrication of highway appurtenances like guardrails, signs and bridges, used as substitutes for pavement structure, as supplementary and aggregates cementitious materials especially in asphalt and Portland cement concrete, stabilized base and subbase or granular, fill, landscaping materials and as substitute embankment (Tibbets, 2002, 16). Mining industry generates high amounts of by-product materials, inaccessibility of mining operations with respect to the major metropolitan zones where demand for highway construction is high and there exist deficiency. This fact limits the potentiality of using large amounts of these resources widely. Conclusion In conclusion, the world faces and will continue to face environmental conservation problems due to cultural, economic, social and political diversity. The aspect of cooperative advantage is driving environmental conditions far from the safe side because countries are utilizing the available resources ignoring chances of possible harm to the rest of the world. The changing consumer behaviors and competition is calling for hi-tech production means, thus employment of production means which are harmful to the atmosphere. The problem has not been the emissions, but the disposal mechanisms. Existing landfills are filling up. One solution to this mayhem is to develop and implement beneficial uses for the residues. Highway construction uses great amounts of diverse wastes. Emphasized use of residue byproducts in lieu of virgin materials relieves disposal burden and avail inexpensive and advantageous construction products. Most of the waste materials used in the highway construction have limited applications in other fields to an extend that only such constructions can utilize those particular wastes. Again, most of them are non degradable and non-decaying such that they are very harmful to the environment and accumulation of such can extend adverse impacts upon the lives of individuals (Carpenter, 2001, 27). Therefore, use of recycled materials in highway construction should be imposed and implemented by all nations to contain the wastes disposal crisis threatening the world. Work Cited Allen Hershkowitz. In Defense of Recycling. Social Research, Vol.65, 1998, pp.10, 22 Carpenter Titus. Environment, Construction and Sustainable Development- Vo.1. New York, John Wiley and Sons, 2001, pp.19, 21, 27 Foster Mark. Looking beyond the Highway: Dixie Roads and Culture. Journal of Southern History, Vol.74, 2008, pp.13, 15 Horan Thomas & Gifford Jonathan. New Dimensions in Infrastructure Evaluation: The Case of Non-Technical Issues in Intelligent Vehicle-Highway Systems. Policy Studies Journal, Vol.21, 2001, pp.9, 11 Tibbets John. Under Construction: Building a Safer Industry. Environmental Health Perspectives, Vol.110, 2002, pp.12, 14, 16

Introduction to Concept Analysis Essay Topics

Introduction to Concept Analysis Essay TopicsIf you are going to college for a business degree, and you want to get your degree on the fast track, you will want to consider taking an online business course so that you can write your Concept Analysis Essay, which is a fundamental part of almost all business courses. It is important that you understand what this section of your degree requires of you, so that you can understand the nature of the work that you will be expected to do. This article looks at the concept analysis essay topics that you should study before you start your first year of college.The overview section of the essay is one of the more popular topics to cover in your first year. This section is really designed to give you an overview of your course and the material you will be studying. It is also supposed to introduce you to a few of the more complicated concepts that you will need to work on throughout your college career. By the time you get through the overview, you should be reasonably confident that you know the basics of your course.The analysis essay, as its name suggests, is what it sounds like. It involves the use of an analysis tool, such as a chart/grapher, to give a detailed account of the entire course material. It is usually used to compare two things. By the end of the analysis, you should have a sense of what has been covered in the course. This allows you to move on to the next set of course material and also help you to keep an overall idea of how your course will be different from what has been done in the past.The literature review essay is another basic topic that you should study in your first year. As its name suggests, it is used to look at one or more pieces of literature, and find out if they provide useful information about the subject that you are studying. It should be easy for you to identify where there is solid data and where there is not. This is a great way to get a general understanding of the topic that you are studying.The overview essay is the broad overview of the topic and describes what the subject means to you and your experience in the course. You should be able to discuss the concepts that pertain to the scope of the course, and be able to demonstrate how it applies to your life. You will also need to write about the techniques that will be used to study the material, as well as the ways in which you will be able to apply these to your own life.The overall purpose of the overview essay is to give you a generalized sense of the topic that you are studying. This gives you a basic idea of the types of material that you will be looking at in the course, and it gives you a general idea of what is being taught. You should include some examples of ways in which the topic pertains to your life in order to give you a feel for the type of discussion that will be required in the real exam. For this reason, you should use a descriptive word such as 'is' in your analysis essay.Your analysis essay should also give you a good idea of what you will be expected to do in the course. You should summarize the basics but also explain how they relate to the rest of the course. You should make sure that you follow up on any major ideas that you present in your summary.A good writing style is essential if you want to be successful in this type of course, so make sure that you are using the right tools for the job. The first year of study in business is not one that you can afford to slack on. You must make the most of your college experience, because the opportunities are only going to increase as you move on to the next level.

