Carriage of Goods by Sea - Free Essay Example

Sample details Pages: 9 Words: 2806 Downloads: 10 Date added: 2017/06/26 Category Law Essay Type Analytical essay Did you like this example? Part A: Butcher Ltd KRY Ltd The contract of affreightment is evidenced by the bill of lading where, as here, the goods to be carried only form part of the total cargo. The liability of the carrier under the bill of lading is now subject to a combination of the rules introduced by the Maritime Law Committee of the International Law Association held in the Hague in 1921 as revised by the Brussels Protocol of 1968, known collectively as the à ¢Ã¢â€š ¬Ã¢â€ž ¢Hague/Visby Rulesà ¢Ã¢â€š ¬Ã¢â€ž ¢. It is agreed here that the bill of lading is subject to English law which passed legislation (the Carriage of Goods by Sea Act 1971) to implement these rules. Don’t waste time! Our writers will create an original "Carriage of Goods by Sea" essay for you Create order It is also necessary to have regard to the Carriage of Goods by Sea Act 1992 which governs all contracts of carriage entered into after 16 September 1992. The object of the Hague/Visby Rules is to establish the minimum obligations of the carrier and to define the maximum immunities to which he is entitled and the extent to which he is able to limit his liability. Article III, rule 2 provides: à ¢Ã¢â€š ¬Ã…“Subject to the provisions of Article IV, the carrier shall properly and carefully load, handle, stow, carry, keep, care for and discharge the goods deliveredà ¢Ã¢â€š ¬Ã‚ . So far as the cobras in Container A are concerned, these are expressly excluded by Art.1(c): à ¢Ã¢â€š ¬Ã…“Goodsà ¢Ã¢â€š ¬Ã‚  includes goods, wares, merchandise, and articles of every kind whatsoever except live animals and cargo which by the contract of carriage is stated as being carried on deck and is so carriedà ¢Ã¢â€š ¬Ã‚ . In any event, Art.IV, rule 2 provides the à ¢Ã¢â€š ¬Ã…“ca talogue of exceptionsà ¢Ã¢â€š ¬Ã‚  which are available to the carrier under the Rules. These include: à ¢Ã¢â€š ¬Ã…“Neither the carrier or the ship shall be responsible for loss or damage arising or resulting from a) Act, neglect, or default of the master, mariner, pilot or the servants of the carrier in the navigation or in the management of the ship.à ¢Ã¢â€š ¬Ã‚  While there is little difficulty in interpreting à ¢Ã¢â€š ¬Ã…“faults in navigationà ¢Ã¢â€š ¬Ã‚ , the concept of à ¢Ã¢â€š ¬Ã…“management of the shipà ¢Ã¢â€š ¬Ã‚  is more problematic. The uncertainty arises because of the distinction between the duty to take care of the ship and a duty toward the safety of the cargo which in reality can frequently overlap. The applicable test was propounded by Greer LJ[1]: If the cause of the damage is solely, or even primarily, a neglect to take reasonable care of the cargo, the ship is liable, but if the cause of the damage is a neglect to take reasonable care of the ship, or some part of it, as distinct from the cargo, the ship is relieved from liability; for if the negligence is not negligence towards the ship, but only negligent failure to use the apparatus of the ship for the protection of the cargo, the ship is not so relieved.à ¢Ã¢â€š ¬Ã‚  Thus, in Gosse Millerd, a cargo of tinplate was damaged by a failure to secure tarpaulins. The House of Lords held that since the purpose of the tarpaulins was to protect the cargo, the conduct in question related to a failure to protect the cargo rather than the management of the ship. In the case of container A, the failure was due to the failure of the crew to secure one of the side doors of the ship. This might be said to relate to a failure to protect the ship. Conversely, contained C was undamaged so it might be argued that the default was specific to the cargo in Container A and did not impinge upon the safety of the ship. It might be expected, therefore, that the ship owners will arg ue the à ¢Ã¢â€š ¬Ã…“safety of the shipà ¢Ã¢â€š ¬Ã‚  exception in addition to the exclusion of animals clause and the general exclusion contained in clause 3 of the bill of lading. So far as Container B is concerned, this appears to fall within the exception to the Rules described above. Two requirements must be satisfied if the carrier is to escape liability: the cargo must actually be stowed on deck and this fact must be apparent to the innocent transferee from a scrutiny of the bill of lading. In Svenska Traktor v Maritime Agencies[2], a consignment of tractors had been shipped under a bill of lading which conferred a liberty upon the carrier to stow the cargo on deck One of the tractors was washed overboard during the voyage. Pilcher J (at p.300) held: à ¢Ã¢â€š ¬Ã…“A mere general liberty to carry goods on deck is not, in my view, a statement in the contract of carriage that the goods are in fact being carried on deck.