Gender and Identity in Raymond Carvers so Much Water, so...

Men are from Mars, women are from Venus. Weve all heard the saying, but what does it mean? We are different, that goes without saying. As evidenced in Raymond Carvers So Much Water, So Close to Home, men and women differ on many key issues of morality, perception, and judgment. The two do have something in common, believe it or not, and that is the expectation of the opposite gender to communicate, think, and react in the exact way they do. Hence, frustration. Not with themselves, God forbid the two ever see a situation from each others point of view. The frustration is with the opposite gender, over something that for the most part, they cannot help. As we have seen time and time again and as Carver proves, its in our blood. What†¦show more content†¦Men as a whole are known to be less compassionate and sensitive than women. The example used in the story is of course an extreme case- in reality even the most masculine of characters would not likely leave a dead body in the river close by for days and even wash their dishes next to it without calling on the proper authorities to help. What does it mean to be a woman? In So Much Water, So Close to Home, the narrator Claire is portrayed as an average woman. She has a hard working husband and a young son. All of the women in the story, excluding the dead one, are shown as very compassionate people. They are sensitive and caring to the needs of other people, even to those they do not personally know. When Claires husband Stuart returns home from his annual fishing trip, he tells her about how he and his friends found the womans body in the river. Not before having a cold beer, sex with Claire, and a good nights sleep, however. Claire cannot comprehend how in the world her husband could have done this. The fact that Stuart had found a body and waited several days to report it is bad enough, but for him to come home and carry on as if it had never happened is unimaginable to Claire. She even considers the po ssibility that it was her husband who raped and killed the innocent young woman. She later realizes, however, that her husband did not commit that particular crime. Claire thinks that her husbands inaction was a crime in itself. Claire sees this inability

Economic Development Of The Egyptian Economy Essay

After years of public spending on education in Egypt, where the government has shouldered heavy financial burdens, did this investment spending reach its planned and desired goals? And what are the changes that have been made in the Egyptian economy as a response to this investment spending? This section will try to find answers to these questions. 4.1 Quality of Labor-Force and the Process of Economic Development Any successful economic development process is based on maximizing the utilization of available domestic resources. Labor-force and domestic savings come on the top of these resources. While financial market is responsible for the efficiency by which domestic and foreign savings are accumulated and allocated, transforming savings to productive real investment, education and healthcare services are responsible for transforming the available labor-force to real human capital. It can be said that these two important resources are mutually related, as the returns of labor-factor are considered one source of domestic savings; and at the same time, real investment created by domestic savings is considered the main source of labor-factor return. The most striking characteristic that distinguishes developing from developed countries is the relatively inefficient utilization and the inferior productivity of their labor resources (Eshag, 1983). Egypt, like most developing countries, suffers from inefficient utilization of both domestic savings andShow MoreRelatedSources Of Economic Growth And Social Justice Essay1402 Words   |  6 Pages3.1 Sources of Economic Growth and Social-Justice Egyptian per-capita income has been significantly improved in the second half of the first decade of 21st century, as it recorded, in average, $1984 (standard deviation $167), compared to $1312 (standard deviation $597), in average, during the first half of the decade. Figure (1) illustrates the development of per-capita income through the first decade of 21th century and it shows that per-capita income growth rates were, in most, negative duringRead MoreThe Influence of the Hyksos Invasion of Egypt737 Words   |  3 PagesWestern Asia in Syria-Palestine, but have no clear origin where they are from. The Egyptians called these people hikau-khausut which means ruler of the foreign countries†. The Hyksos were technologically advanced and because of that they had a strong military. The Egyptians had been isolated from the growing and progressing world by the deserts which surround the country. Because of this isolation, the Egyptians were unprepared for any attack and had a weaker military force. Instead of protectingRead MoreThe Egyptian, Assyrian, And Persian Empires1580 Words   |  7 PagesFrom 1567 to 330 B.C. humanity experienced many subsequent development as well as decline in its civilizations. Among these events emerged three coloss al empires that had shaken the world and forever changed the course of human history. The Egyptian, Assyrian, and Persian Empires have been instrumental in influencing technology, religion, and ideas throughout the world. Various factors have contributed to the success and downfall of these giants. Each of the â€Å"World Powers† have similarities as wellRead MoreModern Egyptian Economy1526 Words   |  6 PagesIntroduction: The Egyptian economy has been witnessing a series of economic and political reforms since the beginning of the 21st century. Starting from post-Gamal Abdel-Nasser’s era in 1990 several economic reforms and monetary policies have been implemented by the Central Bank of Egypt (CBE) and other economic institutions. The economic reforms started by the Economic Reform and Structural Adjustment Programme (ERSAP), offered by the International MonetaryRead MoreEssay on Egypts Economic Climate908 Words   |  4 Pages Egyptian Economy Egypt’s economic climate has been greatly impacted by the political turmoil and unrest since 2011. The unstable political environment continues to change, and a new constitution was recently approved in January 2014 (Egypt Overview, 2014). Egypt continues to struggle economically with a weak growth rate at 1.8% and unemployment reaching 13.4% (The World Factbook, 2014). Out of the 13.4% unemployed, over 75% are individuals ages 15-29 (Egypt Overview, 2014). These factorsRead MoreThe Determinants Of The National Business Environment Essay1116 Words   |  5 PagesAnalyzing China and Egypt in terms of the competitiveness will help to better understand how the diamond framework works. China’s economy is emerging, fast growing and leading economy in the international market. 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Deutsche Bank free essay sample

A description of the organizational structure of Deutsche Bank. This paper analyzes Deutsche Bank by reviewing how three key activities are planned and managed within the Group Executive Committee division of this organization. In addition it reviews what roles teamwork, effective management and motivated employees play in completing these activities. The paper demonstrates how planning techniques are created using P.E.R.T. It also outlines how Deutsche Bank approaches the monitoring and management of quality and related issues in the Group Executive Committee Division of the organization. The paper gives an overview of the organizational structure of the bank and how this division of the bank interrelates with other functional areas. A graph is provided illustrating the organizational structure of the bank. The organizational structure of the Deutsche Bank is made up of three groups, which include Corporate and Investment Banking, Private Clients and Asset Management and Corporate Investment. These three groups also make up the Divisional Committee; the other two committees are the Group Executive Committee and the Functional Committee. We will write a custom essay sample on Deutsche Bank or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page

Physics Essay Example

Physics Paper What is science? Science is a body of knowledge that is ever changing. It is made up of not only facts but also theories that are made up of well-tested hypotheses. 2. Dullnesss among the scientific fact, hypothesis, law and theory As stated above, a theory Is made up of well-tested hypotheses, which In themselves are well educated guesses yet to be proven. A fact is something that can change over time even though it was agreed upon by knowledgeable scientists. Scientific laws are not specific, are mostly principles and are the result of repeated observations. Why do some people think they have to choose between science and religion? They are either uninformed or misinformed to believe that must choose. Science and religion are very different as the domain of science Is natures order whereas religions domain is natures intent. 4. Clearly distinguish between Science and Technology. Science is a body of knowledge that not only uses technology as a tool but also is used In the developme nt of technology. As scientists make more and more breakthroughs, they are using the latest and greatest technology to do so and In turn ore technological breakthroughs. . Why is Physics considered to be the basic Science? Physics may be considered one of the physical sciences but it is the foundation that other physical sciences are built upon. It deals with forces, light, atoms and matter to begin with, which are the building blocks of all things, including other sciences. Exercises 1. What is the penalty for scientific fraud in the science community? The punishment for scientific fraud is professional excommunication, or in simpler terms, their work is no longer recognized as that of a scientist. 2. Which of the following are scientific hypotheses? A) Chlorophyll makes grass green. (b) Earth rotates about its axis because living things need an alternation of light and darkness. (c) Tides are caused by the moon. (a) is the only hypothesis because there is a test for falseness. Tho ugh the other examples may very well be opinion, like why does the Earth spin about its axis. 4. The great philosopher and mathematician Bertrand Russell wrote about ideas in the early part of his life that he rejected in the latter part of his life. Do you see this as a sign of weakness or a sign of strength? Do you speculate that your present ideas about the world around you will change as you learn and experience more, or do you speculate that further knowledge and experience will solidify your present understanding? ) I see that as a strength, many people Just take for granted what was told to them as an unchanging fact, and it is the people who have questioned these facts that have truly reshaped our world in all aspects, not Just science and mathematics. 6. When you step from shade into the sunlight, the Suns heat is as evident as the coals in a fireplace in an otherwise cold room. We will write a custom essay sample on Physics specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Physics specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Physics specifically for you FOR ONLY $16.38 $13.9/page Hire Writer You feel the Suns heat, not because of its high temperature, but because the Sun is big. Which do you estimate is larger, the Suns radius or the distance between the moon and the Earth? Do you find your answer surprising? I estimated that the distance to the moon was slightly larger than the Suns radius, but in actuality the Suns radius is larger than the distance to the moon which was very surprising to me from the lower level science classes that I remember. 7. What is probably misunderstood by a person that says, But thats only a scientific theory? The process of formulating a scientific theory is a very tedious process consisting of analyzing many well-tested hypotheses and facts. Chapter 2 1 . What are the three major items of Aristotle that Galileo nullified? The first was his idea of motion, proving that weight doesnt matter on time of falling objects, proving this by dropping different sized items off of the leaning tower of Pisa. 2. Who first introduced the word Inertia? Galileo first stated that everything tends to resist changes in motion and called it inertia. Newtons first law was the law of inertia but it was Just expounding upon Galileo original thought. 3. What is Newtons First law of Motion? As previously stated, Newtons first law was the law of inertia. This law states Every object continues in a state of rest or of uniform speed in a straight line unless acted on by a nonzero net force. 4. What is equilibrium rule? The equilibrium rule is basically describing something that has a net force of zero. Weight, the gravity is pulling the object down but it is not moving due to the strength of the string. 5. What is support Force and why is it important to understand it? Support force is he potential amount of force or strength that an object has while it is stationary. The example that the textbook uses is that a book sitting on a table is stationary and not falling because of the tables support force. It is important to understand because it is the potential of force and isnt always acting upon something. 2. Copernicus postulated that Earth moves around the Sun, but he was troubled about the idea. What concepts of mechanics were he missing (later introduced by Galileo and Newton) that would have eased his doubts? He was missing the concepts f inertia and net force in that Just because something seems to be stationary, it isnt necessarily, it may have a net force of zero or it may not be accelerating or slowing down so that speed is actually acts upon all things equally like throwing a ball in a moving car. 4. What Aristotelian idea did Galileo demolish with his experiments with inclined planes? He demolished the idea that a vacuum would be impossible and all things are acted upon by some sort of medium, whether it be air, water or land to cause friction to an object. 5. Why do you lurch forward in a bus that suddenly slows? Why do you lurch backward when it picks up speed? What law applies here? This is the law of inertia at work, stating that all things tend to stay the same unless acted upon by another force, so the slowing of the bus makes your body want to continue at the same speed it was going, therefore moving forwards, the same with speeding up as you body lurches backwards to compens ate in acceleration. 26. Can you say that no force acts on a body at rest? Or is it correct to say no net force? Defend your answer. A body at rest has a zero net force since gravity is a instant force pushing a body down but it has the supportive force to stay whole. Also two kids pushing a grocery cart at the exact same NON rate, the cart will not move though it has forces being applied to it. 28. Harry the painter swings year after year from his bosons chair. His weight is NON and the rope, unknown to him, has a breaking point of BOON. Why doesnt the rope break when he is supported as shown on the left? One day, Harry is painting near a flagpole, and, for a change, he ties the free end of the rope to the flagpole instead of his chair, as shown on the right. Why did Harry end up taking vacation vacation. On the left picture, he has his rope doubled over onto his chair with a pulley system, effectively only applying NON on each half of his rope but if it is only tied to his chair and another object, his full NON is applied to the rope that has a breaking limit of NON and down he goes. Chapter 3 1. What is the difference between Instantaneous Speed and Average speed? Instantaneous speed is the speed at which something is moving at that exact moment in time whereas the average speed of something is calculated as the total stance covered over the time interval used. So over a 30 minute period a car could average mi/h but at an exact moment be traveling at Mimi/h but it wouldnt be sustained. 2. What is the difference between Velocity and Acceleration. Give example. Velocity is the speed and direction that something is going while acceleration is a change in velocity. If a car is traveling due East at Mimi/h, that is the velocity but if that cars velocity changes to 51 mi/h, Mimi/h or turns 12 degrees to the west, it would be accelerating. 3. How did Galileo explain Acceleration by an inclined plane? Since he did not have accurate timing devices, he used planes at certain inclines to learn that balls rolling on them had unchanging acceleration, both upwards and downwards. He also showed that a vertical plane had the same acceleration as dropping the same object. 4. What is the meaning of Free Fall? What becomes the acceleration in free fall? Free Fall is an object falling with no friction or wind resistance, basically falling under the force of gravity alone. The rate of this is usually rounded to mm/s though a more accurate rate of 9. Mm/s is used when more precise results are required. Exercises 5, 19, 20, 40, 41 5. Light travels in a straight line at a constant speed of 300,000 km/s. What is the acceleration of light? O, if light is always traveling in a straight line at an exact, constant speed, then it is never accelerating, changing direction or speed. 9. On which of these hills does the ball roll down with increasing speed and decreasing acceleration along the same path? The middle hill would have the ball moving downwards to start increasing speed as it goes until the angle begins to change, making the hill at that point much less steep. At that point the ball begins to 20. Suppose that the three balls shown in Exercise 19 start simultaneously from the tops of the hills . Which one reaches the bottom first? Explain. The ball on the second hill would land first because it has such a large acceleration at the top of the hill that the other balls would not be able to catch up despite there being a period of deceleration. 40. Two balls are released simultaneously from rest at the left end of equal-length tracks A and B as shown. Which ball reaches the end of its track first? If both balls are dropped simultaneously, the ball on track B reaches the end first since the speed s increased for such a time before it is decreased again to match the speed on track A. 1. Refer to the pair of tracks in Exercise 40. (A) On which track is the average speed greater? (B) Why is the speed of the ball at the end of the tracks the same? (A) The average speed is greater on track B since it accelerates during the dip and then when it has a deceleration but the speed only drops to that of the other track.