The First American Political Conventions

The First American Political Conventions The history of political conventions in America is so long and steeped in lore that its easy to overlook that it took a few decades for nominating conventions to become part of presidential politics. In the early years of the United States, presidential candidates were usually nominated by a caucus of members of Congress. By the 1820s, that idea was falling out of favor, helped along by the rise of Andrew Jackson and his appeal to the common man. The election of 1824, which was denounced as The Corrupt Bargain, also energized Americans to find a better way to select candidates and presidents. After Jacksons election in 1828, party structures strengthened, and the idea of national political conventions began to make sense. At that time there had been party conventions held at the state level but no national conventions. First National Political Convention: the Anti-Masonic Party The first national political convention was held by a long-forgotten and extinct political party, the Anti-Masonic Party. The party, as the name indicates, was opposed to the Masonic Order and its rumored influence in American politics. The Anti-Masonic Party, which began in upstate New York but gained adherents around the country, convened in Philadelphia in 1830 and agreed to have a nominating convention the following year. The various state organizations chose delegates to send to the national convention, which set a precedent for all later political conventions. The Anti-Masonic Convention was held in Baltimore, Maryland on September 26, 1831, and was attended by 96 delegates from ten states. The party nominated William Wirt of Maryland as its candidate for president. He was a peculiar choice, especially as Wirt had once been a Mason. The National Republican Party Held a Convention in December 1831 A political faction calling itself the National Republican Party had supported John Quincy Adams in his unsuccessful bid for reelection in 1828. When Andrew Jackson became president, the National Republicans became a devoted anti-Jackson party. Planning to take the White House from Jackson in 1832, the National Republicans called for its own national convention. As the party was essentially run by Henry Clay, it was a foregone conclusion that Clay would be its nominee. The National Republicans held their convention in Baltimore on December 12, 1831. Due to bad weather and poor traveling conditions, only 135 delegates were able to attend. As everyone knew the outcome ahead of time, the real purpose of the convention was to intensify anti-Jackson fervor. One noteworthy aspect of the first National Republican Convention was that James Barbour of Virginia delivered an address that was the first keynote speech at a political convention. The First Democratic National Convention Was Held in May 1832 Baltimore was also chosen to be the site of the first Democratic Convention, which began on May 21, 1832. A total of 334 delegates assembled from every state except Missouri, whose delegation never arrived in Baltimore. The Democratic Party at the time was headed by Andrew Jackson, and it was obvious that Jackson would be running for a second term. So there was no need to nominate a candidate. The ostensible purpose of the first Democratic National Convention was to nominate someone to run for vice president, as  John C. Calhoun, against the backdrop of the Nullification Crisis, would not be running again with Jackson.  Martin Van Buren of New York was nominated  and received the sufficient number of votes on the first ballot. The first Democratic National Convention instituted a number of rules which essentially created the framework for political conventions that endures to the present day. So, in that sense, the 1832 convention was the prototype for modern political conventions. The Democrats who had gathered in Baltimore also agreed to meet again every four years, which began the tradition of Democratic National Conventions that extends to the modern era. Baltimore Was the Site of Many Early Political Conventions The city of Baltimore was the location of all three political conventions prior to the 1832 election. The reason is fairly obvious: it was the major city closest to Washington, DC, so it was convenient for those serving in the government. And with the nation still mostly positioned along the east coast, Baltimore was centrally located and could be reached by road or even by boat. The Democrats in 1832 did not formally agree to hold all their future conventions in Baltimore, but it worked out that way for years. The Democratic National Conventions were held in Baltimore in 1836, 1840, 1844, 1848, and 1852. The convention was held in Cincinnati, Ohio in 1856, and the tradition developed of moving the convention to different locations. The Election of 1832 In the election of 1832, Andrew Jackson won easily, garnering about 54 percent of the popular vote and crushing his opponents in the electoral vote. The National Republican candidate, Henry Clay, took about 37 percent of the popular vote. And William Wirt, running on the Anti-Masonic ticket, won about 8 percent of the popular vote, and carried one state, Vermont, in the electoral college. The National Republican Party and Anti-Masonic Party joined the list of extinct political parties after the 1832 election. Members of both parties gravitated toward the Whig Party, which formed in the mid-1830s. Andrew Jackson was a popular figure in America and always stood a very good chance of winning his bid for reelection. So while the election of 1832 was never really in doubt, that election cycle made a major contribution to political history by instituting the concept of national political conventions.