à ¢Ã¢â€š ¬Ã‚  As is apparent from Encyclopae dia Britannica v Hong Kong Producer[3], even a liberty to do so unless the shipper lodges an objection will not suffice. Accordingly, the qualification (applicable in the event to Contained B) à ¢Ã¢â€š ¬Ã…“if sufficient space is not available below deckà ¢Ã¢â€š ¬Ã‚  will be unlikely to save the ship from an action in this regard by Butcher Ltd since the bill of lading does not make it sufficiently clear that the cargo will be carried on deck. In this instance, it is unlikely that the carrier will be able to rely upon the exception to the Rules discussed above since the loss of Container B from the deck would appear to be reasonably foreseeable and not related to the management of the ship as opposed to care for the safety of the cargo. It is perhaps fortunate for Butcher Ltd that the carrier will incur primary liability in respect of Container B since their policy of insurance with Max Insurance Corporation is likely to be held to be seriously defective in respect of Contain er B. In Rozanes v Bowen[4], it was held: à ¢Ã¢â€š ¬Ã…“It has been for centuries in England that the law in connection with insurance of all sorts, marine fire, life, guarantee and every kind of policy, that, as the underwriter knows nothing and the man who comes to him to ask him to insure knows everything, it is the duty of the assuredà ¢Ã¢â€š ¬Ã‚ ¦to make full disclosure to the underwriters, without being asked, of all the material circumstances.à ¢Ã¢â€š ¬Ã‚  This principle was applied in Hood v West End Motor Car Packing Co[5] in which a policy of insurance was avoided on the basis that the assured had failed to declare that the cargo may be carried on deck thus increasing the risk. The subject of deviation is treated strictly by the Rules. Article IV, rule 4 limits permissible deviation to à ¢Ã¢â€š ¬Ã…“any deviation in attempting to save life or property at sea or any reasonable deviationà ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã‚ . It is said[6] that à ¢Ã¢â€š ¬Ã…“the co urts in the United Kingdom have given an extremely restricted interpretation to the term à ¢Ã¢â€š ¬Ã‹Å"reasonable deviationà ¢Ã¢â€š ¬Ã¢â€ž ¢ with the result that there are few reported cases in which the concept has been successfully invokedà ¢Ã¢â€š ¬Ã‚ . However, in this instance, the bill of lading contains an express clause allowing deviation in à ¢Ã¢â€š ¬Ã‹Å"special circumstancesà ¢Ã¢â€š ¬Ã¢â€ž ¢. Since clauses of this type are principally inserted for the benefit of the shipowner, they will be interpreted strictly and contra preferentem. In Glynn v Margetson[7], a cargo of oranges was loaded in Malaga for shipment to Liverpool. The bill of lading gave the vessel express permission to à ¢Ã¢â€š ¬Ã…“proceed to and stay at any port or ports in any rotationà ¢Ã¢â€š ¬Ã‚ . Despite the breathtaking breadth of this provision to which the shippers had agreed, it was held not to protect the shipowner when the vessel called at ports not on the geographical route to Liverpool whe n the oranges consequently arrived in a damaged state. In this instance, it may be argued that the inclusion of a reference to à ¢Ã¢â€š ¬Ã…“special circumstancesà ¢Ã¢â€š ¬Ã‚  means that this liberty should be construed more strictly and Master Gabettaà ¢Ã¢â€š ¬Ã¢â€ž ¢s deviation to Valletta does not fall within the definition of such circumstances and the purported protection should be struck down in any event in accordance with the principle propounded in Glynn. Traditionally, such an unjustifiable deviation was regarded as a fundamental breach of the