The eNotes Blog Downloadable Shakespeare Map for YourClassroom

Downloadable Shakespeare Map for YourClassroom The settings of Shakespeare’s thirty-seven plays cast a wide net across Europe. The majority are set outside of England, providing his audiences with intriguing, foreign lands and allowing for flexibility in expressing social and political commentary. Our free, downloadable map of Shakespeares plays  features the locations and dates of his comedies, tragedies, and histories across Europe, which can serve as a helpful resource in your classroom to show how each location lends itself to different types of plays. Download the Shakespeare map of works  » Let’s take a look at five ways in which you can reference  our Shakespeare map during your lessons or classroom activities. 1. Explaining Historical Context When teaching Shakespeare’s plays, it’s important to note that Shakespeare wrote to entertain. While many of Shakespeare’s plays feature historical elements, their historical accuracy is often dramatized for the sake of performance. Because Shakespeare’s plays were being performed in public theater, the audience was composed of a wide range of economic, educational, and social levels. Therefore, the characters Shakespeare included in his plays hail from a variety of different backgrounds and social classes to make them relatable to the audience. Additionally, many of the characters are created with stereotypes and prejudices that would fit the audiences understanding of a place and its people. Why exaggerate history? Shakespeare produces a historical bias in his plays that favor the Queen and the Tudor dynasty. Examples of the historical events exaggerated for the stage: Shakespeare’s three Henry VI plays and Richard III were part of â€Å"The War of the Roses,† that portrayed the conflict between the House of Lancaster and The House of York. While the War of the Roses was a real event, historians claim that there were no actual roses involved as symbols for the houses. In fact, The War of Roses was not coined until the 19th century, and the struggle between the two houses had been known as the â€Å"Cousins’ War.† One of Shakespeare’s most monstrous characters is Richard III, who is depicted as a relentless murderer in the interests of his own ambitions. While Richard III was responsible for the execution and murder of several people during his rule, Shakespeare exaggerated the long list of ghosts who haunt him in the play. For example, there is no proof that King Richard III murdered his wife, Anne, or King Henry IV. 2. Analyzing Shakespeare’s Commentary Although Shakespeare’s plays reflect the cultural, social, and political conditions of the Elizabethan Age, Shakespeare could not explicitly critique the monarchy without being accused of treason or slander. Therefore, Shakespeare used foreign settings to mask his criticism of Christian orthodoxies and political ideologies of England. For example, by setting plays in Rome, Shakespeare could discuss sensitive issues like the political assassination of Julius Caesar. Examples of Shakespeare’s commentary: In both Hamlet and Macbeth, Shakespeare depicts murder and regicide as means of obtaining positions of power. Setting these types of violent scenes in foreign countries allowed Shakespeare to criticize powerful leaders without being prosecuted for treason or having his plays censored. In King John, Shakespeare explored the issue of what establishes a â€Å"right† to the throne of England, which alludes to the doubts of legitimacy regarding both King John and Queen Elizabeths reign. 3. Exploring the Setting of Comedies A majority of Shakespeare’s comedies are set throughout contemporary Italy and the Mediterranean. During the 17th century, English writers were fascinated by their Italian neighbors and regarded them as passionate, devious, and often violent people. The Italian stereotype leant itself to the comedic elements in his plays that feature tangled plots of love and mistaken identity. In Shakespeare’s characterization of different Italian cities, Verona became associated with love (Romeo and Juliet and The Two Gentlemen of Verona), while Padua was a place of learning as described in The Taming of The Shrew. Reoccurring themes in Shakespeare’s comedies: Appearance vs. reality Elements of mistaken identity or disguise to advance the plot and characters Fate and fortune The influence of fate, fortune, or some obscure force that changes characters’ course of action Love and romance Characters that fall in love and must overcome various obstacles in order to be together- or die trying 4. Exploring the Setting of Tragedies Shakespeare’s tragedies include a protagonist, or tragic hero, battling internal or external obstacles. A majority of Shakespeares tragedies are based on historical figures, but because the sources of the stories were foreign and ancient, they are almost always classified as tragedies rather than histories. Shakespeare’s best-known tragedies are set in Great Britain and Scandinavia (Hamlet, King Lear, Macbeth) or around contemporary Italy (Julius Caesar, Titus Andronicus, Antony and Cleopatra, and Coriolanus). There were many social and political similarities in classical Rome and 17th century England, in which Shakespeare could reflect familiar stories to his audience that resonated with their experience living in Elizabethan England. The Roman tragedies raise questions about the consequences of political overthrow and the duty of citizens and their government. Reoccurring themes in Shakespeare’s tragedies: Death Conclusions often end in death to comment on human morality or to resolve conflicts in the plot Tragic flaw (hamartia) A character trait that leads to a fall from power or eventual demise Revenge Often motivated by uncontrolled jealousy that leads to tragic consequences 5. Exploring the Setting of Histories Shakespeare wrote ten historical plays that explore political themes of power and divine right with blended elements of tragedy and comedy. All ten history plays are named for and about English monarchs who ruled between the 12th and 16th centuries: Kings John, Edward, Richard II, Richard III, and Henry IV, Henry V, Henry VI, and Henry VIII. The history play explore the nature of kingship and what grounds are justifiable to oppose or overthrow it. While the majority of history plays are set in medieval England, they reflect the contemporary context of Shakespeare’s time and may be perceived as warnings to not repeat mistakes of the past. Reoccurring themes in Shakespeare’s histories: Ambition A motivator for characters to pursue positions of power or to overthrow those who currently possess it Corruption Characters who are corrupted by nature or circumstance that leads them to abandon their moral constraints Succession Who or what dictates kingship and how is one able to obtain that power Want more Shakespeare? Check out our other Shakespeare resources to use in your classroom: How to Understand Shakespeare’s Language †¨ William Shakespeare Lesson Plans and Activities†¨ Shakespeare Annotated Texts

How Ballast Water Systems Work

How Ballast Water Systems Work A ballast water system is essential for the safe operation of a ship, but the operation of these systems causes significant threats to the environment and local economy. What Is a Ballast Water System? A ballast water system allows a ship to pump water in and out of very large tanks to compensate for a change in cargo load, shallow draft conditions, or weather. The capacity of ballast water tanks might be millions of gallons on a large vessel. This allows vessels to carry a light or heavy load while maintaining ideal buoyancy and handling conditions in all situations.A ship might discharge all ballast water tanks to pass a shallow area or forward tanks only to raise the bow in rough open seas.Physical components of the system include; raw water intakes, large and small strainers, pumps, distribution pipes, ballast water tanks, treatment system, discharge system, and all the valves, sensors, and controls to run the equipment. Invasive Species in Ballast Water Invasive species are a significant threat to ecosystems and the economies of the affected areas. Researchers think that about one-third of all documented invasive plants and animals are able to travel in the ballast water tanks of ships. Zebra Mussels were introduced into Lake Saint Clair in 1988 when a ship emptied ballast water into the Great Lakes System. The Great Lakes hold nearly twenty percent of the earth’s fresh surface water in a watershed system. The non-native mussels eliminated native varieties once used by industry and have caused an estimated 7 billion dollars (US) in damage by encrusting or clogging underwater equipment essential to industrial and recreational activities.Sea Lamprey and ​Spiny Water Fleas are organisms which feed off of host fish or compete with young fish for food. Many species of fish impacted by these invasive species have significant commercial or sporting value. These animals and others can live in fresh or salt water and may spread into inland waterways from saline ports and harbors.Plants can also travel long distances in ballast water. Eurasian Milfoil is a surface plant which can clog equipment and deter recreation where it forms thick mats. Eurasian Milfoil was introduced to the United States in the 1940s. Because the plant can produce large colonies from only one small fragment it is likely the plant was introduced in the ballast water of a ship. Resolving Ballast Water Issues For years amateurs and professional researchers have experimented with a huge array of weapons to combat invasive species in a ship’s ballast water. Most of the difficulty is due to the fact that huge volumes of water must be treated in a reasonably short period of time. Many land-based systems for treating public supplies takes many hours or days to pass water through their treatment systems. A ship, on the other hand, must be able to discharge ballast water as quickly as cargo is loaded. In emergency situations, ballast tanks need to empty as quickly as possible. A quick pass through most ballast water treatment systems is not enough to kill all the organisms that may be present. Ballast Water Treatment Solutions and Shortcomings No Discharge or Ballast Exchange Rules: International, National, and Local law govern ballast water discharge. Some areas require ballast tanks to be sealed while others allow ballast to be exchanged. Ballast exchange allows tanks to be filled with local waters. Sealed ballast tanks may need to be emptied in an emergency situation and exchange is hindered by the fact that foreign waters must be discharged in close proximity to ​the sensitive area for vessels to operate safely.Mechanical Filters: Filters which are fine enough to remove the small immature young and eggs of invasive species clog quickly and require constant maintenance.Thermal Treatment: The idea is to heat ballast water to kill any unwanted organisms. Unfortunately heating such a huge volume of water is impractical due to time and energy constraints.Other Energy Treatments: Ultraviolet, sonic, and other radiation have all been tried but have similar problems to a thermal treatment; limits on time and energy.Chem ical Treatments: One of the earliest and most dangerous of all the methods used to control invasive species in ballast water. Chlorine bleach and other toxic chemicals will kill existing organisms but the release of these chemicals on the scale necessary to treat every ship would reach toxic levels for all aquatic life near the discharge points. The Future of Ballast Water Treatment Researchers are pursuing this difficult and financially lucrative goal at institutions around the world. In 2011, a team announced their successful small-scale test of a two-phase ballast treatment system which eliminates unwanted organisms and produces sodium bicarbonate as a byproduct. The system is undergoing full-size tests in the Great Lakes. The test for a scalable system is expected to perform well. It is not clear how regulatory agencies around the world will respond to the potential discharge of industrial amounts of sodium bicarbonate into their waters. Sodium bicarbonate is a common and safe chemical in small amounts, but studies must be conducted to assure this method is safe for long term use.

Unit 2 IP Presentation Essentials Essay Example | Topics and Well Written Essays - 500 words

Unit 2 IP Presentation Essentials - Essay Example (0323); Reconnaissance Man, Combatant Diver Certified (0324); Reconnaissance Man, Parachute and Combatant Diver Certified (0326); Machine Gunner (0331); Mortarman (0341); Infantry Assaultman (0351); Anti-Tank Missileman (0352); Infantry Unit Leader 0369) (Powers, 2012). II. Taking a step back, the grunt is part of the highly esteemed US Marine Corps, whose commander is a member of the Joint Chiefs of Staff in the US, and which functionally is part of the US Navy (Columbia Encyclopedia, 2012) 2. The place of US Marine Corps in American culture is one of honor, as evidenced by the dedicated war memorial that has come to be the final resting place of US Marine grunts (National Park Service, 2012) I. Life as a Marine grunt is hard and strenuous, from the first day of training through the different missions and tasks that the grunt is assigned to. It is demanding physically, emotionally, and psychologically, and only the fittest survive through to the training and the actual field deployments (US Marine Corps, 2012; Wetzel, 2012; Lodder, 2011; Hogan, 2008; Mitchell, 2010; Small Wars Foundation, 2009). 1. The dangers that grunts face in the Marines is real, and there are testimonies to the strength and courage of those who suffered serious and life-threatening disabilities and injuries on the field. Those testimonies and stories make up the vast lore of valor and bravery that make up the life of the Marine grunt, and they are widely discussed and honored by all Marines and the larger society. The story of one Marine who suffered massive injuries while on duty in Germany is the story of all Marines (Wetzel, 2012) References to grunt life in the protracted wars that the US continues to fight, such as those in Afghanistan, are graphic and unedited, giving us a glimpse of the unromantic aspect of grunt life, so unlike the romantic images we get from the movies and from popular culture. Real grunt life in the Marines is sometimes harrowing, but Marine grunts try and

Critical Thinking Essay Example | Topics and Well Written Essays - 250 words - 7

Critical Thinking - Essay Example 2. Are there any similarities between the characteristics demanded of an entrepreneur and those of a professional athlete? Would an athlete be a good prospect for entrepreneurship? Why or why not? Could teamwork be important in an entrepreneurial effort? Why or why not? I think that there are many similarities between the characteristics of an entrepreneur and a professional athlete, most notably the discipline required to succeed. Preparation time is also a key aspect of both jobs because nothing should be left to chance. Just like an entrepreneur has to come up with short and long-term business plans, professional athletes need to set goals so that they are always improving. An athlete would be a good prospect for entrepreneurship because he or she would be able to carry over these same traits. Teamwork is very important in an entrepreneurial effort because no one can do something by themselves. Although they may have a thought or vision, they will need other people to carry out the objectives and work for the betterment of the

Creative Piece for as Level English Literature Coursework Comparing Two Film Adaptations of Hamlet Essay Example for Free

Creative Piece for as Level English Literature Coursework Comparing Two Film Adaptations of Hamlet Essay Kenneth Branagh takes Hamlet from play to screen in an intense, full-length adaptation and he got it right! Gregory Doran also takes a whack at bringing Hamlet from the stage to the screen but with a more modern-day interpretation. Branagh restores Hamlet’s greatest scenes and brings out the most in Shakespeare’s awe-inspiring revenge-tragedy plot; in both performance and direction, Branagh displays energy and cogency. The language has the upmost clarity and makes the film feel accessible and comprehensible for a range of viewers. Branagh’s pragmatic approach, which includes short illustrative ‘flashbacks’, work as a perfectly credible cinematic device that helps the audience to understand the complex scenarios. Branagh tends to rant on and shout throughout the film, especially in his soliloquys, but to the audience it could feel commanding and passionate and so it creates quite an impressive effect. The musical scores are generally helpful, although on occasions they don’t quite fit in with the mood, for example in Act 4, Scene 4, during Hamlet’s speech, the music just made it more humorous rather than serious and dramatic, honestly it sounded more like a cheesy American speech with a flag in the background! At the start of the film, the setting is a bit weak, with the shaking of the earth and the appearance of the ghost proving to be a poor attempt at special effects! However the film then gets flooded with colour and majestically inviting grand halls and rooms which are truly beautiful. The BBC’s adaptation of Hamlet (2009), takes a modern-day approach; from the start it is clear that this adaptation is modern dress, Hamlet wears jeans and a T-shirt and he kills Polonius with a handgun, as well as there being Helicopters and women in military roles. Some dialogue and scenes were ‘trimmed’ and adapted to suit viewers of the modern day and unlike the exuberant, bravura styling of Branagh’s version, Doran has favoured a more refined minimalist dramatization. Whilst the production design is theatrical, Doran directs the camera in a manner that is more typical of television; he uses a few cinematic flourishes and can reach angles that would be impossible on the stage. The use of modern CCTV may enforce the element of surveillance but their clumsy, intrusive functioning is more distractive rather than innovative. It is interesting however how Doran puts a camera in Hamlet’s hands to highlight that character’s observations of others. Onstage, Tennant made eye-contact with the audience, bringing  viewers into the plot and the tense impression of the play; this quality was also apparent in the film where Tennant looks directly into the camera, enhancing the meaning behind the text whilst recreating the theatrical intimacy. Branagh doesn’t stray from the original text in his exciting adaptation of Hamlet and the cast, acting, set and overall production was brilliant and can really captivate viewers. However despite the fact the former Doctor Who star tackled his role with an excellent fierceness, Doran’s modern-day approach was nowhere near as dynamic as Branagh’s performance.