ECON 4020-001 - Intermed Macroecon Essay Example | Topics and Well Written Essays - 500 words

ECON 4020-001 - Intermed Macroecon - Essay Example Davidson suggests that US increased the national debt during wars and recessionary periods because during those times only spender is government. The spending by the government therefore stimulates the necessary domestic demand which creates more jobs and increases the consumption. He provides evidence of how large deficits by the government during war and recessionary times actually were followed by periods of economic prosperity as well as job creation. Era after World War II was an era which was economically more prosperous than the times before war and one of the most important reasons for this was the government spending during war times by the US government and resulting large deficits. Davidson therefore suggests that actual task of fiscal policy is to act as a balancing wheel to generate sufficient aggregate demand which can stimulate entrepreneurs to create new jobs and deter from imposing or raising taxes to reduce the fiscal deficit and remove the role of government from the economy. Robert J Barrow’s article â€Å"Robin Hood Cant Lead Us Out of the Debt Hole: Obamas obsession with higher tax rates on the rich is not helpful† however focuses upon the argument of raising marginal taxes for rich in America to finance the fiscal deficit of the country. Barrow suggests that the current government in US may be missing the point that by increasing the government expenditure, multiplier effect can have a positive impact on the economy. He presents the recent historical analysis of the financial crisis and how the government actually allowed Lehman Brothers to fail to actually initiate a systematic failure of important institutions. Barrow therefore argues that rather than taxing the rich, the overall composition of the federal government needs to be changed. Government shall increase the maximum age limit for the entitlement of the social security as well as further rationalize the federal government

Modern pricing models Essay Example | Topics and Well Written Essays - 250 words - 1

Modern pricing models - Essay Example Some of the shortcomings experienced with the Black-Scholes model were strike-price bias and return skewness. Consequently, the development of the Heston model came in as the best alternative tool for the purposes of advanced investments (Gilli, Maringer & Schumann 2011, p.257). As any other stochastic volatility model, the Heston model utilizes statistical methods when making calculations or forecasts of the various pricing options in consideration. As such, it also bases on the assumption that the underlying security or trading option has an arbitrary volatility. Therefore, the Heston model falls among the various different models of stochastic volatility such as the GARCH model, the Chen model, as well as the SABR model. Consequently, the Heston Model also falls under the standard smile model category, with â€Å"smile† in this concept referring to the volatility smile. A volatility smile is a graphical representation of various options that have identical expiration date expressing an increasing volatility. This increase in volatility arises often arises when the options become more out of the money or in the money. The concave shape generated by the graph is what gives rise to the name, the smiles model, as it appears like a smile (Wang 2007, p. 3). The Heston Model applies mathematical calculations in describing the process of evolution in volatility that an underlying asset undergoes under the stochastic volatility options. As such, just as other statistical models mentioned above, the Heston Model equally has a number of assumptions, such as the volatility of an asset not being constant, or deterministic, but rather following a random process. Some the of the basic assumptions of the Heston Model is that the stochastic process determines the asset price, St In addition, forms part of the Wiener Process as experienced under the GBM (Geometric Brownian Motion) also considered

There could be a trouble ahead Article Example | Topics and Well Written Essays - 250 words

There could be a trouble ahead - Article Example From the article, it is clear that different economists have diverse opinion on the way to manage economic crisis. Whereas some argue that expansionary measures are the best to undertake, others view contraction measures feasible in correcting economic anomalies. Whichever the policy adopted, the end result should be recovery of the slow pace of growth (Chinn & Frieden, 2011). The article further compares the mitigation strategies pursued by different economies and the way they messed in the process. From the article, the author tries to justify his version that the lessons learnt in the 1930s depression helped in salvaging the 2008 economic depression. The author elucidates this by giving figures of the rate of unemployment, interest rates, currency rates, and contagion caused in the financial markets in both the depression and the recession (1936, 1938). From the analysis, it is evident that the expansionary policies that were employed in 2008 recession had better impacts than the contractionary policies in the 1930s recession (Krugman, 2009). In all instances, monetary policy was important in controlling the supply of money, exchange rates fluctuations and bringing smooth operations of the financial market. Fiscal policies were also crucial in stimulating growth hence increasing rate of employment and investment (2009). Debt management and control must also be checked in managing the depression. The fact that the author has extensively and concisely dissected the comparison makes me agree that the article is right. The facts have been well substantiated with figures and correct economic theories and knowledge. In my opinion, the periods of recession and depressions demands policies that stimulates growth and controls the level of debt while keeping the financial sector sound. In conclusion, Obama’s administration learned from the failure of the Roosevelt regime thus