contract of affreightment. Doubt was cast upon this as a result of the decisions in Suisse Atlantique[8] and Photo Production v Securicor[9] but the best guidance is probably to be obtained from the Court of Appeal judgments in The Antares[10] in which Lloyd LJ expressed the view that à ¢Ã¢â€š ¬Ã…“the deviation cases should now be assimilated into the ordinary law of contractà ¢Ã¢â€š ¬Ã‚ . Wilson[11] opines: à ¢Ã¢â€š ¬Ã …“Such an approach would require the courts to take into consideration the entire terms of the contract, including both exceptions and liberty clauses, with a view to discovering whether, on their true construction, the parties intended them to apply to the new situation, I.e. the substituted voyage.à ¢Ã¢â€š ¬Ã‚  On such a construction, it appears highly unlikely that the personal imperatives of Master Gabetta would absolve the ship owners from liability in respect of the damage to the watermelons. However, it should be borne in mind that such damage could be argued not to have been caused by the diversion to Valletta but rather by the ensuing delay of some three weeks that was enforced by the port workers strike. Butcher Ltd may be argued to be at the mercy of the strike but the reasons for it will have to be scrutinised. In The New Horizon[12], Lord Denning MR stated: à ¢Ã¢â€š ¬Ã…“I think a strike is a concerted stoppage of work by men done with a view to improving their wages or conditions, or giving vent to a grievance, or making a protest about something or other, or supporting or sympathising with other workmen in such an endeavour. It is distinct from a stoppage which is brought about by an external event such as a bombscare or an apprehension of danger [emphasis supplied].à ¢Ã¢â€š ¬Ã‚  However, unless the strike can be blamed upon such an external factor, it is probable that the shipowner will be protected by the exception supplied by Art.IV, rule 2(j) of the Rules which expressly provides for à ¢Ã¢â€š ¬Ã…“strikes or lockouts or stoppage or restraint of labour from whatever cause, whether partial or generalà ¢Ã¢â€š ¬Ã‚ . So far as KRY Ltd is concerned, the bill of lading will act as a document of title to the goods in Container C. This is now expressly provided for by the Carriage of Goods by Sea Act 1992 which provides that title to sue is vested in the lawful holder of the bill of lading with à ¢Ã¢â€š ¬Ã…“lawful holder à ¢Ã¢â€š ¬Ã‚  being defined, inter alia, as an indorsee of the bill. The ability of KRY Ltd to sue in tort is subject to the qualification provided in Margarine Union v Cambay Prince[13] in which a cargo of copra was seriously damaged as a result of the negligence of the ship owner. The plaintiff was the holder of a delivery order for part of the cargo issued by the seller under a c.i.f. contract. As the plaintiff did not become owner of the goods until they were ascertained on discharge, it was held that an action in negligence could not lie. This betrays an underlying public policy consideration, namely, the reluctance of the courts to allow recovery for pure economic loss and the undesirability of allowing an indorsee to sue in negligence, unconstrained by the terms of the contract of carriage. This principle, therefore, may well prevent KRY Ltd from pursuing an action in negligence alone and they will therefore be limited by the principles applicable to Container C discussed a bove. Part B: Amount of Cargo At common law the bill of lading in the hands of the shipper is prima facie evidence of the quantity or weight of goods shipped. Accordingly, if the Master is unable to check the quantity, he is at risk of exposing the carriers to liability in the event that the discharged cargo fails to amount to the quantity recorded. The burden upon the carrier is a heavy one since it will then require him to prove that the goods were not in fact shipped. The balance of probabilities test does not apply in this situation and therefore it will not be possible to argue that it is more likely than not (as would appear common sense) that the goods delivered equate to the goods loaded. In Smith v Bedouin Steam Navigation Co[14] 988 bales of jute were delivered under a bill of lading which stated that 1000 bales had been shipped. Lord Shand stated that: à ¢Ã¢â€š ¬Ã…“The evidence must be sufficient to lead to the inference not merely that the goods may possibly not have been shipped, but that in point of fact they were not shipped.