Portugal :: essays research papers

The republic of Portugal is located in the southwestern part of Europe, situated in the western portion of the Iberian Peninsula, bordered by Spain on the north and east and by the Atlantic Ocean on the south and west. The Azores and Madeira Islands in the Atlantic are independent regions of Portugal, considered integral parts of the republic. Portugal administers one overseas territory, Macau (Macao) in eastern Asia near Hong Kong. Macau is scheduled to return to Chinese administration in 1999. The total area of metropolitan Portugal, including the Azores (2247 sq. km./868 sq. mi.) and the Madeira Islands (794 sq. km./307 sq. mi.), is 92,345 sq. km. (35,655 sq.mi.). The capital and the largest city is Lisbon.   Ã‚  Ã‚  Ã‚  Ã‚  Climate varies in Portugal according to the altitude in which you are located. Low temperatures occur only in the comparatively low regions of the south. The mean annual temperature north of the Douro River is about 10 C (about 50 F). Between Tajo and Douro the temperature is about 16 C (about 60 F). The temperatures in the valley of the Guadiana are at about 18 C (about 65 F). Rainfall is very heavy, especially in the north.   Ã‚  Ã‚  Ã‚  Ã‚  Minerals are the most valuable natural resources in Portugal. Much of these resources were developed until after World War 2 (1939-1945). Some of the mineral resources are coal, copper, gold, iron ore, kaolin, tin, and wolframite, which is Acosta 2 source of tungsten. The most sufficient trees are the evergreen oak, cork, poplar, and olive. Portugal is also a home of many kinds of wild animals. some of these wild animals include the wolf, lynx, wildcat, fox, wild boar, wild goat, deer, and hare. Portugal also has big waterpower resources in its rivers and mountain streams.   Ã‚  Ã‚  Ã‚  Ã‚  The Portuguese are a combination of several ethnic elements, principally Iberians, Romans, Visigoths, and later Moors. The people still live for the most part, in rural villages. The population of Portugal, including the Azores and Madeira Islands, is 9,931,045. The overall population density is 108 people per sq. km. (280 per sq. mi.). Mainland Portugal is divided into 18 districts for administrative causes: Aveiro, Beja, Braga, Bragnca, Castelo Branco, Coimbra, Évora, Faro, Guarda, Leiria, Lisbon, Porto, Portalegre, Santarà ©m, Setà ºbal, Viana do Castelo, Villa Real, and Viseu. The Azores and the Madeira Islands each constitute an autonomous region.   Ã‚  Ã‚  Ã‚  Ã‚  Roman Catholicism is the faith of more than 94 percent of the Portuguese people. The Constitution guarantees freedom of religion, and some Protestant churches have been established. The official language of the country is Portuguese.   Ã‚  Ã‚  Ã‚  Ã‚  Portuguese culture is closely related to the Spanish culture and has been influenced by the three primary cultures from which

Whywhy Children Should Play or Organized Sports

Why Children Should Play School or Organized Sport â€Å"Research has shown that participation in outside of school sports and or other organized sports is associated with lower dropout rates, reduced problem behaviors, and increased school performance. Children build interpersonal skills, positive assets needed to become active and productive young adults. Studies suggest that children who are involved with after school sports or organized sports have higher self esteem, lower depression rates and have better opportunities for optimal growth and development†. Howie, 2009) Children should play school sports or organized sports, because sports improve children’s self esteem, sports teach children skills that they can use to become leaders, and sports give children the exercise they need to stay healthy. Although, school sports or organized sports help children with their self esteem, teach children to be team players and give children the exercise to stay healthy there a re cons to playing sports. School sports or organized sports are commitments that a child needs to make.When there is a child that is going to play sports, the family also needs to be a part of the team as well. Playing sports is time consuming and takes a lot of time from be able to do other things outside of sports. It is important that the child and parents know the length of the season, the practice schedule and game schedule to make sure that there is time for family time too. It is also important that when a child has decided to play a sport that the entire family is willing to be a part of the team as well. School sports and or organized sports are wonderful to help increase self esteem in children.When children have a high level of self esteem they reduce the chances of depression and anxiety. Children that play school sports or organized sports have a high level of self esteem and do well in school; it helps children to become problem solvers and gives children encouragemen t to do well in school. It has been proven that children that participate in school sports or organized sports earn better grades, have better behaviors in and out of the classroom, and there is a lower rate of them dropping out of school. School sports or organized sports keep hildren going to school on a regular basis with fewer unexcused days missed, because they know that if they are not in school they are going to miss the opportunity to play with their team. â€Å"Furthermore, non participants of school sports or organized sports were more likely to drop of school; children were more likely to smoke cigarettes, more likely to become teen parents and more likely to be arrested than children who are sport participants†. (Donaldson, 2007) School sports or organized sports gives children skills to become team members and helps children to become leaders.Children that play school sports or organized sports learn skills that they can use their entire lives. â€Å"Development al benefits include: developing individual and team goals, meeting deadlines, working as a team, learning to perform under pressure, dealing with adversity, handling success and failure, developing self confidence, developing decision making strategies, and learning communication skills†. (Zaichowsky, 2007) School sports or organized sports are a wonderful way to encourage children to learn skills to become leaders in today’s society.After children graduate from high school and continue on to college, they are going to be able to take the skills that they have learned with them to the â€Å"Real World†. When children play school sports or organized sports they know that they are part of a team and that their team needs them. They need to make sure that they go to practice, go to school and make sure that they get good grades so that they are eligible to play in their games. Sports give children the feeling of membership and know that they are needed to complete a task from start to finish. Playing sports starts a foundation for children to be leaders.As children grow older and are learning the skills to become better adults, it is important that they understand that the younger generations are going to look up to them for guidance. They need to take their skills that they have learned and teach it to the younger children that are looking up to them for guidance. They have been taught the skills to be good role models for the next generation. Although school sports or organized sports teaches children lessons in life to be successful human beings, the most important reason that children should play sports is to be healthy. When children are school sports or rganized sport teams, they are going to get the exercise that they need to get healthy and stay healthy. â€Å"An increase in physical activity has many health benefits: it lowers the risk of obesity, coronary heart disease, type II diabetes, hypertension, and osteoporosis†. (Colla rd, 2008) Exercise teaches children to be physical fit, but also teaches children that nutrition is also important. Child obesity is on the rise in the United States. In today’s society we lead very busy lives and it is convenient to stop at fast food restaurants between work, home and sporting events to pick up dinner.Also, there are a lot of entertaining shows on television that children are interested in watching. We can help our children become healthier by leading healthy lifestyles as a family. Exercising is important to keep children fit and healthy to prevent injuries. Injuries can happen to healthy children do, but the risk is higher for children that are not in physical shape. Everyone should have at least 20 to 30 minutes of cardiovascular exercise each day, when children are playing school sports or organized sports they are exercising and having fun at the same time.Children should play school sports or organized sports to make sure that they get enough exercise. The word exercise to children sounds like work, however when they are playing sports they are exercising and getting into shape without knowing it. The importance of limiting television time and playing games on the computer or other gaming systems would be helpful to children too. When children are not playing school sports or organized sports, they should be encouraged to go for walk, go for a bike ride, take their dog for a walk or simply run up and down a set of stairs.By playing school sports or organized sports it is easier for children to get the exercise they need, but when they are not playing they also need to make sure they get the exercise they need to stay in shape. Physical Education classes in school help children, but there are schools in our country that are cutting PE classes from their budgets. School sports are great to get children exercising during the season but once the season ends it is just as important that they stay fit and healthy for the next season.Th ere has been a drop in the number of students enrolled in daily physical education classes, so that one in four children do not attend any school physical education class. Seventy percent of children drop out of sports by the age of 13. Nearly half of young people ages 12 through 21, and more than one-third of high school students do not participate in any vigorous physical activity on a regular basis. Fewer than one out of four children get 20 minutes of vigorous daily activity. The percentage of overweight young Americans has more than doubled in the past 30 years†. Engle, 2010) Children that play school sports or organized sports have a better chance of getting the exercise that they need compared to students that do not play sports. For children that don’t play sports, it is important that they are encouraged to join some other activity that involved daily exercise to keep children fit and healthy.In conclusion school sports or organized sports is wonderful for chil dren to learn tools that they are going to use through their childhood, but most importantly they are going to be able to take these tools and use them through the entire life. Sports participation is a major factor in the development of most American children. About 20 million American children ages 6 through 16 plays organized out of school sports, and about 25 million youth play competitive school sports. 30 to 45 million kids’ ages 6 through 18 participate in at least one school or community based athletic program†. (Engle, 2010) School sports or organized sports improve children’s self esteem levels, gives children the tools and lessons to become a leader and also allows children time to get the exercise that they need to get and stay healthy.When children have a high level of self esteem they do better in school and have more confidence. School sports or organized sports are a wonderful tool that is used to help children achieve their goals.

Organizational Conflict Essay

Often when we come across the word conflict, we usually think of more than a simple disagreement. We think of individuals or groups in sharp disagreement over issues, ideas, or interests. This results in an emotional disturbance between the involved parties, with stress developing & undesirable behaviors being exhibited. [1] The present diverse workforce characterized by organizational change, competition, and complex communications are drawing attention to interpersonal conflicts among workers. 2] Organizational change for example, alters the status quo and requires members of an organization to work together in new ways and under new rules. Competition compounds issues of power and escalates conflicts of personalities and behavior. The complexities of communication make it more difficult for culturally, economically and socially diverse workers to resolve the issues and problems they encounter on the job. While conflict is inevitable in groups and organizations due to the complexity and interdependence of organizational life, theorists have differed about whether it is harmful or beneficial to organizations. Early organizational theorists suggested that conflict is detrimental to Organizational functioning (Pondy, 1967; Brow, 1983) and focused much of their attention on the causes and resolution of conflict (Schimidt & Kochan, 1972; Brett, 1984). More recently, researchers have theorized that conflict is beneficial under some circumstances (Tjosvold, 1991; Van de Vliert & De Dreu, 1994). [3] Thus, this paper attempts to present the losses and benefits from conflicts in organizations. I. CONFLICT IN GROUPS AND ORGANIZATIONS A. Definition Generally, conflict is defined as a contest of opposing forces or power. 4] it is a perceived difference between a two or more parties that results in mutual opposition. [5] Looking at conflict in the context of groups, there is what we call an Intergroup Conflict, which can be defined as the behavior that occurs among organizational groups when participants identify with one group and perceive that other groups may block their group’s goal achievement or expectations. [6] Intergroup conflict with in organizations can occur in both horizontal & vertical directions. A. 1 Horizontal Conflict. This type of conflict occurs among groups or departments at the same level in the hierarchy, such as between line & staff. 7] This is commonly observed between Production & Quality Control Departments, Sales & Finance Departments, or R&D & Marketing Departments. A. 2 Vertical Conflict. This arises over issues of control, power, goals, and wages and benefits. [8] A typical source of vertical conflict is between head quarters executives and regional plants or franchises. Status and power differences among groups are often greater for vertical conflict. Part of the reason vertical conflict occurs is to equalize power differences; for example, u nions try to give workers more power over wages or working conditions. [9] B. The Nature of Conflict Conflict as related to competition is illustrated by the following figure: The illustration shows how conflict and competition are related. Competition occurs when groups strive for the same goal, have little or no antagonism toward one another, and behave according to rules and procedures. In conflict, on the other hand, one group’s goals jeopardize the others; there is open antagonism among the groups; and few rules and procedures regulate behavior. When this happens, the goals become extremely important, the antagonism increases, rules and procedures are violated, and conflict occurs. 10] C. Causes of Conflict A number of factors contribute to conflict. Several of the most important causes are discussed below. C. 1 Task Interdependence. Task interdependence refers to the dependence of one unit on another for materials, resources, or information. [11] Two types of task interdependence are particularly prone to conflict. One is sequential interdependenc e, in which one individual or work unit is heavily dependent on another. For example, waiters generally are more reliant on cooks than the reverse because waiters must depend on cooks to furnish good meals in timely manner. Line and staff conflicts often arise because staff members frequently are dependent upon the line to implement their ideas. The second form of task interdependence is reciprocal interdependence, in which individuals or work units are mutually interdependent. For instance, purchasing agents want engineers to provide detailed generic specifications so that they can negotiate lower costs from suppliers. At the same time, engineers need to obtain materials of the proper quality on a timely basis, so they may find it more convenient to specify a brand name. 12] Generally, as interdependence increases, the potential for conflict increases. [13] Sequential & reciprocal interdependence require employees to spend time coordinating and sharing information. Employees must communicate frequently, and differences in goals or attitudes will surface. Conflict is especially likely to occur when agreement is not reached about the coordination of services to each other. Greater interderdependence mean s departments often exert pressure for a fast response because departmental work has to wait on other departments. C. 2 Scarce Resources. Another major source of conflict involves competition between groups for what members perceive as limited resources. [14] Possibilities for conflict expand when there are limited resources, such as office space, equipment, training, human resources, operating funds, and pay allocations. In their desire to achieve goals, groups want to increase their resources. This becomes another cause for conflict in groups. C. 3 Goal Incompatibility. Goal incompatibility is probably the greatest cause of intergroup conflict in organizations. The overall goals of an organization are broken down into operative goals that guide each department. The accomplishment of operative goals by one department may block goal accomplishment by other departments and hence, cause conflict. [15] Out of necessity, organization members frequently pursue goals that are somewhat different from one another, setting the stage for potential conflicts. [16] For example, sales personnel may find it easier to battle the competition by promising very quick deliveries, while people in manufacturing may find that small production runs on short notice interfere with their cost cutting efforts. C. 4 Communication Failures. Breakdown in communication due to distortions or lack of communication often lead to conflicts. [17] Conflict in an organization is an indication of the most basic communication failure. Failure to talk with someone. Failure to notify someone of something before it becomes public. Failure to involve someone in a problem-solving process. [18] C. 5 Individual Differences. Differences in personality, experience, and values make frequent conflicts likely. [19] Functional specialization requires people with specific education, skills, attitudes, and time horizons. When an individual who have ability and aptitude in marketing joins the marketing department. Eventually, that individual will be influenced by departmental norms and values, attitudes, and standards of behavior, differ across departments, which is often a source of horizontal conflicts. Cultural differences can be particularly acute in the case of mergers or acquisitions. Employees in the acquired company may have completely different work styles and attitudes, and a â€Å"we against them† attitude can develop. [20] C. 6 Poorly Designed Reward System.