Asher Lev :: essays research papers

Asher Lev This story is about a Jewish boy from Brooklyn, who’s talent is painting. He introduces himself as a young man struggling with inner conflict between his religious upbringing and his extraordinary God-given gift that cannot be controlled and seems to possess a spirit all it own. He can not explain why he feels he must paint, and does not like the fact that he hurts everyone he loves, and insults everything he believes in, but continues on his path which seems to have been chosen for him. All throughout the book we see the conflicts between Asher and his family, and grow a hatred towards his father, even though he is a good man and respected highly in the community. As a young boy Asher is told by his father who seems to think that his artistic ability is foolishness and that he needs to focus his attention on his school work. We tend to like his mother, Rivkeh, because, even though she says she doesn’t want Asher to paint, we know that deep down she knows art is where his heart is, and it is the only thing that makes him happy. We can relate with her as she stands by the window worrying and wondering when her loved ones will be home. Asher does not get very much encouragement from other people until he meets the world famous Jacob Kahn, who becomes his inspiration, his teacher, and his link to the great work of art. The two meet at the Rebbe’s office. This meeting was not accidental. It was set up by the Rebbe, who Asher was not very fond of because he is sending his father to Vienna. The Rebbe understands Asher better than his parents do. He knows that Asher has this talent, and wants him to per sew it. When Asher’s dad goes away to Vienna, his mom stays back in Brooklyn with him in hopes that he will studyhard. He studies enough to get by, but still brings to life everything he sees. Jacob Kohn teaches Asher how to become a great painter, cautioning him what he is getting into. As Asher becomes Asher Lev the painter, instead of the son of Reb Aryeh Lev, his father becomes curious and wants to go to one of his shows. Aryeh wants to see some of his work but refuses to go if there are nude paintings.