à ¢Ã¢â€š ¬Ã‚  In Grant v Norway[15], the position was more extreme still: the Master had signed a bill acknowledging that 12 bales of silk had been shipped where in fact none had been taken on board. It was held that the indorsees of the bill were not entitled to recover when it was in fact established that no bales had been shipped. Jervis CJ stated: à ¢Ã¢â€š ¬Ã…“It is not contended that the captain had any real authority to sign bills of lading unless the goods had been shipped; nor can we discover any ground on which a party taking a bill of lading by indorsement would be justified in assuming that he had authority to sign such bills, whether the goods were on board or not.à ¢Ã¢â€š ¬Ã‚  This created an anomaly in that it rendered meaningless the signature of the Master upon a bill of lading where it was subsequently possible to prove that his acknowledgement of quantity had been incorrect. The Hague/Visby Rules (Art.III, rule 4) remove this protection from the Master in this situation by providing that statements as to quantity in a bill of lading are conclusive evidence in favour of a consignee or indorsee who takes the bill in good faith. This is reinforced by s.4 of the Carriage of Goods by Sea Act 1992 which provides that representations in a bill of lading are conclusive evidence against the carrier in favour of the lawful holder of a bill. However, the Master here has the advantage of being able to contract out of the representation of quantity in the bill. In New Chinese Antimony Co Ltd v Ocean Steamship Co[16], a bill of lading expressly stated that 937 tons of antimony oxide had been shipped. However, the bill contained a standard clause to the effect that à ¢Ã¢â€š ¬Ã…“weight, measurement, contents and value (except for the purpose of estimating freight) [are] unknownà ¢Ã¢â€š ¬Ã‚ . This was a powerful decision in favour of carriers since the Court of Appeal held that this pre-printed clause even had the effect of displacing the express statement as to quantity and that such a statement in such circumstances was evidence only of the amount which the shipper maintained to be comprised in the cargo. It is recommended therefore that the Master in this situation protect the position of his owners by an indorsement on the bill in such terms as à ¢Ã¢â€š ¬Ã…“shipperà ¢Ã¢â€š ¬Ã¢â€ž ¢s countà ¢Ã¢â€š ¬Ã‚ , à ¢Ã¢â€š ¬Ã…“said to beà ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã‚  or even a flatly contradictory à ¢Ã¢â€š ¬Ã…“weight and quantity unknown. He should be aware, however, that under the Hague/Visby Rules, (Art.III, rule 2) the shipper is able to demand that the carrier issue a bill of lading showing à ¢Ã¢â€š ¬Ã…“either the number of packages or pieces, or the quantity or weight as the case may be, as furnished in writing by the shipperà ¢Ã¢â€š ¬Ã‚ . The carrier is under no obligation to issue a bill acknowledging the quantity of cargo unle ss required to do so by the shipper. Failure to observe this procedure will of course generally operate to the prejudice of the ultimate consignee. However, it also provides valuable protection to a Master in a situation such as this. This Master should therefore exercise care since the basic position under the Rules is the same as that at common law in terms of the prima facie evidentiary value of the bill of lading so far as determining quantity is concerned with the important qualification that the Rules also provide protection in this regard to a third party to whom the bill has been transferred acting in good faith. The very fact of acting in good faith would give rise to an estoppel preventing the carrier denying the quantity of the bill of lading (no consideration is required) and the Master should have regard to this potential consequence in addition to any duty immediately apparent. Bibliography Dockray, M., Cases and Materials on the Carriage of Goods by Sea, (3rd Ed ., 2004) Treitel, G., The Law of Contract, (11th Ed., 