Free Essays on Every Man A King

Every Man a King There is perhaps no individual in Louisiana History who was as charismatic, influential and â€Å"interesting† as that of Huey Long. In his autobiography, Every Man a King, Long shares his story from his childhood in the north Louisiana hills to his magnetic climb into Louisiana and American politics. Long, in Every Man a King, does an exemplary job in describing one of America’s most remarkable politicians [himself] through his own eyes. Long was born in Winnfield, Winn Parish, Louisiana on August 30, 1893, the eight of nine children of a farmer. As a small boy, Long absorbed many of the ideas that came out of the Populist – Socialist traditions that were found in the region. He attended High School but had many troubles with the school officials and other local authorities and left the school before graduation. He sold vegetable oil door-to-door for four years. He conducted a cake-baking contest in Shreveport. The winner was Rose McConnell; they married in 1913. He told her that he would hold a secondary state office and would then become, in succession, governor, senator, and president; a job that allowed him to travel to several states, including Oklahoma. He attended the University of Oklahoma briefly to study law. He decided to become a lawyer and enrolled in the law School of Tulane University. He took courses for a year and was admitted to the bar. He began practicing law in his native stat e in 1915; first in Winnfield, but later moved to Shreveport. Long prospered as a lawyer, but had only used law as a jumping board into politics. He was elected a member of the Louisiana railroad commission in 1918; and later, in 1921, it enlarged in power and became known as the Public Service Commission. Huey Long ran for governor in 1924 and lost, but ran again four years later – on the platform of building better roads and free textbooks for all school children. Long won. He was the first maj... Free Essays on Every Man A King Free Essays on Every Man A King Every Man a King There is perhaps no individual in Louisiana History who was as charismatic, influential and â€Å"interesting† as that of Huey Long. In his autobiography, Every Man a King, Long shares his story from his childhood in the north Louisiana hills to his magnetic climb into Louisiana and American politics. Long, in Every Man a King, does an exemplary job in describing one of America’s most remarkable politicians [himself] through his own eyes. Long was born in Winnfield, Winn Parish, Louisiana on August 30, 1893, the eight of nine children of a farmer. As a small boy, Long absorbed many of the ideas that came out of the Populist – Socialist traditions that were found in the region. He attended High School but had many troubles with the school officials and other local authorities and left the school before graduation. He sold vegetable oil door-to-door for four years. He conducted a cake-baking contest in Shreveport. The winner was Rose McConnell; they married in 1913. He told her that he would hold a secondary state office and would then become, in succession, governor, senator, and president; a job that allowed him to travel to several states, including Oklahoma. He attended the University of Oklahoma briefly to study law. He decided to become a lawyer and enrolled in the law School of Tulane University. He took courses for a year and was admitted to the bar. He began practicing law in his native stat e in 1915; first in Winnfield, but later moved to Shreveport. Long prospered as a lawyer, but had only used law as a jumping board into politics. He was elected a member of the Louisiana railroad commission in 1918; and later, in 1921, it enlarged in power and became known as the Public Service Commission. Huey Long ran for governor in 1924 and lost, but ran again four years later – on the platform of building better roads and free textbooks for all school children. Long won. He was the first maj...

Dialogue Dos and Donts

Dialogue Dos and Donts Dialogue Dos and Donts Dialogue Dos and Donts By Erin In the post Show, Dont Tell, I mentioned dialogue as one of the ways you can â€Å"show† your reader what’s happening in a scene. Effective dialogue is an essential part of both fiction and creative nonfiction writing. Good dialogue can be tricky. It needs to move the story forward and reveal important character information without seeming artificial. It needs to seem realistic without actually being realistic. Confused? Let’s break it down. Here are some things good dialogue should do: It should follow some simple grammatical rules. Dialogue should be enclosed within quotation marks. Each new line of dialogue is indented, and a new paragraph should be started every time a new person is speaking. It should be concise. Long, wordy passages of dialogue might seem like a good way to get information across, but they can be tedious for the reader. It should communicate character information. Good dialogue lets the reader know something about the person speaking it. It should be broken up with action. People don’t typically stop everything when they talk. They fidget. They keep washing the dishes. They pace. Don’t forget that your characters aren’t static. And here are a few dialogue don’ts: Don’t get too crazy with dialogue tags. Usually, a few well-placed â€Å"he saids† or â€Å"she replieds† will do the trick. If your dialogue is well-written, it should be clear who is speaking, even without the tags. Don’t go overboard with backstory. You should never use dialogue to tell the readers things your characters already know. Don’t use too much dialogue. Your readers don’t need to know everything your characters say, word-for-word. Dialogue should be chosen carefully. Don’t try to be too realistic. Our actual speech wouldn’t make great dialogue. We say â€Å"um† and â€Å"uh† a lot. We trail off in the middle of sentences. We change subjects without warning. Good dialogue should approximate real speech, not mimic it. To give you an example of what dialogue should look like here’s the opening of a short story I wrote, titled Me: What do we do now? Shadows from the single candle flickered on Heathers face. It masked the basement smell with green apple. She rolled her eyes at me. Nothing, Kristy. Just wait. I sighed. I was sick of waiting. My arms, and my butt, were starting to hurt. I drummed my fingers impatiently on the plastic pointer thingy. Stop it, Heather hissed. Youll make them mad. Make who mad? The spirits, stupid. Right. The spirits. Like I really believed the spirits were going to talk to us on a piece of Parker Brothers cardboard. The words exchanged between Kristy and Heather let us know something about their respective moods and character traits. In just that brief opening, we already know something about them. So how can you improve your dialogue? Read. Pay attention to what your favorite authors do well, and what they dont. Listen. Pay attention to what natural speech sounds like, and be sure to use those natural rhythms in your writing. Read aloud. Read your own dialogue out loud, to yourself or to a friend, to test yourself. Youll be writing dialogue like a pro before you know it! Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Fiction Writing category, check our popular posts, or choose a related post below:Compared "to" or Compared "with"?Confused Words #3: Lose, Loose, Loss45 Idioms with "Roll"

Product design overview Coursework Example | Topics and Well Written Essays - 250 words

Product design overview - Coursework Example The design places open drawers underneath the table with elevated sides and fluid mechanical structure for easy and minimal effort in sliding the drawers and for tagging along of the product. With no doubts, this concept of a product is actually possible to render. The product is viable and can be made by the Just Add Glue workers who have certain limitations because there are already existing counter tables with drawers that are industry made by workers with basic molding tools. Although existing, these counters are made of driftwood and tiles which make these existing counter drawers hard to maneuver, not made for mobility, and are not geared for the elderly people. These existing counters are hard and heavy to open the drawers, and impossible to tag along because of the material. On the contrary, the Tag-along product is actually a portable counterpart of these kitchen counters that already exist. This can be produced by the JAG workforce since simple molding tools can produce the Tag-along table. The feasibility of this project is unquestionable as it can be easily moved along in the kitchen while storing all the kitchen necessities. It is lightweight which makes the target consumers, which are old people, taken into consideration. The target market is real because there is a need for elderly people to be effort efficient when they move about the kitchen. As seen in the Survey Results Analysis, there were actually real people who were willing to pay the average of 60$ from 67% of the senior respondents for the Tag-along Table product. These consisted of 47% who thought 60$-80$, 20% of the respondents who were willing to pay 40$-60$, These target market range from the 50-80 year old elderly people in the suburbs of Eastern and Western Sydney. According to Australian Bureau of Statistics In June 2010, there has actually

Improving Learning and Achievement Coursework Example | Topics and Well Written Essays - 1250 words - 1

Improving Learning and Achievement - Coursework Example The two authors also suggest that an ethic of care must always be undertaken to support the academic achievement of the multicultural students which is often marginalized by schooling. In most cases, the achievement and success of students in a multicultural setting often depends on a wide range of academic and non-academic factors some of which may include enthusiasm and motivation of the students for school, family and community support and the availability of learning opportunities in schools. This paper critically analyses the learning at King Middle School and provides recommendations for improving the learning and achievement of all the students regardless of their diverse ethnic and cultural backgrounds. King Middle School currently serves one of the most racially, ethnically, culturally and economically diverse neighborhoods in Maine state. For example, approximately 120 students of the schools population of about 500 speak almost 28 languages and can trace their origins from 17

Identity among American Indians Essay Example | Topics and Well Written Essays - 1250 words

Identity among American Indians - Essay Example outdated practice as the quantum blood policy can be seen not only as a way for the federal government to reduce the number of Indians who are dependent on its support but also as a way of eventually forcing the dissolution of Indian tribal groupings in time and the eventual assimilation into the mainstream American way of life. In reality, the majority, if not all, the current Indians can be said to be of mixed blood to a certain degree. Miscegenation between European settlers and Indians began within the first century of European arrival in North America and has continued since then to modern times. Moreover, as the other racial groups came to America, they also inevitably mixed with the Indians. In the 2000 census more than 1.6 million American Indians reported descent from two or more races and at the beginning of the twenty first century, at least 40% of American Indians were of mixed blood. The lives of Indians is always complicated by the non Indian opinion of how the Indians should look and act because they are often envisioned as noble savages and are expected to look and act just the way their ancestors did during the time of the Pilgrims at Plymouth or as they are depicted in books and movies. What most people in America do not realize is that the Indians have developed and adapted to the modern world just as they themselves have and that their cultures today are not so different to be distinguishable. It is a fact that many of them live and work in the urban areas of America and that they are so well assimilated that it would be very hard to actually recognize them to be phenotypic Indians. A large number of Indians are marrying outside their own communities and in doing so, the number of mixed race Indians has also increased dramatically. This brings us... Some Indians identify very strongly with their native cultures and actively participate in them while others are all for the abandonment of their culture and see the adoption of mainstream American culture as the only way to secure their future. There are others who take a stand in the middle believing that the best course is to adopt the best from both Indian and American cultures and use them as a basis for their future. The majority of those who support the latter are mixed blood Indians who tend to identify with both cultures but are unable to comfortably fit within either culture. Most of the young unemployed Indians in the reservations would prefer to abandon their culture and go to the cities where they feel that there are better opportunities for them than in the reservations. There are however some Indians who have experienced mainstream American culture and have not found it to be fulfilling. This has led to their rediscovery of their native culture and their participation in it which has filled a void within them. In conclusion, it is my opinion that the current means of identifying and determining who can be considered an Indian and who cannot should be changed. It is my belief that all people with Indian blood, however minimal should be identified as an Indian because doing otherwise as it is being done today is very discriminatory. It should be remembered that no race in the world, whether red, black, white, or yellow, is genetically pure because over the ages, racial mixing has been inevitable.