Tropical Hut

WORKING CAPITAL Working capital is a measure of liquidity of a business. It equals current assets minus current liabilities. It is a measure of both a company's efficiency and its short-term financial health. The Company’s working capital during 2011 and 2010 are -P61,608,166. 00 and -P48,921,660. 00 indicating that the Company’s current liabilities are more than its current assets. It tells that the company is expected to suffer from liquidity crunch in near future and that the business may not be able to pay off its current liabilities when due. Status: Weakness of the Company) LIQUIDITY RATIOS| | | | | | Notes| Status| 2011| 2010| Current Ratio| 1| Weakness| 0. 83:1| 0. 85:1| Quick Ratio| 1| Weakness| 0. 37:1| 0. 39:1| Liquidity ratios measure a firm’s ability to meet maturing short-term obligations. Current ratio measures the extent to which a firm can meet its short-term obligations. During 2010, the Company’s current ratio is 0. 85:1 which indicates that the Company’s current assets were not enough to pay its short-term obligations. During 2011, the Company’s current ratio decreases to 0. 3:1 which indicates that its ability to pay its short-term obligations became worse (see Note 1 for computation). Quick ratio measures the extent to which a firm can meet its short-term obligations without relying upon the sales of its inventories. During 2010, the Company’s quick (or acid-test) ratio is 0. 39:1 which shows that its current assets less its inventory is not enough to meet its short-term obligations. During 2011, the Company’s quick ratio decreases to 0. 37:1 which shows that its ability to meet its short-term obligations became worse (see Note 1 for computation).Therefore, Tropical Hut Food Market, Inc as of December 31, 2011 and 2010 is not liquid. LEVERAGE RATIOS| | | | | Notes| Status| Ave of 2011;2010| Debt-to-Total-Assets Ratio| 2| Strength| 0. 56| Debt-to-Equity Ratio| 2| Weakness| 1. 29| Long- Term Debt-to-Equity Ratio| 2| Strength| 0. 0007| Times-Interest-Earned Ratio| 2| Weakness| -19. 36| Leverage ratios measure the extent to which a firm has been financed by debt. Debt-to-Total-Assets Ratio is the percentage of total funds that are provided by creditors. The average Debt-to-Total-Assets Ratio during 2011 and 2010 is 56% (or 0. 6:1) which indicates that the Company is capable to meet outside obligations in full out of its own assets (see Note 2 for computation). Debt-to-Equity Ratio is the percentage of total funds provided by the creditors versus by owners. The average Debt-to-Equity Ratio during 2011 and 2010 is 129% (1. 29:1). This means that for every peso of the company owned by the shareholders, the company owed 1. 29 to creditors. This high debt-to-equity ratio indicates that the Company was not able to generate enough cash  to satisfy its  debt  obligations (see Note 2 for computation).Long-Term Debt-to-Equity Ratio is the balance between debt and equity in a firm’s long-term capital structure. It expresses the degree of protection provided by the owners for the long-term creditors. The average Long-Term Debt-to-Equity Ratio during 2011 and 2010 is . 07% (or 0. 0007:1) which indicates that the Company’s degree of leverage is low (see Note 2 for computation). Times-Interest-Earned Ratio is the extent to which earnings can decline without the firm becoming unable to meet its annual interest costs. The Company’s Times-Interest-Earned Ratio is -19. 6 due to consecutive years of net loss which indicates that the Company was not able to meet its annual interest costs. ACTIVITY RATIOS| | | | | Notes| Status| 2011| 2010| Inventory Turnover| 3| Weakness| 8. 08 | 9. 38| Fixed Assets Turnover| 3| Strength| 10. 88| 10. 19| Total Asset Turnover| 3| Weakness| 3. 06| 3. 32| Accounts Receivable Turnover| 3| Strength| 77. 43| 64. 01| Average Collection Period| 3| Strength| 4. 71| 5. 70| Activity ratios measure how effectively a firm is using its resources. Inventory turnover ratio is used to measure the inventory management efficiency of a business.The Inventory ratio for the year 2011 and 2010 are 8. 08 and 9. 38, respectively. The decreased in the Inventory Turnover ratio indicates that the company is inefficient on controlling their inventory levels (see Note 3 for computation). The fixed-asset turnover ratio measures a company's ability to generate net sales from fixed-asset investments. The Ratios are 10. 88 and 10. 19 for the year 2011 and 2010. The increase in the turnover ratio indicates that the company can generate more sales with its fewer assets which tell that the company is good because it is using its assets efficiently (see Note 3 for computation).The total asset turnover ratio measures the ability of a company to use its assets to efficiently generate sales. The ratios are 3. 06 and 3. 32 for the year 2011 and 2010. The decrease in the turnover ratio indicates that the company is not growi ng in its capacity (see Note 3 for computation). Accounts receivable turnover measures the efficiency of a business in collecting its credit sales. The Accounts Receivable Turnover for the year 2011 and 2010 are 77. 43 and 64. 01, respectively.Increase in the accounts receivable turnover indicates improvement in the process of cash collection on credit sales of the company (see Note 3 for computation). Average collection period measures the average number of days that accounts receivable are outstanding. The Average collection period for 2011 and 2010 are 4. 71 and 5. 70, respectively. The decreasing number of collection days indicates that the accounts receivable of the company is liquid and is being converted to cash quickly compared to the previous year. PROFITABILITY RATIOS| | | | Notes| Status| 2011| 2010| Gross Profit Margin (GPM)| 4| Strength| 30. 4%| 28. 44%| Operating Profit Margin (OPM)| 4| Weakness| -2. 90%| -2. 21%| Net Profit Margin (NPM)| 4| Weakness| -2. 48%| -1. 75%| Return on Total Assets (ROA)| 4| Weakness| -7. 59%| -5. 80%| Return on Shareholders' Equity (ROE)| 4| Weakness| -18. 56%| -12. 52%| Earnings Per Share 4 Weakness -19. 68% -15. 28% Profitability Ratio measure management’s overall effectiveness as shown by the returns generated on sales and investment. Gross Profit Margin is the total margin available to cover operating expenses and yield a profit.During 2011 and 2010 the GPM’s are 30. 24% and 28. 44% respectively which indicates that the company has a reasonable profit margin but it cannot cover up all of its expenses resulting to a net loss (see Note 4 for computation). Operating profit margin is the profitability without concern for taxes and interest. The 2011 and 2010 OPM’s are -2. 90% and -2. 21% respectively. Thus, indicating that the company has poor cost control and/or that sales are insufficient to cover up COS and expenses (see Note 4 for computation). Net profit margin is the profitability after tax a nd interest.The 2011 and 2010 NPM’s are -2. 48% and -1. 75% respectively. This shows that the sales of the company is decreasing with a poor management of expenses (see Note 4 for computation). Return on total assets an indicator of how profitable a company is relative to its total assets. The 2011 and 2010 ROA’s are  -7. 59% and -5. 80% respectively. Thus management is inefficient in using its assets to generate earnings (see Note 4 for computation). Return on Shareholder’s Equity measures a corporation's profitability by revealing how much profit a company generates with the money shareholders have invested.During 2011 and 2010 the ROE’s are -18. 56% and -12. 52% respectively. Thus, indicating that the company is not generating profit by the investment of the shareholders but instead incurring a loss. Earnings Per Share is the earnings per each outstanding share. The 2011 and 2010 EPS are -19. 68% and -15. 28% respectively. Since EPS in considered as one of the factors that an investor considers, it implies that issuance of shares will not generate more money thus, less attractive (see Note 4 for computation). GROWTH RATIOS | Notes| Status| Ratio| |Growth Ratio on Sales| 5| Weakness| -13. 13%| Growth Ratio on Net Income| 5| Weakness| * -20. 06%| Growth Ratio on EPS| 5| Strength| 22. 26%| Growth Ratio on Dividends Per Share| 5| Weakness| -3. 502%| Growth ratio indicates the amount by which a variable increases over a given period of time as a percentage of its previous value. The growth ratios for Sales, Net income, Earnings Per Share, Dividends per Share are -13. 13%, -20. 06%, 22. 26% and -3. 502% respectively. Growth Rates are one of the factors that investors consider in order to extend their resources to generate future cash flows.It indicates that the company’s sales, earnings have not grown that would make its firm value less attractive. Also, it evaluates that the company was not performing good enough in order to generate sales, earnings and returns, hence, occurring losses as resulted. Based on the computation of Growth Ratio on EPS, though it has been reported through financial statements that the sales and income have weaken, still it indicates that the earnings through issuance of shares increases over time. (see Note 5 for computation).