2003) Wilson, J., Carriage of Goods by Sea, (5th Ed., 2004) Westlaw International Convention for the Unification of Rules of Law Relating to Bills of Lading, Brussels, August 25, 1924 (à ¢Ã¢â€š ¬Ã…“The Hague Rulesà ¢Ã¢â€š ¬Ã‚ ) Footnotes [1] Gosse Millerd v Canadian Government Merchant Marine, dissenting judgment upheld by the House of Lords at [1929] AC 223 [2] [1953] 2 QB 295 [3] [1969] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 536 [4] (1928) 32 LlLR 98 at 102 [5] [1917] 2 KB 38 [6] Wilson, J., Carriage of Goods by Sea, (5th Ed., 2004), p.19 [7] [1893] AC 351 [8] [1967] 1 AC 361 [9] [1980] AC 827 [10] [1987] 1 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 424 [11] Op. Cit., p.22 [12] [1975] 2 Lloydà ¢Ã¢â€š ¬Ã¢â€ž ¢s Rep 314 at p.317 [13] [1969] 1 KB 219 [14] [1896] AC 70 [15] (1851) 10 CB 665 [16] [1917] 2 KB 664

Analysis of Brand Performances, Introduction of the New Product in a M Assignment

Essays on Analysis of Brand Performances, Introduction of the New Product in a Market Assignment The paper â€Å"Analysis of Brand Performances, Introduction of the New Product in a Market† is a  potent version of the assignment on marketing. In a normal business operation field, promotion always has an impact on sales volumes of products. Products sold under high promotion strategies especially in a competitive market show higher volumes than those left to operate freely in the market. This has been the reason under price wars in the most competitive market and the result is that the lower price-setters take the market advantage above their competitors’. From this perspective, Mr. Bossy's statement could be right.The data in the Appendix can be used to evaluate the Executive managers’ decision. To achieve this consideration will be put on the price against market share coverage. The expected outcome as per the executive managers’ comment is that those products having a wider market share are supposed to show averagely low prices as a promotional st rategy. Taking for example of Kellogg’s, it’s showed sales reduction as across the period as compared with the price before promotion. The worst of this could be seen in the April market where after price promotion the sales reduced from 12.998 to 5.125 (third market region 1). Across the regions, the sales of Kellogg’s are seen to substantially drop instead of increasing as expected from Mr. Boss’s view. Also in the region, one market Brekky shows fluctuation in sales despite the price promotion which was expected to show some increase in sales. Taking an example of January to April market in the first region, it could be seen that Private labels, Lowan and Uncle Tobys were the least in the market share at 8 percent before promotion. After promotion, Uncle Toby's market share was 17 percent, Lowan market share remained at 8% while private level moved to 17%. Carman, which was at a 10% share in the market showed a leap to 17% promotion, while Sanitarium m oved from 11 to 14% in the market share. Kellogg’s and Nestle which shared the markets at 20 and 1t percent in the market a 14% and 17% result after promotion.Using the above study, the expectation was to have a general scaled sales increase across the products tentatively. However, this is not the case in this where there is a fluctuation in the trends with major shareholders going down after price promotions have been undertaken.However, going by the principle of data reduction, this is not seen to be the case. From appendix 1, the reduction of production volumes to as well as combining them to achieve large volumes that will be cost-effective seems to produce almost equal results. Averagely, the volumes, as well as average prices, remain constant. From the study, it can hence be deduced that the executive officers' view on the influence of price promotion of the market share is inaccurate.For Brekky, the most profitable region is in region three. The rest of the regions Be kky operates seem smaller share in the market. Attempts through price promotion to reach maximum share in the market as well as seen the sales drastically reduces such as in region 2 an 1. Brekky maximum sales are hence experienced in the third region.