Local Agenda 21 Guidelines

Local Agenda 21 Guidelines The concept of Local Agenda 21 was first introduced in 1987 at a meeting of world leaders in Norway. During that meeting the participants agreed that the planet has to adopt policies of sustainable development in order to move forward. Officially the Local Agenda 21 was then introduced at the Rio Earth Summit in 1992, organised by the United Nations where more than 100 countries and representatives of more than 10000 organizations agreed to work out local agendas for sustainable living. Each country represented was then advised to develop a LA21 plan with the agenda set by the community itself rather than by the central government. Since 1992, more than 6,400 municipalities in 113 countries have been working to accelerate the transition to sustainable, equitable and secure communities. In European Union thousands of Local Authorities have a Local Agenda 21 plan although in countries like Greece for example this initiative is not always under the name of Agenda 21. In the World Summit on Sustainable Development in 2002 there was a review of the progress made in Local Agenda 21. The participants were pleased of the progress made but also pointed out new opportunities to adopt concrete steps and identify quantifiable targets for better implementing Agenda 21 as the best strategies are only as good as their implementation. The major results and announcements from the Johannesburg Summit regarding Local Agenda 21 and Energy were: Increasing energy accessibility Although energy services have been extended to new groups of consumers, there is still a significant number of residents in rural and remote areas still lack access to sufficient energy resources. Changing production and consumption patterns In a lot of countries there was an introduction of policies and programs for encouraging energy conservation and efficiency in various sectors. This had as a result to: Reduce the growth rate of energy consumption. Improve the efficiency of electric power plants, but also the distribution efficiencies and electricity transmission; Support for the preparation of energy audits, The creation of specialized national bodies of expertise in the energy area; and Dissemination for raising public awareness for energy savings and sustainable development. Promotion of renewable sources of energy progress has been achieved in promoting the use of renewable energy technologies. Introduction of cleaner fuels and technologies the last few decades there was a significant increase in the use of natural gas. There was also commercialisation of some new renewable energy. The use of combined-cycle electricity generation systems has also become more common in industries and the electric power sector. Energy and transport There was a great deal of new policies which have been applied throughout the developed and developing countries. For example in European Union there was a band on leaded gasoline. In developing countries like Egypt for example, there was an incentive program in Cairo that supported a switch to natural gas vehicles; The outcome of this initiative was to increase substantial the number of vehicles using natural gas and today there are more than 27000 such vehicles are already in use. Pilot projects to use fuel cells for buses are also under consideration in some parts of the region. Promotion of regional cooperation the 1990s witnessed noticeable progress in regional cooperation in the energy sector. This is manifest by the realisation of a regional electricity grid interconnection between countries in the European Union. Also, as European Union expanded to the East there are now even more opportunities for further cooperation between the old EU countries with the new comers. Finally and perhaps the most important announcement was the launch of Local Action 21 Local Action 21 builds upon the worldwide successes of Local Agenda 21 since Rio. Local Action 21 fills in Agenda 21 in regards the implementation of Agenda 21, it represents a move from Agenda to Action, from plan to practice. Energy In Agenda 21 Energy is a key issue on Agenda 21 as it recognises its importance for human productivity and development. As such, energy receives significant coverage within most of the chapters of Agenda 21. It addresses the importance and the relationship of energy use and sustainable development. In particular explains the importance of energy supply, demand, and suggests ways for the transition from unsustainable to sustainable approaches to energy management. For example in Chapter 4 it states the importance of changing consumption patterns and it gives suggestions of how economies can reduce the use of energy and harmful materials without compromising their growth. This can be achieved by greater efficiency in the use of energy and resources by choosing the right technology and resources to produce goods and services which otherwise would have required significant amounts of energy. Governments should cooperate by giving initiatives to industry to use energy and resources efficiently and with special attention to the environment. In chapter 6 Agenda 21 points out how badly the environment has been damaged as a result of past and present developments in consumption and production patterns and lifestyles in energy production and use of people in developed and developing world, but also because of industrys bad practices. This has as a result hundreds of millions of people to suffer of pollution related conditions. Therefore, in chapter 6 it is suggested to establish environmental health impact assessment procedures for the planning and development of new industries and energy facilities as well as promote the introduction of environmentally sound technologies within the industry and energy sectors. In chapter 7 of the Local Agenda 21 is clearly recognized that the promotion of sustainable energy and transportation is one of the best ways of achieving sustainability. It urges to increase the efforts of energy saving and promote renewable energy techniques and technologies. It calls to use energy efficient building materials and use an integrated approach to buildings as needed. This is important as the building sector today is one of the major user of energy and any energy saving made on this sector will contribute significantly to the reduction of energy use. Chapter 9 recognizes that the protection of the atmosphere is an essential element of sustainable development and as such energy generated air pollution should be reduced. Therefore, all the different energy sources should be used in ways that respect the atmosphere as well as the human health and the environment as a whole. To achieve this, cooperation between different partners is important in order to identify and develop economically viable and environmentally friendly energy sources for meeting the increasing energy needs (in particular for the developing countries). The above shows that energy development, efficiency and consumptions are one of the main issues of Agenda 21. Energy is well understood that is essential to both social improvement and economic development and contributes to better quality of life. In the last few decades has been realised that much of the worlds energy, is produced and consumed in ways that could not be sustained if technology were to remain constant and if overall quantities were to increase substantially. According to recent scientific findings the need to control atmospheric emissions of greenhouse and other gases and substances, will increasingly need to be based on the efficient use of energy (in terms of production, transmission, distribution and consumption), and on growing reliance on environmentally sound energy systems, such as new and renewable sources of energy. This means that all energy sources will need to be used in ways that respect the atmosphere, human health and the environment as a whole. At the moment there are significant constraints to increasing the environmentally sound energy supplies in developing world such as the world economic crisis. Agenda 21 Guidelines In order to overcome any barriers and help countries and people adopt to Local Agenda commitments, Agenda 21 sets up guidelines for activities that governments at the appropriate level, with the cooperation of the relevant United Nations bodies and, as appropriate, intergovernmental and non-governmental organizations, and the private sector, should follow. These are: Environmentally sound energy sources Cooperate in identifying and developing environmentally sound energy sources and economically viable to support the availability of increased energy supplies to promote sustainable development efforts, specially in developing countries; Environmental Impact assessments Promote the development at the national level of appropriate methodologies for making integrated energy, economic and environment policy decisions for sustainable development, through environmental impact assessments; Modernisation of old power stations Promote the research, development, transfer and use of superior energy-efficient practices and technologies, including endogenous technologies in all relevant sectors, giving special attention to the modernization and rehabilitation of power systems; Promotion of renewable energy technology Overcome any barriers found in the way of the development of renewable energy technology to promote the research, development, transfer and use of technologies and practices for renewable energy systems such as biomass energy technologies, wind energy, solar technologies hydro and others. Energy capacities Promote the development of institutional, planning, scientific and management capacities, in order to encourage policies which targets energy efficiency and environmental protection. Energy diagnosis of energy supply mixes Study current energy supply mixes in order to increase in an economically efficient manner, in developing and developed countries, the use of environmentally sound energy systems and overcome any barriers to their development and use. Evaluation and promotion of cost effective policies Improvement of energy efficiency by promoting cost-effective policies in accordance with national socio-economic development and environmental priorities of a country. Good planning and programme management Build capacity for programme management and energy planning in energy efficiency, as well as for the development, introduction, and promotion of new and renewable sources of energy; Establishment of standards Promote appropriate emission standards or recommendations and energy efficiency at the national level, aimed at the development and use of technologies that minimize undesirable impacts on the environment; Education awareness programs Encourage awareness-raising programs at the local, national and regional levels concerning how energy affects the environment and what can be done to minimise our environmental footprint by wise use of energy. Energy labelling Establish, in cooperation with the private sector, labelling programmes for products to inform consumers of energy consumption and benefits of choosing the most efficient products. In summary Agenda 21 and Local Action 21 as it was introduced in a later stage sets up some main objectives for the energy. The basic and most important objective is to reduce adverse effects on the atmosphere from the energy sector. This can be done by promoting policies or programmes, as appropriate, to increase the contribution of environmentally sound and cost-effective energy systems, such as new and renewable ones, through less polluting and more efficient energy production, transmission, distribution and use. In order to meet this objective it should be understood the need for equity, adequate energy supplies and increasing energy consumption in developing countries. In particular it should be taken into consideration countries that are highly dependent on income generated from the production, processing and export, and/or consumption of fossil fuels and associated energy-intensive products and/or the use of fossil fuels for which countries have serious difficulties in switchi ng to alternatives, but also countries that are highly vulnerable to adverse effects of climate change. In European Union, although there was a significant progress on the implementation of Agenda 21 there are still lots that need to be done. The policies and tools that have been used by the EU are numerous and it is not of the scope of this document to mention, therefore we mention just three key targets that has been set up by EU to be met by 2020, these are: Cut off at least 20% in greenhouse gas emissions from all primary energy sources compared to 1990 levels. 20% of energy consumption should come up by renewable sources and Achieve a 20% energy saving by 2020 in energy consumption through energy efficiency. The above targets could only be achieved if citizens act responsible on how they use energy by recognising that the way they choose to live has a direct impact to the environment.

The Federal Reserve System :: essays research papers

The Federal Reserve System was founded by Congress in 1913, it began to operate in Nov., 1914. Its setup, although somewhat altered since its establishment, particularly by the Banking Act of 1935, has remained substantially the same. Structure The Federal Reserve Act created 12 regional Federal Reserve banks, supervised by a Federal Reserve Board. Each reserve bank is the central bank for its district. The boundary lines of the districts were drawn in accordance with broad geographic patterns of business, and the banks were placed in Boston, New York City, Philadelphia, Cleveland, Richmond, Atlanta, Chicago, St. Louis, Minneapolis, Kansas City, Dallas, and San Francisco. In addition some of the regional banks have one or more branch banks attached to them. All national banks must belong to the system, and state banks may if they meet certain requirements. Member banks hold the bulk of the deposits of all commercial banks in the country. Each member bank is required to own stock in the Federal Reserve bank of its district and must maintain legal reserves on deposit with the district reserve bank. The required reserves are proportionate to the member bank’s own deposits, the proportion varying according to the location of the member bank and the character of its deposits. Each reserve bank is managed by a board of nine directors (three appointed by the Federal Reserve Board, six by the local member banks). The Federal Reserve System’s Board of Governors designates one of the federally appointed directors as chairman and Federal Reserve agent; it is the chairman’s duty to report to the Board. The board of directors appoints the bank’s president and other officers and employees. The operations of the Federal Reserve banks, although not conducted primarily for profit, yield an income that is ordinarily sufficient to cover expenses, to pay a 6% cumulative dividend annually on the stock held by member banks, to make additions to surplus, and to provide the U.S. Treasury with over $1 billion a year in revenue. The Board of Governors of the Federal Reserve System—the national supervisory agency—is composed of seven members appointed for 14-year terms by the President. Its offices are in Washington, D.C. The Federal Open Market Committee, created later (1923) than the system’s other divisions, comprises the seven members of the Board of Governors and five representatives of the Federal Reserve banks; it directs the purchases and sales by the reserve banks of federal government securities and other obligations in the open market.

Reaction Paper Leadership Essay

Leaders are made and not born. Leadership skills can be thought to anyone who is willing and given an opportunity to lead an organization. It is important have someone to continue the goals of a company. There are some qualities a great leader should have: Be strong when you are week – This is very important for developing a leader. You need to give them the opportunity to grow strong and they will learn from their own experience in leadership especially when a leader is weak, he has no choice but to become strong. Be brave when you are scared – Risks are very essential in business. You need to be brave to take risks. In developing a leader, it might be risky because they might fail their tasks but learning takes time and someone needs to experience failure in order to succeed. Be humble when you are victorious – Executive leaders don’t shout their success, instead they remain humble and silent. The more you show your achievements, the more people will env y you and will try to destroy you. A few days ago, I had this opportunity to attend a gathering with successful salesman. We played dice game and everyone is aiming for the first price. Theirs this one man beside me, he said that he didn’t want to get the first price because he didn’t want too much greedy, any price will do. I knew this guy as a successful man but he dress and live very simple. The moral lesson I learned is that you don’t need to be greedy and live elegant in life, you just need to stay humble. As a leader, you need to stay humble to your employees. The business world is very crucial place and having too much pride and envy will not earn you anything. Sometimes when the company has too much greediness, they will became impromptu in investing without thinking further and this might became the cause of their downfall. Look at the mirror and not on the window – a great leader don’t need to hear negative feedbacks form others, they look at their self and improve. Other people might tell you that you can’t achieve anything in life or other people will judge you. The important is that you know yourself that you can reach you goals and if ever they judge your capabilities, prove it to them that their wrong. You can’t  explain to everyone that why they shouldn’t judge you, instead make this as your motivation to change other’s belief on you. A great leader is honest of what he/she is capable of. You don’t need to pretend of what you have and promise to a person, you will just break people’s trust on you. Trust is your most important assent – Great companies expands and continually growing because of the people who trust them. They use this trust to get investors and stock holders. They trust this companies that they will became successful someday. Leaders need to gain trust from their employees. If your employee’s don’t trust you, they will not follow your advice and your commands.