Developing Common Law In Environmental Law Policy - Free Essay Example

Sample details Pages: 9 Words: 2803 Downloads: 7 Date added: 2017/06/26 Category Ecology Essay Type Narrative essay Did you like this example? Common law actions have in recent years proved to be a fertile ground for environmental litigation, although the judiciary have demonstrated a rather lukewarm response to attempts to use torts as a mechanism to control the adverse impacts of pollution on people, property and the wider environment. The courts have shown a preference for specific pollution legislation, such as the Environmental Protection Act 1990, and have shown minimal support for attempts to develop the common law as a means for resolving modern-day environmental problems (Wolf and Stanley, 2010). Introduction Common law is a Judge-declared law, a law which exists and applies to a group on the basis of customs and legal precedents developed over hundreds of years in Britain. Common law is split into two sectors: case law and legislation. Legislation is an act passed by a Parliament or legislature, whereas case law is the law that accumulates as a result of court decisions. There has been much discussion when regarding the issue of common law. Don’t waste time! Our writers will create an original "Developing Common Law In Environmental Law Policy" essay for you Create order For The easiest way to deduce whether the courts have shown a lack of support for the development of common law legislation to counter present day people, property and environmental problems is to analyse well known environmental cases, and make judgements to whether more could have been accomplished by the courts. First the difference between must be defined. Rylands v Fletcher [1868] Rylands v Fletcher is one of the most pivotal cases in Tort law, due to the implications it had on future Tort law cases. Rylands possessed a piece of property over mines and veins of coal. However, he didnt own the rights to these. Nearby coal mines were owned by Fletcher. Rylands built a reservoir, unaware of the abandoned mine left underneath, which led to the overflow of water into Fletchers nearby cave. Fletcher sued Rylands under the tort of trespass, which was deemed inapplicable, as at the time of the case, one-off events werent classed as trespass, and therefore leading to the case being b rought under the tort of nuisance. The arbitrator ruled that Rylands was not guilty of negligence as they had no way of knowing about the shafts under the reservoir. The case was appealed, and ruled in favour of Fletcher, due to Rylands causing mischief by not keeping control of the reservoir. Although he acted without negligence, he was still liable due to the mischief he caused. Due to the reversal in charge, this case became extremely important in regard to Tort law, with some considering Rylands v Fletcher as the fourth Tort. Cambridge Water Co Ltd v Eastern Counties Leather plc  [1994] The most prominent case to consider when agreeing the statement is most probably the Cambridge Water Co Ltd v Eastern Counties Leather plc, which is an important English Tort Law case. It is a case strongly linked to the Rylands v Fletcher case (1868), due to the nature of the case. In 1976, Cambridge Water Co purchased Sawston Mill, which had a borehole from which water could be pumped from. The water was tested at the time, and was declared suitable. Nearby, ECL plc owned a tannery, in which PCE was used within the process. Over the years, the PCE leaked in small quantities and mixed with the groundwater, eventually travelling down, and percolating in the borehole of Sawston Mill, affecting the quality of the water. PCE in water was not a major problem at this, which meant Cambridge Water neglected to test for it. When the European Directive was introduced, the water was tested, and high levels of PCE were found, leading to the shutdown of pumps. CWC then sought damages against ECL, demanding  £1 million in damages due to the requirement of finding a new borehole, and covering the cost of the attempted cleanup of the old borehole. CWC stated they were liable under three of the four Torts; nuisance, negligence and Rylands v Fletcher. The case reached the High Court, but the action was dismissed in both nuisance and negligence. The reasoning behind this was that at that time, there was no possible way of ECL of knowing that PCE release were occurring, and could not have foreseen the damage done to the aquifer. The Rylands v Fletcher rule was considered also, which states the person who for his own purposes brings on his lands and collects and keeps there anything likely to do mischief if it escapes, must keep it at his peril, and, if he does not do so, is prima facie answerable for all the damage which is the natural consequence of its escape and that with a requirement that this use of land be non-natural. The Judge Ian Kennedy disagreed that PCE was non-natural as it was on an industrial site, rendering the claim under Rylands v Fletcher invalid. CWC appealed to the High Courts, and the decision was reversed, due to the decision being based on the nuisance Tort and the case Ballard v Tomlinson (1885). The argument that ECL was interfering with CWCs right to abstract uncontaminated water, which itself was regarded as an action able nuisance. Although the appeal was also claimed under Rylands v Fletcher, this was disregarded. CWC was awarded  £1 million in damages plus costs. This caused uproar within industry, with fears that many companies would be liable for historical contamination. The case was appealed again, this time to the House of Lords. The judgement of the case made important statements regarding the connection between nuisance