In mathematics, Pi is the symbol denoting the rati Essay Example For Students

In mathematics, Pi is the symbol denoting the rati Essay PiIn mathematics, Pi is the symboldenoting the ratio of the circumference of a circle to its diameter. The ratio is approximately 3.14159265, pi being an irrational number (one that cannot be expressed as a simple fraction or as a decimal with a finite number of decimal places) and a transcendental number (one without continuously recurrent digits). Electronic computers in the late 20th century have carried pi to more than 100,000,000 decimal places. Using a computer program, I calculated pi into 1000 decimals:3.14159265 358979323846 2643383279 5028841971 6939937510 5820974944 5923078164 0628620899 8628034825 3421170679 8214808651 3282306647 0938446095 5058223172 5359408128 4811174502 8410270193 8521105559 6446229489 5493038196 4428810975 6659334461 2847564823 3786783165 2712019091 4564856692 3460348610 4543266482 1339360726 0249141273 7245870066 0631558817 4881520920 9628292540 9171536436 7892590360 0113305305 4882046652 1384146951 9415116094 3305727036 5759591953 0921861173 8193261179 3105118548 0744623799 6274956735 1885752724 8912279381 8301194912 9833673362 4406566430 8602139494 6395224737 1907021798 6094370277 0539217176 2931767523 8467481846 7669405132 0005681271 4526356082 7785771342 7577896091 7363717872 1468440901 2249534301 4654958537 1050792279 6892589235 4201995611 2129021960 8640344181 5981362977 4771309960 5187072113 4999999837 2978049951 0597317328 1609631859 5024459455 3469083026 4252230825 3344685035 2619311881 7101000313 7838752886 5875332083 8142061717 7669147303 5982534904 2875546873 1159562863 8823537875 9375195778 1857780532 1712268066 1300192787 6611195909 2164201989. Pi occurs in various mathematical calculations. The circumference (c) of a circle can be determined by multiplying the diameter (d) by : c = d. The area (A) of a circle is determined by the square of the radius (r): A = r2. Pi is applied to mathematical problems involving the lengths of arcs or other curves, the areas of ellipses, sectors, and other curved surfaces, and the volumes of solids. It is also used in various formulas of physics and engineering to describe such periodic phenomena as the motion of pendulums, the vibration of strings, and alternating electric currents. In very ancient times, 3 was used as the approximate value of pi, and not until Archimedes (3rd century BC) does there seem to have been a scientific effort to compute it; he reached a figure equivalent to about 3.14. A figure equivalent to 3.1416 dates from before AD 200. By the early 6th century Chinese and Indian mathematicians had independently confirmed or improved the number of decimal places. By the end of the 17th century in Europe, new methods of mathematical analysis provided various ways of calculating pi. Early in the 20th century the Indian mathematical genius Srinivasa Ramanujan developed ways of calculating pi that were so efficient that they have been incorporated into computer algorithms, permitting expressions of pi in millions of digits. On the next couple of pages, I will outline problems and formulas to solve Pi. There are 4 ways to calculate the value of Pi:1.) Arctangent Formulas for Pi This is one of the oldest methods to calculate PI, it uses the power series expansion of arctan (x). This method gets you about 1.4 correct decimals for every term of the series you calculate. 2.) Gauss-Legendre This method doubles the number of correct decimals per iteration. 3.) Ramanujan I This method comes from the theory of complex multiplication of elliptic curves, and was discovered by S. Ramanujan. It is a linear formula, so it will get you 14 correct decimals for every term you calculate. 4.) Ramanujan II This formula is also based on the work of the eccentric Indian mathematician Srinivasa Ramanujan. It is a quadratic iteration based on an elliptic function called the Singular Value Function of the Second Kind. It converges exponentially to 1/PI as its argument increases. Each iteration of this formula gives approximately four times the number of decimal places as the previous one. Words/ Pages : 588 / 24

Overpopulation the Underlying Cause of Most Environmental Essay Example

Overpopulation: the Underlying Cause of Most Environmental Paper That means that people themselves are the very ones causing harm to the environment. What we do or dont do about the issue of overpopulation will determine the very fate of the environment in the future. This presents the need for ethical decision making. Global environmental problems are ethical problems (Brown, 2009). Each and every person has a moral and ethical responsibility toward the environment, the problem is that people often ignore that responsibility, especially when it presents other ethical dilemmas. Defining Teeth CICS To begin, I would like to define ethics. A definition taken from the National Academy of Engineering states ethics is concerned with what is right or wrong, good or bad, fair or unfair, responsible or irresponsible, obligatory or permissible, praiseworthy or blameworthy (2006). So what does ethics have to do with overpopulation and other environmental issues? If we know that overpopulation is the direct cause Of many Of the environmental issues that are affecting the entire globe, ethically, it is our responsibility as humans to come up with a solution to the problem. Population Growth Over-population is the term that refers to a condition by which the population density enlarges to a limit that provokes the environmental deterioration, a remarkable decline in the quality of life or a population collapse (Biology Cabinet Organization, 2003). In around 1963, the global rate of human population growth peaked, but the number of people living on Earth has grown by more than two-thirds since then, topping out at over 6. 