Employment Torts: Information Guide

September 16, 2006 Worksheet 1 EMPLOYMENT TORTS Employer’s Liability 1. Introduction The basis of the liability of an employer for negligence in respect of injury suffered by his employee during the course of the employee’s work is twofold: 1. He may be liable for breach of the personal duty of care which he owes to each employee; 2. He may be vicariously liable for breach by one employee of the duty of care which that employee owes to his fellow employees. The action against the employer for damages by the employee who suffers personal injury on the job is only one of the methods available for compensation for workplace accidents. . Common Law Duties of the Employer There are essentially implied terms of the contract of employment – ‘It is quite clear that the contract between employer and employed, involves on the part of the former the duty of taking reasonable care to provide proper appliances, and to maintain them in a proper condition, and so to carry on his operations as not to subject those employed by him to unnecessary risk†¦Ã¢â‚¬  per Lord Herschell in Smith v. Baker This was later refined in Wilsons and Clyde Coal Co v. English and in Davie v.New Merton Board Mills Ltd. The duty is now regarded as four-fold and is non-delegable. In sum, the employer must take reasonable care to provide: 1. A competent staff of workers; 2. Adequate plant and equipment; 3. A safe system of working; and 4. A safe place of work. The common law duty of an employer to his employees was enunciated in Davie v. New Merton Board Mills Ltd [1959] 1 All ER 346 as a duty to take reasonable care for their safety i. e. you owe an employee a duty of care not to cause them damage.In that case, in 1946 an old-established firm of toolmakers made a drift (a tool consisting of a tapered bar of steel about one foot long) which had a latent defect, viz, excessive hardness of the steel due to negligent heat treatment. In July, 1946, the manufacturers sold t he drift to B & Co Ltd reputable suppliers of tools of this kind, from whom, in the same month, the employers of D bought at a reasonable price a batch of drifts, including this tool. The defect in the drift was not discoverable on inspection and no intermediate examination by the employers between the times of its manufacture and of its use was reasonably to be expected.Between July, 1946, and March, 1953, the drift was seldom, if ever, used, but in March, 1953, D used it in the course of his employment as a maintenance fitter. Owing to the defect in its manufacture, a piece flew off the drift when it was struck with a hammer by D in the course of using it, and destroyed the sight of his left eye. There was no negligence in the employers’ system of maintenance and inspection and the accident was solely due to the defect in the drift.HELD: -The employers were not liable to D for the injury caused to him by the defective drift, because they had fulfilled their duty to him as t heir servant, namely, a duty to take reasonable care to provide proper appliances, and were not responsible for the negligence of the manufacturers, who had no contractual relationship with the employers and in manufacturing the tool were not acting as persons (whether servants, agents or independent contractors) to whom the employers had delegated the performance of any duty that it was for the employers to perform.Per Lord Tucker: in my view, it would have made no difference if the drift had been purchased [by the employers] direct from the manufacturers. An employer may, however, render himself liable to his servant for injury suffered by him by reason of a faulty specification prepared by the employer for the manufacturer, or where the manufactured article may require inspection or test after delivery. The duty is not an absolute one and can be discharged by the exercise of due are and skill, which is a matter to be determined by a consideration of all the circumstances of the p articular case. It is well established that every employer has a duty at common law to provide: 1. A competent staff of men; 2. Adequate plant and equipment; 3. A safe system of working, with effective supervision; and 4. A safe place of work. Wilsons and Clyde Coal Ltd v English [1937] 3 All ER 628In an action by a miner against his employers for damages for personal injury alleged to be due to the negligence of the employers in that they had failed to provide a reasonably safe system of working the colliery, questions were raised (1) whether the employers were liable at common law for a defective system of working negligently provided or permitted to be carried on by a servant to whom the duty of regulating the system of working had been delegated by the employers, the employers' board of directors being unaware of the defect, and (2) if they were liable, whether the employers were relieved of their liability in view of the prohibition contained in the Coal Mines Act 1911, s2(4), against the owner of a mine taking any part in the technical management of the mine unless he is qualified to be a manager.HELD: – It was held by the House of Lords that (1) the employers were not absolved from their duty to take due care in the provision of a reasonably safe system of working by the appointment of a competent person to perform that duty. Although the employers might, and in some events were bound to, appoint someone as their agent in the discharge of their duty, the employers remained responsible. (2) the doctrine of common employment does not apply where it is proved that a defective system of working has been provided. To provide a proper system of working is a paramount duty, and, if it is delegated by a master to another, the master still remains liable.Lord Wright stated (at p644A) that the whole course of authority consistently recognises a duty which rests on the employer, and which is personal to the employer, to take reasonable care for the safety o f his workmen, whether the employer be an individual, a firm, or a company, and whether or not the employer takes any share in the conduct of the operations (at p644A). The obligation is threefold, â€Å"the provision of a competent staff of men, adequate material, and a proper system and effective supervision† (at p640C). 1. COMPETENT STAFF OF WORKERS An employer will be in breach of this duty if he engages a workman who has had insufficient training or experience for a particular job and, as a result of that workman’s incompetence, another employee is injured.Competence here usually relates to qualifications, training and experience. It may also include the disposition of the employee. Ifill v. Rayside Concrete Workers Ltd (1981) 16 Barb. LR The plaintiff and J were employed by the defendants as labourers. They were both known by the defendants to have a propensity for ‘skylarking’ at work, and had been warned on at least two occasions not to do so. One day, J picked the plaintiff up and cradled him in his arms, saying he was ‘light as a baby’ and singing ‘Rock-a-bye-baby’. As J carried the plaintiff forward, he tripped over a pipeline and both J and the plaintiff fell into a cement mixer, which was only partly covered, both of them sustaining injuries.The plaintiff brought an action against the defendant for: (a) breach of statutory duty; and (b) negligence at common law. HELD: -(a) the cement mixer was a ‘dangerous part of machinery’ within what was then s 10(1) of the Factories Act, Cap 347, and the defendants were in breach of their absolute statutory duty to fence it securely; (b) the defendants were in breach of their duty at common law not to expose the plaintiff to risks of danger emanating from indisciplined fellow employees, and were liable in negligence; (c) the plaintiff was guilty of contributory negligence and his damages would be reduced by 50%. Douglas CJ said: †¦it is obv ious that the plaintiff and the second defendant each had a marked propensity for skylarking.They persisted in it, in spite of warnings†¦in my view, mere warnings were totally inadequate for such serious cases of indiscipline†¦Rayside was negligent in exposing its employees, including the plaintiff, to the risk of injury from the second defendant’s skylarking†¦the plaintiff was contributorily negligent in participating in the skylarking activity which caused his injury. â€Å"†¦upon principle it seems to me that if, in fact, a fellow workman is not merely incompetent but, by his habitual conduct, is likely to prove a source of danger to his fellow employees, a duty lies†¦on the employers to remove that source of danger†¦Ã¢â‚¬  Hudson v. Ridge Manufacturing Co Ltd [1957] 2 QB 348 The defendants had had in their employ, for a period of almost four years, a man given to horseplay and skylarking. He had been reprimanded on many occasions by the for eman, seemingly without any result.In the end, while indulging in skylarking, he tripped and injured the plaintiff, a fellow employee who sued his employer for failing to take reasonable care for his safety. HELD: -Straetfield J said: This is an unusual case, because the particular form of lack of care by the employers alleged is that they failed to maintain discipline and to take proper steps to put an end to this skylarking, which might lead to injury at some time in the future†¦the matter is covered not by authority so much as principle. It is the duty of employers, for the safety of employees, to have reasonably safe plant and machinery. It is their duty to have premises which are similarly reasonably safe.It is their duty to have a reasonably safe system of work. It is their duty to employ reasonably competent fellow workmen†¦it seems to me that if, in fact, a fellow workman is not merely incompetent but, by his habitual conduct, is likely to prove a source of danger to his fellow employees, a duty lies fairly and squarely on the employers to remove that source of danger. Smith v. Crossley Bros Ltd (1951) 95 SJ 655 Injury was done to the plaintiff, a 16 year old apprentice, by inserting in him, in horseplay, compressed air. At first instance, it was held that the employers had not exercised adequate supervision over the apprentices and that lack of supervision constituted negligence.HELD: -on appeal, it was held that the evidence disclosed no negligence on the part of the employers, because the injury to the plaintiff resulted from what was wilful misbehaviour by the other boys and a wicked act which the employers had no reason to foresee. There was no history of childish behaviour – the employers did not know or ought to have known about the defendant’s propensity for skylarking. 1. ADEQUATE PLANT & EQUIPMENT An employer must take the necessary steps to provide adequate plant and equipment for his workers, and he will be liable to any workman who is injured through the absence of any equipment which is obviously necessary or which a reasonable employer would recognise as being necessary for the safety of the workman.The employer must take reasonable care to ensure that damage is not caused to the employee by the absence of necessary safety equipment such as goggles, safety helmets, shoes etc. or by the presence of unsafe machinery. Sammy v. BWIA (1988) High Court, TT, No 5692 of 1983 (unreported) The plaintiff, who was employed by the defendant as a mechanic, was sent to repair a vehicle which had broken down on a ramp at Piarco Airport. While attempting to start the vehicle, it caught fire. No fire extinguishers were provided either in the vehicle being repaired or in the service vehicle and, in attempting to put out the fire with a cloth, the plaintiff suffered burns.HELD: – Gopeesingh J held the defendant liable for breach of its common law duty to the plaintiff to take reasonable care for his safe ty,†¦by not exposing him to safety to any unnecessary risk during the performance of his duties as an employee†¦By failing to provide fire extinguishers on these vehicles, the defendant clearly exposed the plaintiff to unnecessary risk when the fire started on the vehicle†¦The defendant was under a duty to provide proper safety appliances on these vehicles to safeguard the plaintiff in the event of such an occurrence. Morris v. Point Lisas Steel Products Ltd (1989) High Court, TT, No 1886 of 1983 (unreported) The plaintiff was employed as a machine operator at the defendant’s factory. While the plaintiff was using a wire cutting machine, a piece of steel flew into his right eye, causing a complete loss of sight in that eye. Holding the employer in breach of its common law duty of care in failing to provide goggles; HELD: – Hosein J said that†¦since the risk was obvious to the defendant and not insidious, the defendant ought to have made goggles avai lable and also given firm instructions that they must be orn, and the defendant ought to have educated the men and made it a rule of the factory that goggles must be worn, since, if an accident did happen, the probability was likely to be the loss of sight of one or both eyes. Forbes v. Burns House Ltd (2000) Supreme Court, The Bahamas, No 432 of 1995 (unreported) An office worker was injured at the workplace when a swivel chair on which she was sitting collapsed. HELD: – the employer was in breach of its duty to inspect and maintain office equipment, including the chair. McGhee v. National Coal Board [1972] 3 All ER 1008 The appellant was sent by the respondents, his employers, to clean out brick kilns.Although the working conditions there were hot and dirty, the appellant being exposed to clouds of abrasive brick dust, the respondents provided no adequate washing facilities. In consequence the appellant had to continue exerting himself after work by bicycling home caked wit h sweat and grime. After some days working in the brick kilns the appellant was found to be suffering from dermatitis. In an action by the appellant against the respondents for negligence the medical evidence showed that the dermatitis had been caused by the working conditions in the brick kilns. The evidence also showed that the fact that after work the appellant had had to exert himself further by bicycling home with brick dust adhering to his skin had added materially to the risk that he might develop the disease.It was held in the Court of Session that the respondents had been in breach of duty to the appellant in failing to provide adequate washing facilities but that the appellant’s action failed because he had not shown that that breach of duty had caused his injury, in that there was no positive evidence that it was more probable than not that he would not have contracted dermatitis if adequate washing facilities had been provided. On appeal, HELD: – A defender was liable in negligence to the pursuer if the defender’s breach of duty had caused, or materially contributed to, the injury suffered by the pursuer notwithstanding that there were other factors, for which the defender was not responsible, which had contributed to the injury. Accordingly the respondents were liable to the appellant, and the appeal would be allowed, because— (i) (per Lord Reid, Lord Wilberforce, Lord Simon f Glaisdale and Lord Salmon) a finding that the respondents’ breach of duty had materially increased the risk of injury to the appellant amounted, for practical purposes, to a finding that the respondents’ breach of duty had materially contributed to his injury, at least (per Lord Wilberforce) in the absence of positive proof by the respondents to the contrary; (ii) (per Lord Kilbrandon) on the facts found, the appellant had succeeded in showing that, on a balance of probabilities, his injury had been caused or contributed to by the re spondents’ breach of duty 2. SAFE SYSTEM OF WORKING An employer must organise a safe system of working (includes a duty to take reasonable precautions to protect employees from attacks by armed bandits) and must ensure as far as possible that the system is adhered to.In addition to supervising workmen, the employer should organise a system which itself reduces the risk of injury from the workmen’s foreseeable carelessness. This has been described as â€Å"†¦the sequence in which the work is to be carried out the provision in proper cases of warnings and notices and the issue of special instructions†¦Ã¢â‚¬  per Lord Greene MR Legall v. Skinner Drilling (Contractors) Ltd (1993) High Court, Barbados, No 1775 of 1991 (unreported) The defendant company was engaged in oil drilling. The plaintiff was employed by the defendant as a derrick man, one of his duties being the removal of nuts and bolts from the rigs as part of the ‘rigging down’ operation. In order to remove a bolt from a rig platform about 10 ft from the ground, the plaintiff was given an empty oil drum to stand on.The drum toppled over and the plaintiff fell to the ground and was injured. HELD: – the defendant, by failing to ensure that its workers used ladders to reach high platforms and to warn the plaintiff of the danger of standing on the oil drum, was in breach of its common law duty to provide a safe system of work. Bish v. Leathercraft Ltd. (1975) 24 WIR 351 The plaintiff was operating a button pressing machine in the defendants’ factory when a button became stuck in the piston. While attempting to dislodge the button with her right index finger, the plaintiff’s elbow came into contact with an unguarded lever, which caused the piston to descend and crush her finger.HELD: – The Jamaican Court of Appeal held that the defendants were in breach of their common law duties to provide adequate equipment and a safe system of work, in that: (a) the button had not been pre-heated, which was the cause of its becoming stuck in the position; (b) no three inch nail, which would have been effective to dislodge the button, was provided for the plaintiff’s use, with the result that the plaintiff had to resort to using her finger; and (c) the lever was not provided with a guard, which would most probably have prevented the accident which occurred. Qualcast v. Haynes [1959] AC 743 Hurdle v. Allied metals Ltd. [1974] 9 Barb LR 1 3. SAFE PLACE OF WORK An employer has a duty to take care to ensure that the premises where his employees are required to work are reasonably safe. The duty exists only in relation to those parts of the workplace which the employee is authorised to enter.An employee who enters an area which he knows to be ‘out of bounds’, will generally be treated as a trespasser. As the occupier, in most cases, of the workplace, the employer is under a duty to the employee (a lawful visitor) to take reasonable care to see that the premises are reasonably safe for the purpose of doing the job. Where the employer is not the occupier of the workplace, there is still a requirement that he take reasonable care to ensure that the worker is reasonably safe. This will vary with the circumstances. A significant question is whether the employer knew of or ought to have been aware of the danger and what steps were to be regarded as reasonable in providing a safe place of work. Alcan (Jamaica) Ltd v.Nicholson (1986) Court of Appeal, Jamaica, Civ App No 49 of 1985 (unreported), per Hall J A welder, during his lunch break, left his area of work at a bauxite installation and entered a location called a ‘precipitation area’, in search of cigarettes. There, he suffered a serious eye injury when caustic soda, which was stored in tanks, splashed into his eye. HELD: – the employer/occupier was held not liable for the injury, since the welder was a trespasser in the area who kne w he had no right to be there and was well aware of the dangers of caustic soda. Watson v. Arawak Cement Co Ltd (1998) High Court, Barbados, No 958 of 1990 (unreported) The plaintiff was employed by the defendant as a general worker. He was sent to work on a ship which was in the possession of a third party.While attempting to leave the ship at the end of his day’s work, the plaintiff fell from an unlit walkway inside the ship and sustained injuries. HELD: – Chase J held the defendant liable on account of its failure to provide a suitable means of egress from the ship and to instruct the plaintiff as to the method of leaving the vessel. Another aspect of the employer’s duty to exercise reasonable care and not to expose his servants to unnecessary risk in his duty to provide a reasonable safe place of work and access thereto. This duty does not come to an end merely because the employee has been sent to work at premises which are occupied by a third party and not the employer. The duty remains throughout the course of his employment.General Cleaning Contractors Ltd v. Christmas [1953] AC 180 The plaintiff, a window cleaner, was employed by the defendants, a firm of contractors, to clean the windows of a club. While, following the practice usually