and Rylands v Fletcher. Lord Goff considered forseeability (only liability where interference was foreseeable by a person in the defendants position belief that damage was unforseeable), non natural use (storage of substantial chemicals should be considered non-natural freed up restriction on liability under Rylands v Fletcher) and the courts and environmental protection (referring to common law as environmental protection aiming to create a statutory regime of liability for environmental damage). The decision was once again reversed in favour of ECL. The main r eason for this was the issue of forseeability of the damage suffered by CWC, as it was believed at the time that any spilt solvent would be evaporated. There are major criticisms of the how the case ended. Most environmentalists believe the judgement was restrictive due to the introduction of the requirement of forseeability of the type of damage as a component of the rule in Rylands v Fletcher. Another criticism of the judgement is that only very rarely will it impose liability for pollution cases such as this one. To some, it is believed that not enough impetus was placed on the safety of the environment when regarding the case in general. The reaction from Lord Goff seemed to be one of timidity and uninterest in correcting a wrongdoing. The fact that the judges felt the case should be dealt with by Parliament rather than the courts seem to be a statement that disregards the importance of dealing with pollution to the environment. Fairchild v Glenhaven Funeral Services [2 002] The next case of interest is the Fairchild v Glenhaven Funeral Services Ltd. The case involved Mr Fairchild, a subcontractor who worked for a number of different employers, all of which inadvertently exposed him to asbestos. Fairchild then died of Mesothelioma, which resulted in his wife suing the employers under the Tort of negligence. This lead to other people affected with similar situations suing the companies as well. The problem with determining whether the employers were to blame for Mr Fairchilds death was that a single fibre of asbestos can lead to the contraction of Mesothelioma, and was therefore very difficult to determine which employer was completely to blame for the death. Unlike asbestosis, Mesothelioma is a single indivisible disease, therefore the claimant cannot deduce when the asbestos fibre was inhaled leading to the mesothelioma cell becoming malignant. The question was if the defendants had overexposed Mr Fairchild to the asbestos. All employers wer e equally liable. However, this lead to the question of probability, as it was difficult to determine which employer had exposed Mr Fairchild to more asbestos. Due to this uncertainty, the Court ruled that the claimant was unable to judge if the breaches of duty were a cause to the deceased death. In other words, no damages were paid to Mrs Fairchild. This is another classic case of the Courts washing their hands of a difficult decision. Instead of implementing legislation regarding asbestos, the claimant ended up with nothing. In 2001, the case Edwin Matthews v The Associated Portland Cement Manufacturers (1978) Ltd was brought to court, with the same problem of exposure of asbestos the cause. Mr Matthews had been exposed while working for several contractors, contracted Mesothelioma, and had sued two of the employers. However, unlike Fairchild v Glenhaven, Mr Justice Mitting had an alternate opinion on the case.He concluded: I can see no substantial difference between saying th at what the defendant did materially increased the risk of injury to the claimant, and saying that what the defendants did made a material contribution to the injury. It seems to me wholly artificial to require a claimant to prove which fibre, or fibres, inhaled in whose employment, in precisely what circumstances, caused or set off or contributed to the process by which one or more mesothelial cells became malignant.  [i] Mr Justice Mitting The court ruled in favour of Mr Matthews, who received damages from both employers, with the reasoning that even though it could not be determined which employer exposed him to the actual asbestos resulting in the Mesothelioma, it could be deduced that they had both increased the risk of him doing so. This leads to the question: How can two such similar cases end so differently? Hunter v Canary Wharf The Hunter v Canary Wharf Ltd [1997] involved the construction of Canary Wharf Tower. However, the construction of the tower, which w as situated near to BBCs primary television transmitter, which affected the reception of local residents television. Also, action was brought against the London Docklands Development Corporation under nuisance also, due to the dust created from the road construction. Over 500 residents filed cases, including Patricia Hunter, against Canary Wharf under the Tort of nuisance, arguing that their television license was now wasted and loss of enjoyment. Originally they filed under negligence too, but the Tort was abandoned soon after. During the case, it was stated that the nuisance in question must be substantial, and that only householders with a right to a property could file anything under the Tort of nuisance. It was Lord Goffs judgement that a building being built in the near vicinity does not apply as nuisance. Initially, the case of Khorasandjian v Bush [1993] was brought up, in order to show that the occupation of a property as a home was enough to constitute action in private nuisance. However, this was rejected in the House of Lords, with the point being that when dealing with private nuisance, the right to sue can only be exercised by those with rights to the land affected (freehold owners, tenants