6 billion today (West, 2009). Every year, more than 81 million people add to the world-wide population. We will write a custom essay sample on Overpopulation: the Underlying Cause of Most Environmental specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Overpopulation: the Underlying Cause of Most Environmental specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Overpopulation: the Underlying Cause of Most Environmental specifically for you FOR ONLY $16.38 $13.9/page Hire Writer Every 10 years almost one billion inhabitants are added to the worlds population (BCC, 2006). By the year 2050, the human population is expected to exceed nine billion (West, 2009). What affect does this have On the environment? Effects Of Over-population Global Warming Global warming is considered to be one of the top environmental issues today. Scientists have determined that it is mostly human activities that are contributing to global warming by adding excessive amounts of greenhouse gases to the atmosphere. Greenhouse gases, such as carbon dioxide, accumulate in the atmosphere and trap heat that would normally exit into outer space. Many greenhouse gases occur naturally and are needed to rate the greenhouse effect that keeps the Earth warm enough to support life, but it is human use of fossil fuels that cause the excess greenhouse gases. By driving cars, using electricity from coal-fired power plants, or heating our homes with oil or natural gas, we release carbon dioxide and other heat-trapping gases into the atmosphere (West, 2009). Deforestation Deforestation is another environmental issue and is a significant source of greenhouse gases because fewer trees mean less carbon dioxide conversion to oxygen. The most important direct causes of deforestation include oozing, the conversion of forested lands for agriculture and cattle-raising, arbitration, mining and oil exploitation, acid rain and fire (World Rain Forest Movement, 1998). Deforestation and forest degradation occurs both in Northern and Southern countries and its underlying causes also originate in both, although with varying degrees of responsibility. Industrialized countries have not only cut down or degraded their own forests in the past; many are still doing so today. This occurs either through large-scale clear- cutting (as in many areas of Canada, the US or Australia) or through the hinging and therefore degradation Of forests, reducing them to a few commercially valuable species at the expense of biodiversity (such as in Sweden, France or Finland) (World Rainforests Movement, 1998). The root of the problem is trying to keep up with the demand of the ever-growing population. Biodiversity Biodiversity is defined by the Washington Biodiversity Council as the full range of life in all its forms (2003). Biodiversity loss is largely a result of deforestation. The worldwide rate of extinction of plant and animal species is estimated to be 1 0,000 times as rapid as it was in prehistoric times, with more Han 27,000 species becoming extinct every year. An example of the loss of biodiversity due to overpopulation is seen in the state of Washington. Washington is one of the most biologically diverse states in the union. This is due to the states diverse topography, its exposure to Pacific Ocean currents and weather patterns, and its location on the migratory path of many wildlife species. Washington, in fact, contains most of the major ecosystem types found in the western United States, including n. Vivo found nowhere else in the world: the Olympic rainforests and channeled scabbards. However, since tattooed in 1 889, Washington has lost an estimated 70 percent of its estuarine wetlands, 50 percent of its riparian habitat, 90 percent of its old- growth forest, and 70 percent of its native shrub-steppe and arid grasslands (Washington Biodiversity Council, 2003). As the smallest and second most densely populated of the rapidly growing Western states, Washingtons population in 2008 was 6. Million according to the U. S. Census Bureau, and is expected to add over 21 percent by the year 2020 (2009). This puts Washington in great danger of losing much of its diversity of plant and animal life within the next few decades. Although scientists are not fully aware of all the consequences of the continual loss of biodiversity, they do know that a diversity of healthy, functioning ecosystems is essential to the environment. Water Shortages As we in water-rich countries take our daily showers, water the lawn or laze about in the pool, its easy to forget that fresh water is a life-or-death issue in many parts of the world. Of a population of roughly 6. 