adopted by employees of the defendants, he was standing on the sill of one of the windows to clean the outside of the window and was holding one sash of the window for support, the other sash came down on his fingers, causing him to let go and fall to the ground, suffering injury. On a claim by him against the defendants for damages; HELD: – it was held by the House of Lords that even assuming that other systems of carrying out the work, e. g. by the use of safety belts or ladders, were impracticable, the defendants were still under an obligation to ensure that the system that was adopted was as reasonably safe as it could be made and that their employees were instructed as to the steps to b e taken to avoid accidents; the defendants had not discharged their duty in this respect towards the plaintiff; and, therefore, they were liable to him in respect of his injury. Per Lord Reid: Where a practice of ignoring an obvious danger has grown up it is not reasonable to expect an individual workman to take the initiative in devising and using precautions. It is the duty of the employer to consider the situation, to devise a suitable system, to instruct his men what they must do, and to supply any implements that may be required.Since the employer’s liability is merely another form of negligence, the employee must establish not only the breach of the duty of care owed to her, but also that it legally caused the resultant damage, and that such damage was not too remote. Walker v. Northumberland [1995] 1 All ER 737 The plaintiff was employed by the defendant local authority as an area social services officer from 1970 until December 1987. He was responsible for managing fo ur teams of social services fieldworkers in an area which had a high proportion of child care problems. In 1986 the plaintiff suffered a nervous breakdown because of the stress and pressures of work and was off work for three months. Before he returned to work he discussed his position with his superior who agreed that some assistance should be provided to lessen the burden of the plaintiff's work.In the event, when the plaintiff returned to work only very limited assistance was provided and he found that he had to clear the backlog of paperwork that had built up during his absence while the pending child care cases in his area were increasing at a considerable rate. Six months later he suffered a second mental breakdown and was forced to stop work permanently. In February 1988 he was dismissed by the local authority on the grounds of permanent ill health. He brought an action against the local authority claiming damages for breach of its duty of care, as his employer, to take reaso nable steps to avoid exposing him to a health-endangering workload.HELD: – It was held in the QBD that where it was reasonably foreseeable to an employer that an employee might suffer a nervous breakdown because of the stress and pressures of his workload, the employer was under a duty of care, as part of the duty to provide a safe system of work, not to cause the employee psychiatric damage by reason of the volume or character of the work which the employee was required to perform. On the facts, prior to the 1986 illness, it was not reasonably foreseeable to the local authority that the plaintiff's workload would give rise to a material risk of mental illness. However, as to the second illness, the local authority ought to have foreseen that if the plaintiff was again exposed to the same workload there was a risk that he would suffer another nervous breakdown which would probably end his career as an area manager.The local authority ought therefore to have provided additiona l assistance to reduce the plaintiff's workload even at the expense of some disruption of other social work and, in choosing to continue to employ the plaintiff without providing effective help, it had acted unreasonably and in breach of its duty of care. It followed that the local authority was liable in negligence for the plaintiff's second nervous breakdown and that accordingly there would be judgment for the plaintiff with damages to be assessed. Sutherland v. Hatton [2002] IRLR 263 The claimant in this case was a secondary school teacher who suffered from depression and a nervous breakdown and was initially awarded ? 90,765.HELD: – The CA found that Hatton gave the school she worked for no notice that she was growing unable to cope with her work. She had suffered some distressing events outside of work, which the school could reasonably have attributed her absence to, particularly as other staff did not suffer from health problems as a result of restructuring in the scho ol, and the fact that she did not complain. The court held that as teaching cannot be regarded as intrinsically stressful; the school had done all they could reasonably be expected to do. It was unnecessary to have in place systems to overcome the reluctance of people to voluntarily seek help. The guidelines set up by the CA are as follows: 1.There are no special control mechanisms relating to work-related stress injury claims; ordinary principles of employers’ liability apply. 2. The â€Å"threshold† question is whether this kind of harm to this particular employee was reasonably foreseeable. 3. Foreseeability depends on what the employer knows or should know about the individual employee. Unless aware of a particular problem or vulnerability, the employer can usually assume that the employee can withstand the normal pressures of the job. 4. The test is the same for all occupations; no occupation is to be regarded as intrinsically dangerous to mental health. 5. Reason able foreseeability of harm includes consideration of:  ·Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   the nature and extent of the work   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   whether the workload is much greater than normal  ·Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   whether the work is particularly intellectually or emotionally demanding for that employee  ·Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   whether unreasonable demands are being made of the employee  ·Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   whether others doing this job are suffering harmful levels of stress  ·Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   whether there is an abnormal level of sickness or absenteeism in the same job or department. The employer can take what the employee tells it at face value, unless it has good reason not to, and need not make searching enquiries of the employee or his or her medical advisors. 6. The employer can take what the employee tells it at face value, unless it has good reason not to and need not make searching enquiries of the employee or his/her medical advisors. 7. The duty to take steps is triggered by indications of impending harm to health, which must be plain enough for any reasonable employer to realise it has to act. 8.There is a breach of duty only if the employer has failed to take steps that are reasonable in the circumstances, bearing in mind the magnitude of the risk of harm occurring, the gravity of that harm, the costs and practicability of preventing it and the justifications for running the risk. 9. The employer’s size, scope, resources and demands on it are relevant in deciding what is reasonable (including the need to treat other employees fairly, for example in any redistribution of duties). 10. An employer need only take steps that are likely to do some good; the court will need expert evidence on this. 1. An employer that offers a confidential advice service, with appropriate counselling or treatment services is unlikely to be found in breach of duty. 2.If the only reasonable and effective way to prevent the injury would be to dismiss or demote the employee, the employer will not be in breach in allowing a willing employee to continue working. 3. In all cases, it is necessary to identify the steps that the employer could and should have taken before finding it in breach of duty of care 4. The claimant must show that that breach of duty has caused or materially contributed to the harm suffered. It is not enough to show that occupational stress caused the harm; it must be linked with the breach. 5. Where the harm suffered has more than one cause, the employer should only pay for that part caused by its wrongdoing, unless the harm is indivisible. 1.Assessment of damages will take account of pre-existing disorders or vulnerability and the chance that the claimant would have suffered a stress-related disorder in any event. Hudson v Ridge Manufacturing [1957] 2 All ER 229 The plaintiff, while at work, was injured through a foolish prank played on him by Chadw ick, a fellow workman. Over a period of about four years C had been in the habit of indulging in horseplay during his work, at the expense of the plaintiff and the other workmen. The employers knew about C's conduct and had frequently reprimanded him and warned him that someone might one day be hurt, but, although he paid no heed to their reprimands, he was allowed to remain in their employment.In an action by the plaintiff against the employers, claiming damages for negligence at common law; HELD: – it was held at Manchester Assizes that the employers were liable to the plaintiff in damages for breach of their duty at common law to provide competent workmen, because, if a workman, by his habitual conduct, was likely to prove a source of danger to his fellow workmen, it was the employers' duty to remove that source of danger, and the plaintiff's injury was sustained as a result of the employers' failure to take proper steps to put an end to C's horseplay or to remove him from their employment if he persisted in it. Smith v Crossley Brothers Ltd ((1951) 95 Sol Jo 655) considered. Wilson v Tyneside Window Cleaning Co [1958] 2 All ER 265A master's duty to his servant to take reasonable care so to carry out his operations as not to subject his servant unnecessary (see Smith v Baker & Sons [1891] AC at p362) is one single duty applicable in all circumstances, though it may be convenient to divide it into categories (as was done by Lord Wright in Wilsons & Clyde Coal v English [1937] 3 All ER at p640) when dealing with a particular case. So viewed, the question whether the master was in control of the premises, or whether the premises were those of a stranger, becomes merely one of the ingredients, albeit an important one, in considering the question of fact whether, in all the circumstances, the master took reasonable care.A skilled and experienced window cleaner, who knew that he should not trust the handles on windows without first testing them, was freque ntly sent by his employers to clean the windows of a particular customer. The employers did not inspect the customer's premises each time when they sent the window cleaners there, nor did they specifically warn the window cleaner of particular dangers; but they did instruct him to leave uncleaned any window which presented unusual difficulty and which he was in doubt whether he could clean safely, to report the fact to them and to ask for further instructions. There was no evidence of any practice in the trade either of inspecting premises for safety before work or of repeatedly warning workmen of the dangers.While cleaning the outside of a kitchen window, the woodwork of which appeared to the window cleaner to be rotten, of which he knew the sash to be stiff and of which one of the two handles was missing, the window cleaner attempted to pull the window down by the remaining handle. The handle came away in his hand, causing him to lose his balance, fall and sustain severe injuries. In an action by the window cleaner against the employers for alleged negligence exposing him to unnecessary risk; HELD: – it was held by the Court of Appeal that the employers had taken reasonable care not to subject the plaintiff to unnecessary risk, because the danger was an apparent danger, the plaintiff was very experienced at the work, and they had instructed him not to clean windows which it might not be safe to clean; the employers, therefore, were not liable. DEFENCES 1.Volenti non fit injuria is a defence for an employer against an employee. It could apply where an employee is so negligent that it could be said that the employee is completely at fault. 2. An employee's knowledge of the existence of a danger does not in itself amount to consent to run the risk. 3. Contributory negligence is also a defence that an employer may utilise against an employee. However, the courts are reluctant to apply this doctrine. This doctrine does not completely exonerate an employee but in fact reduces the amount of damages (apportionment) given to the employee. 4. Contributory negligence is a defence both to an action in negligence and breach of statutory duty.In general, however, the carelessness of employees as claimants is treated more leniently than the negligence of employers, even where liability rests upon the vicarious responsibility of the employer for the negligence of another employee. Smith v. Baker [1891] AC 325 When a workman engaged in an employment not in itself dangerous is exposed to danger arising from an operation in another department over which he has no control – the danger being created or enhanced by the negligence of the employer – the mere fact that he undertakes or continues in such employment with full knowledge and understanding of the danger is not conclusive to show that he has undertaken the risk so as to make the maxim â€Å"Volenti non fit injuria† applicable in case of injury.The question whether he has so undertaken the risk is one of fact and not of law. And this so both at common law and in cases arising under the Employers Liability Act 1880. The plaintiff was employed by railway contractors to drill holes in a rock cutting near a crane worked by men in the employ of the contractors. The crane lifted stones and at times swung over the plaintiff's head without warning. The plaintiff was fully aware of the danger to which he was exposed by thus working near the crane without any warning being given, and had been thus employed for months. A stone having fallen from the crane and injured the plaintiff, he sued his employers in the County Court under the Employers Liability Act 1880.HELD: – the House of Lords, reversing the decision of the Court of Appeal (Lord Bramwell dissenting), that the mere fact that the plaintiff undertook and continued in the employment with full knowledge and understanding of the danger arising from the systematic neglect to give warning did not prec lude him from recovering; that the evidence would justify a finding that the plaintiff did not voluntarily undertake the risk of injury; that the maxim â€Å"Volenti non fit injuria† did not apply; and that the action was maintainable. ICI v. Shatwell [1965] AC 656 G and J who were brothers, were certificated and experienced shotfirers employed by ICI Ltd.By their employers' rules, and by reg 27(4) of the Quarries (Explosives) Regulations 1959, G and J were required to ensure that no testing of an electric circuit for shotfiring should be done unless all persons in the vicinity had withdrawn to shelter. The statutory duty was imposed on G and J, not on their employers. The risk, which had been explained to G and J, was of premature explosions. On the day of the accident, while a third man had gone to fetch a longer cable so that a shotfiring circuit, which had been made in the course of their employment, could be tested from shelter, G invited J to proceed with him to make a test in the open. G and J were injured by the resulting explosion.On appeal from an award of damages to G (both negligence and breach of statutory duty by J being found at the trial, and the award being of an amount reduced in respect of G's contributory negligence) in an action by G against the employers as vicariously responsible for J's breach of duty; HELD: – the House of Lords said that although J's acts were a contributing cause (Viscount Radcliffe dissenting as regards causation) of G's injury, the employers were not liable because – (1) the employers not being themselves in breach of duty, any liability of theirs would be vicarious liability for the fault of J, and to such liability (whether for negligence or for breach of statutory duty) the principle volenti non fit injuria afforded a defence, where, as here, the facts showed that G and J knew and accepted the risk (albeit a remote risk) of testing in a way that contravened their employers' instructions and t he statutory regulations. (2) (per Viscount Radcliffe) each of them, G and J, emerged from their joint enterprise as author of his own injury, and neither should be regarded as having contributed a separate wrongful act injuring the other.Per Lord Pearce (Viscount Radcliffe concurring): the defence of volenti non fit injuria should be available where the employer is not himself in breach of statutory duty and is not vicariously in breach of any statutory duty through neglect of some person of superior rank to the plaintiff and whose commands the plaintiff is bound to obey, or who has some special and different duty of care. [Editorial Note – There was no breach of statutory duty by the employers: the defence of â€Å"volens† was admitted against vicarious responsibility only †¦ The defence is not available to an employer on whom a statutory obligation is imposed as against liability for his own breach of that obligation. ] Staple v. Gypson Mines Ltd [1953] AC 663 The plaintiff claimed damages on behalf of her husband. There had been a mining accident. A roof fell in the section of the mine where the deceased was working and he was crushed.The deceased and another colleague had been told to bring the rest of the roof down; however, they left part of the roof hanging and then continued working. HELD: – The House of Lords held that the employer was vicariously liable as Mr. Staple consented to continue working and such consent amounted to 80% contributory negligence. Fagelson (1979) 42 MLR 646 Flower v. Ebbw Vale Steel Iron & Coal Ltd [1934] 2 KB 134 The plaintiff brought an action for personal injury alleged to have been sustained by a workman through his employers' breach of their statutory duty under s10 of the Factory and Workshop Act 1901, in not securely fencing a machine for rolling metal sheets in their factory. The workman in the course of his duty was cleaning the machine.To enable this to be done the rollers are set in motion. The safe and simple way to clean them is to take one's stand at the back of the machine and apply emery-cloth or engineers' waste over the iron bar to the upper part of the rollers; for then all the seven rollers are revolving away from the operator. There was some evidence that he had been told to use this method, but it was of a vague and general kind. The employers pleaded that the alleged injury was caused solely by the workman's own negligence in attempting to clean the machine at a wrong part, and omitting to take reasonable care to prevent his left hand from coming into contact with the rollers.The judge held that the machine was dangerous and that it was not sufficiently fenced; but that the workman had acted in disobedience to his orders without any good reason for so acting, and that his disobedience was the proximate cause of the accident. The judge also held that the defence of contributory negligence was open to the employers. Accordingly he gave judgment for the emplo yers. The workman appealed to the Court of Appeal, which affirmed the judgment of the trial judge. HELD: – The House of Lords held that judgment be entered for the employee. The decision of the Court of Appeal was reversed on the ground that the only contributory negligence relied on was disobedience to orders, and that the evidence at the trial was insufficient to prove that the alleged orders were ever given.Consideration was given by Lord Wright (at p214-5) of the circumstances in which contributory negligence may be pleaded as a defence to an action by a workman for personal injuries through a breach by his employers of their duty under s10 (1) (c) of the Factory and Workshop Act 1901, to fence securely all dangerous parts of the machinery in their factory. Per Lawrence J – â€Å"It is not for every risky thing which a workman in a factory may do in his familiarity with the machinery that [he] ought to be held guilty of contributory negligence†¦ 3. Breach of Statutory Duty (Employment) An employer may be under a statutory duty to provide safety equipment to protect his employees from injury, especially where they are operating dangerous machinery.Generally, where a statute provides a criminal penalty