in possession). The question of dust was rejected as personal injury doesnt apply under the Tort of nuisance. Due to the connection made between property rights and nuisance, the development of greater protection of the wider environmental problems has been halted. It was Lord Hopes opinion that not enough had been stated within the case to make a change to the law in regard to a nuisance. Against When considering the argument against the original statement, there are also many cases to represent this opinion. The argument will be fought with examples where the Courts place more impetus on protecting the environment than on themselves from a tough decision. Empress Car Company Ltd v National Rivers Authority [1998] The case in question focused on the prosecution of Empress Car Company being sued by the National Rivers Authority, due to the release of red diesel fuel into a river. An oil tank owned by Empress, was surrounded by a protective bund, in case of a spill. However, a pipe leading to a smaller oil tank outside the bund was installed to make oil use easier. However, the oil tap was vandalised by a trespasser, which led to the oil overflowing from the secondary tank, which in turn led to the contamination of a local river. When the case reached the Courts, the defendant tried to place the blame on the trespasser who caused the tap to be open, and had only crea ted the circumstances which led the trespasser entering the grounds. He also argued that the involvement of the trespasser broke the chain of causation. The argument was rejected by Lord Hoffman, who found Empress Car Company Ltd guilty. Another point brought up was the act of prevention of a chance of contamination. It seemed that Empress had a lack of a valid backup plan if a spill occurred. The question of liability was resolved in 1991 when the WRA was created, which states that escapes of pollutants into controlled waters will lead to absolute liability. This is a prime case when deciding whether or not the original statement is true. Empress v National Rivers Authority reflects that proper incite was made into the environmental effect when determining the judgement of the case. It showed that even though the defendant had not directly led to the release of the oil, he was still liable as he didnt take enough care in ensuring that if a spill occurred, it would be dealt wi th accordingly. Wheeler v Saunders [1994] In the case Wheeler v Saunders [1994], Mr Wheeler was a veterinary surgeon who owned Kingdom Farm House. The farm as owned by J.J Saunders, who used it to raise pigs. Wheeler filed a complaint regarding the smell of the pigs, under the Tort of nuisance. The court agreed with Wheeler, in regard to the smell nuisance affecting his use and enjoyment of the land. The decision was appealed by Saunders, who stated that the allowance of planning permission changed the nature of the area, which then would lead to the nuisance Tort being allowable, thus throwing the case out. He referred to the case of  Gillingham Borough Council v Medway (Chatham) Dock Co Ltd, which allowed the building of a commercial dock. However, the appeal was disregarded, with the reasoning that the case of pig houses would affect the surrounding area more dramatically than it would have regarding the Gillingham case. This decision goes against the original sta tement as it directly supports the avoidance of the environmental effect of the pig farms. Transco v Stockport The Transco v Stockport Metropolitan Borough Council [2003] involved the collection of a large amount of water under a block of flats, due to an undetected leak. The leak then spread to a nearby embankment, which led to the embankment collapsing. This in turn led to a gas pipe becoming exposed and unsupported, due to the ground underneath the pipe being washed away. The gas company, Transco, then sued the Stockport Council under the Rylands v Fletcher Tort, in regard to the repairs necessary. The Courts judgement was that the council was not liable as the amount of water from the pipe is not considered a dangerous amount. When considering the Rylands case, which showed that excessive amounts of water can lead to risk of damage, the case seemed to have justification. However, Lord Hoffman judged that a burst water pipe does not does not count as something excessive or dangerous. When considering section 209 of the Water Industry Act (1991), which states that although the water undertaker is considered liable when causing damage or loss, they would not incur any liability if the case in question is regarding a specific claimant, such as Public Gas Suppliers, who must insure themselves. Due to this, the Court supported the Council. Conclusion In regard to the original statement, there are several cases supporting and disregarding the claim. On one hand, there are several examples (many more than stated) that show a lack of will to combat environmental problems by developing the common law. On the other hand, there are also examples where the courts have supported the use of legislation to help protect the environment. There seems to be a pattern when regarding the cases supporting the original claim. It seems when the case in question offers a dilemma in ethics, the courts are more than willing to sweep it under the rug, rather than finding a better way of dealing with the same kind of problem in the future. When referring to Cambridge Water Co Ltd v Eastern Counties Leather plc, it seemed the Judge was more than happy passing the problem over to Parliament than finding a constructive method of dealing with it correctly. The fact that forseeability was considered more of an issue than the non-natural use of land also re presents this opinion.