for an infringement of one of its provisions, the penalty is normally treated as the only liability to which the offender is subject, and no civil action is usually maintainable infringement against him by the victim of his criminal conduct. However, it has for long been recognised that the statutory duties imposed on an employer to enhance the safety of it employees may form the basis of an action for damages by an injured employee for breach of statutory duty. See Factories Act An employer who fails to provide equipment as required by statute will be liable for breach of statutory duty. An employee who is injured as a consequence of a breach of statutory duty must show: 1. That the act which caused the damage was regulated by the statute; 2.That he was one of the persons whom the statute was intended to protect; and 3. That the damage suffered was of a kind that the statute was intended to prevent. The first two requirements are normally easy to satisfy, but the third may be problematic. Gorris v. Scott (1874) LR 9 Ex 125 A ship-owner was required by statute to provide pens for cattle on board his ship. He failed to do this, with the result that the plaintiff’s cattle were swept overboard. HELD: – that the ship-owner was not liable for the loss, because the damage that the statute was intended to prevent was the spread of contagious diseases, not the sweeping overboard of the cattle. Close v. Steel Co of Wales Ltd [1962] AC 367It was held that a workman who is injured by a dangerous part of machinery which flies out of a machine and injures him cannot base a claim on the statutory obligation that dangerous parts of machinery ‘shall be securely fenced’, because the purpose of the statutory duty is ‘to keep the worker out, not to keep the machine or its product in’. Morris v. Seanem Fixtures Ltd (1976) 11 Barb LR 104, High Court Barbados The plaintiff was employed by the defendants as a shop-hand and fitter. Without being authorised or directed to do so by the defendants, she operated a ‘planer’ at the factory, and in attempting to remove some wood shavings from the machine while it was still in motion, sustained injuries to her hand when it became caught in the machine’s rotating blades. She brought an action against the defendants for negligence and breach of statutory duty.HELD: – (a) the claim in negligence failed, since the plaintiff had not been directed or authorised to use the machine; (b) the claim for breach of statutory duty succeeded. The cutting rotor of the planer was a dangerous part of a machine and the defendants were in breach of the duty imposed by s 10(1) of the Factories Act, Cap 347, in failing to fence or t o provided some other safety device to prevent contact; (c) the plaintiff was guilty of contributory negligence and her damages would be reduced by two-thirds. Walker v. Clarke (1959) 1 WIR 143, Court of Appeal, Jamaica The plaintiff/respondent operated a dough-brake machine in the course of his employment at the defendant’s/appellant’s bakery. The machine had a revolving turntable to feed the dough to rollers, but, as this did not work atisfactorily, the respondent, on the instructions of the appellant, fed the dough to the rollers by hand. While attempting to remove some foreign matter from the machine whilst it was in motion, the respondent put his hand too close to the rollers and his fingers were crushed. HELD: – the rollers were a dangerous part of the machine and, as they were not securely fenced, the appellant was in breach of his statutory duty. Bux v. Slough Metals Ltd [1974] 1 All ER 262 Nimmo v. Alexander Cowan & Sons Ltd [1968] AC 107 4. Occupationa l Health & Safety Legislation This type of legislation applies to all forms of employment with only few exceptions, whereas the Factories legislations apply to only such establishments.Essentially, these Acts provide for the general duties of employers to their employees and to persons other than their employees; the general duties of employees; the rights of employees to refuse to perform dangerous work; administrative and criminal sanctions for contravention of its provisions and specific duties in respect of the safety, health and welfare of those in the establishment. R v. Associated Octel Co Ltd [1997] IRLR 123 R v. Swan Hunter Shipbuilders Ltd [1981] ICR 831 R v. Gateway Foodmarkets Ltd [1997] IRLR 189 October 07, 2006 Worksheet II VICARIOUS LIABILITY Employers are vicariously liable for the torts of their employees that are committed during the course of employment. The expression ‘vicarious liability’ refers to the situation where D2 is liable to P for damages c aused to P by the negligence or other tort of D1.It is not necessary that D2 should have participated in the tort or have been in any way at fault. D2 is liable simply because he stands in a particular relationship with D1. That relationship is normally one of ‘master and servant’, or in modern parlance ‘employer an employee’. DEVELOPMENT OF VICARIOUS LIABIITY In early medieval times a master was held responsible for all the wrongs of his servants. Later as the feudal system disintegrated, the ‘command theory’ emerged, under which a master was liable only for those acts of his servants which he had ordered or which he had subsequently ratified. Later still, with the development and expansion of industry and commerce, the ‘command theory’ fell into disuse for two main reasons: 1.Under modern conditions it was no longer practicable for an employer to always control the activities of his employees, especially those employed in large b usinesses; and. 2. The greatly increased hazards of modern enterprises required a wider range of responsibility on the part of employers than that which had been imposed in earlier times. The theory of vicarious liability which eventually emerged was that a master is liable for any tort committed by his servant in the course of the servant’s employment, irrespective of whether the master authorized or ratified the activity complained of, and even though he may have expressly forbidden it. The modern theory of vicarious liability is based on considerations of social policy rather than fault.It may seem unfair and legally unjustifiable that a person who has himself committed no wrong should be liable for the wrongdoing of another, on the other hand, it may be argued that a person who employs others to advance his economic interests should be held responsible for any harm caused by the actions of those employees, and that the innocent victim of an employee’s tort should b e able to sue a financially responsible defendant, who may in any case take out a policy against liability. The cost of such insurance will, of course, ultimately be passed on to the public on the form of higher prices. However, care should be taken not to hamper business enterprises unduly by imposing too wide a range of liability o employers. Therefore there is a requirement that a master will only be liable for those torts hich his servant committed during the course of his employment-that is, while the servant was doing his job he was employed to do. According to Michael A. Jones, Textbook on Torts, 2000, p379, several reasons have been advanced as a justification for the imposition of vicarious liability: 1. The master has the ‘deepest pockets'. The wealth of a defendant, or the fact that he has access to resources via insurance, has in some cases had an unconscious influence on the development of legal principles. 2. Vicarious liability encourages accident prevention by giving an employer a financial interest in encouraging his employees to take care for the safety of others. 3.As the employer makes a profit from the activities of his employees, he should also bear any losses that those activities cause. Three questions must be asked in order to establish liability: 1) Was a tort committed? 2) Was the tortfeasor an employee? 3) Ws the employee acting in the course of employment when the tort was committed? SERVANTS AND INDEPENDENT CONTRACTORS A person who is employed to do a job may be either a servant or an independent contractor. It is important to decide which category he comes into, for whilst an employer is liable for the torts of his servants, he is generally not liable for those of his independent contractors.Various tests for establishing an individual's employment status have been developed through the cases: (a) The control test This was the traditional test. According to ‘Salmond and Heuston on the Law of Torts’: A servant m ay be defined as any person employed by another to do work for him on the terms that he, the servant, is to be subject to the control and directions of his employer: an independent contractor is one who is his own master. A servant is a person engaged to obey the employer’s orders from time to time; an independent contractor is a person engaged to do certain work, but to exercise his own discretion as to the mode and time of doing it – he is bound by his contract, but not by his employer’s orders.A servant is employed under a contract of service, whereas an independent contractor is employed under a contract for services: In Collins v Hertfordshire CC [1947] 1 All ER 633, Hilbery J said: â€Å"The distinction between a contract for services and a contract of service can be summarised in this way: In one case the master can order or require what is to be done, while in the other case he can not only order or require what is to be done, but how it shall be done. † But in Cassidy v Ministry of Health [1951] 1 All ER 574, Somervell LJ pointed out that this test is not universally correct. There are many contracts of service where the master cannot control the manner in which the work is to be done, as in the case of a captain of a ship.He went on to say: â€Å"One perhaps cannot get much beyond this ‘Was the contract a contract of service within the meaning which an ordinary person would give under the words? ’† However, although the control test may be satisfactory in the most basic domestic situations, it has proved to be quite inadequate in the context of modern business enterprise, where large organisations commonly employ highly skilled professional persons under contracts of service, and yet do not or cannot control the manner in which they do their work. (b) The Organisation Test A useful alternative to the control test, and one which is more in keeping with the realities of modern business, is what may be cal led the ‘organisation test’.This test was explained by Denning LJ in Stevenson, Jordan and Harrison Ltd v. Macdonald and Evans Ltd as: Under a contract of service, a man is employed as part of a business, and his work is done as an integral part of the business; whereas under a contract for services, his work, although done for the business, is not integrated into it but is only accessory to it. Examples of servants of the organisation under this test include: hospital doctors and nurses, school teachers, airline pilots, office clerical staff and factory workers. Examples of independent contractors include: freelance journalists, attorneys, architects plumbers and taxi drivers driving their own vehicles. (c) The ‘Multiple’ or ‘Mixed’ TestThe three conditions suggested by MacKenna J in Ready Mixed Concrete (South East) Ltd v. Minister of Pensions, for the existence of a contract of service of employment are: 1. the employee agrees to provide his work and skill to the employer in return for a wage or other remuneration; 2. the employee agrees, expressly or impliedly, to be directed as to the mode of performance to such a degree as to make the other his employer; and 3. the other terms of the contract are consistent with there being a contract of employment. In applying this test, the courts do not limit themselves to considering just those three factors.They consider a wide range of factors including: the degree of control over the worker’s work; his connection with the business; the terms of the agreement between the parties; the nature and regularity of the work; and the method of payment of wages. LENDING AN EMPLOYEE/SERVANT If an employer lends an employee to another employer on a temporary basis, as a general rule it will be difficult for the first employer to shift responsibility to the temporary employer. Mersey Docks & Harbour Board v Coggins Ltd [1946] 2 All ER 345 The appellants employed Y as a driver of a mobile crane. They hired out the crane, together with Y as driver, to the respondents, a stevedoring company, for use in unloading a ship.The contract between the appellants and the respondents provided that Y was to be the servant of the respondents, but Y was paid by the appellants, who alone had the power of dismissal. Whilst loading the cargo, Y was under the immediate control of the respondents, in the sense that they could tell him which boxes to load and where to place them, but they had no power to tell him how to manipulate the controls of the crane. The House of Lords had to decide whether it was the appellants or the respondents who were vicariously liable for Y’s negligence, and the answer to that question depended upon whether he was the respondents’ or the appellants’ servant at the time of the accident. HELD: – The House of Lords held that the driver remained the servant of the Board and thus the appellants were vicariously liable.Lord Port er said that in order to make the respondents liable, it was not sufficient to show that they controlled the task to be performed: it must also be shown that they controlled the manner of performing it. And, ‘where a man driving a mechanical device, such as a crane, is sent to perform a task, it is easier to infer that the general employer continues to control the method of performance, since it is his crane and the driver remains responsible to him for its safe keeping’. These principles were applied in the Bahamian case of Joseph v. Hepburn (1992) Supreme Court, The Bahamas, No 762 of 1989 (unreported). H engaged an independent contractor, S Ltd, to clear his land of bush.In the course of clearing the land, A, a tractor driver employed by S Ltd, encroached upon the plaintiff’s adjacent land and destroyed a number of fruit trees. The main issue in the case was whether S Ltd, as general employer of A, was liable for A’s tort, or whether, as S Ltd alleged, the responsibility for the tort had been shifted to H as special employer. The contractual arrangement between H and S Ltd showed that H had identified the general area in which work was to be done and S Ltd arranged for its project manager to accompany H to the site to see what was required. S Ltd had delegated the tractor driver, A, to take instructions from H, but A’ wages were paid by S Ltd.HELD: – Thorne J said that whether A was to be regarded as the servant of the general employer, S Ltd, ‘or whether he became pro hac vice the servant of his particular employer [H] is a question of fact and depends upon an interpretation of the agreement made between [S Ltd and H]’. His Lordship held that S Ltd had ‘failed to discharge the heavy burden on it to shift to [H] its prima facie responsibility for the acts of the driver, and so [A] remained the servant of [S Ltd]. ‘What was transferred was not the servant but the use and benefit of his workâ⠂¬â„¢. Thorne J ultimately held that H had been negligent in his failure to give clear instructions to A with respect to the extent of his boundaries, and S Ltd was entitled to recover from H 10% of the damages that it was liable to pay to the plaintiff. COMMISSION OF A TORT BY THE SERVANTFor the master to be vicariously liable, the plaintiff must first prove the commission of a tort by the servant. As Denning LJ explained†¦to make a master liable for the conduct of his servant, the first question is to see whether the servant is liable. If the answer is ‘yes’, then the second question is to see whether the employer must shoulder the servant’s liability. In other words, vicarious liability of the master arises only on the primary liability of the servant. RES IPSA LOQUITOR Sometimes, it may be difficult or impossible to prove affirmatively which one of several servants was negligent. As far as the liability of hospitals is concerned, it was established in Ca ssidy v.Ministry of Health that, where the plaintiff had been injured as a result of some operation in the control of one or more servants of a hospital authority, and he cannot identify the particular servant who was responsible, the hospital authority will be vicariously liable, unless it proves that there was no negligent treatment by any of its servants; in other words, res ipsa loquitor applies. In the absence of authority to the contrary, there seems to be no reason why this principle should not apply to other master/servant relationships. THE COURSE OF EMPLOYMENT/SCOPE OF EMPLOYMENT An employer will only be liable for torts which the employee commits in the course of employment. There is no single test for this, although Parke B famously stated in Joel v Morison (1834) 6 C&P 501 at 503, that the servant must be engaged on his master's business, not ‘on a frolic of his own’. A tort comes within the course of the servant’s employment if: 1. t is expressly or impliedly authorised by his master; or 2. it is an unauthorised manner of doing something authorised by his master; or 3. it is necessarily incidental to something which the servant is employed to do. Although this definition is easy enough to state, the second and third circumstances in particular have proved to be very difficult to determine in practice, and it is now accepted that the question of whether a servant’s act is within the course of his employment is ultimately one of fact in each case. Some relevant factors which the courts take into account when considering the question include: 4. Manner of doing the work the servant was employed to doA master will be liable for the negligent act of his servant if that act was an unauthorised mode of doing what the servant was employed to do. The classic example is: Century Insurance Co Ltd v. Northern Ireland Road Transport Board There, the driver of a petrol tanker, whilst transferring gasoline from the vehicle to an under ground tank at a filling station, struck a match in order to light a cigarette and then threw it, still alight, on the floor. HELD: – His employers were held liable for the ensuing explosion and fire, since the driver’s negligent act was merely an unauthorised manner of doing what he was employed to do. Beard v. London General Omnibus Co [1900] 2 QB 530The employers of a bus conductor who took it upon himself to turn a bus around at the terminus and, in so doing, negligently injured the plaintiff, were held not liable because the conductor was employed to collect fares, not drive buses, and his act was entirely outside the scope of his employment. 5. Authorised limits of time and place A relevant factor in determining whether or not a servant’s tort is within the course of his employment is the time or place at which it is committed. As regards time, where a tort is committed during working hours or within a reasonable period before or after, the court is more l ikely to hold the employer liable for it.Thus, in Ruddiman and Co v. Smith (1889) 60 LT 708, where a clerk turned on a tap in the washroom 10 minutes after office hours and forgot to turn it off before going home, his employers were held liable for the consequent flooding of adjoining premises. The use of the washroom by the clerk was an incident of his employment and the negligent act took place only a few minutes after working hours. As regards the place where the tort is committed, a difficult question which has frequently come before the courts is whether a driver/servant is within the course of his employment where he drive negligently after making a detour from his authorised route.The principle to be applied in these cases was laid down by Parke B in Joel v. Morrison (1834) 172 ER 1338: If he was going out of his way, against his master’s implied commands, when driving on his master’s business, he will make his master liable; but if he was going on a frolic of h is own, without being at all on his master’s business, the master will not be liable. Whether a detour by the servant amounts to a ‘frolic of his own’ is a question of degree, and both the extent of the deviation and its purpose will be taken into account. Dunkley v. Howell (1975) 24 WIR 293 R was employed to drive Mrs W in the defendant/appellant’s car to May pen and thereafter to Mrs.W’s home at Mocho, where the car was to be garaged. On reaching May pen, Mrs. W remained there, but R drove the car to Thompson Town for his own private purposes. On his way back from Thompson Town, R negligently ran into the back of the plaintiff