1 billion, more than 1 billion lack access to potable water. The World Health Organization says that at any time, up to half of humanity has one of the six main diseases such as: diarrhea, sadomasochists, or trachea, or infestation with cascaras, Guiana worm, or hookworm which are associated with poor drinking water and inadequate sanitation. About 5 million people die each year from poor drinking water, poor sanitation, or a dirty home environment, often resulting from water shortage (University of Wisconsin, 2001). The water shortages are becoming more and more evident all over the world. For example: Mexico City (home to 20 million people) is sinking because the city sucks out underground water faster than the aquifer can be refilled; Florida wants to fill its over pumped aquifer with untreated surface water, despite federal regulations to the contrary; Texas is moving toward private, for-profit water sales. The water will be mined from aquifers that are disappearing fast. No word on what the private suppliers, including corporate raider T. Boone Pickers, will do once the aquifers run dry. Aquifers around the world are being over tapped for irrigated agriculture, which fills about 40 percent of the global larder; The Bush Administration has withdrawn a proposed tightening of the arsenic standard for drinking water. Critics say the old rule, dating to 942, could allow thousands of cases of cancer and other diseases. Meanwhile, in Bangladesh, whats been called the largest poisoning of a population in history has 35 to 77 million people drinking arsenic-laced water; and last but not least, a showdown is looming over the Tigris and Euphrates Rivers, which originate in Turkey, then water both Syria and Iraq. If Turkey goes ahead with a series of dams, the downriver nations could starve. There are projections that three billion people, half of todays population, will be short of water in 2025 (University of Wisconsin, 2001 Some Recommended Solutions for Overpopulation Being that this issue is one of such great importance, we need to be proactive at finding some kind of solution. There have been many different ideas that have been presented to try to get the population under control; however, thus far, most Of the ideas have been just that- ideas, with no definite plan of action. Some of the proposed solutions, to name a few, have been: making sure people around the world have access to family planning services; empowering women in developing countries economically, socially, and legally in a manner that results in them having an equal say (with their cabanas) in reproductive decisions; modifying school curricula to include information on population levels and implications for the future; reforming tax laws in a way that encourages couples to have no more than two children. They would still be able to have as many kids as they want, but the tax code would no longer subsidize more than ;ay (Jaunted, 2005). The Need for Ethical Decision-Making people tend to be very opposed to the thought of their freedom being imposed upon, especially when it deals with the amount of children that they can or cannot have. Many people will argue from a religious standpoint that God specifically says in the Bible to multiply and subdue the earth. Some feel that the use of birth control is unethical and against Bible principles. The problem is that people do not want to do anything else about the issues at hand either. For example: If we were still living the way our ancestors did the amount of people living on the earth would not be a problem. Unfortunately, we are polluting the earth with our technology and over consuming our resources. So the argument can also be presented to those against birth control for religious purposes, that the Bible also says that we should not be lotuses. But again humans tend to want what they want when they want it. Most only keep the Bible principles that suit them. In any case, as in many ethical problems we are faced with a moral dilemma. A moral dilemma is best described as when two or more obligations are in conflict. The crucial features of a moral dilemma are these: the agent is required to do each of two (or more) actions; the agent can do each of the actions; but the agent cannot do both (or all) of the actions. The agent thus seems condemned to moral failure; no matter what she does, she will do something wrong (or fail o do something that she ought to do) (McConnell, 2006). When presented with a moral dilemma, we need to decide which obligation is most important and give preference to the more important one. Unfortunately, when contemplating any solution for an issue such as overpopulation, we are going to be faced with moral dilemmas. Now we have to choose the lesser of two evils. Should we practice birth control even though it violates our moral principles or continue to allow the population to grow to numbers that the earth cannot sustain? Should we object to abortion when a woman does not ant to have a child? Abortion may violate our own personal beliefs; however, if it is what the woman wants for herself and it will surely decrease the number of people being added to our population, shouldnt we support that decision? Utilitarians view the best moral decision to be the one that brings about the maximum amount of pleasures and the least amount of suffering. They do not make decisions based on their own self-centeredness, they insist that the joys and sorrows of others must be part of the calculation (when making any ethical decisions (Waller, 2008). So, from the utilitarian dominant, trying to find an answer to slowing the population growth would not be an intrusion or a violation of ones rights, it would be welcomed to lessen the amount of suffering that is caused by the issue of overpopulation. In the very near future, we will have no choice but to make some very important decisions as to what we will do about the issues that plague the environment. Again, environmental problems are indeed ethical problems. The only way that things will get better in our environment is if we get the rate of growth of the human population under control.

The Ryder Cup Essays - Ryder Cup, Match Play, Foursome, Samuel Ryder

The Ryder Cup The Ryder Cup The Ryder Cup is the most famous team golf event in the world. The Ryder Cup is played for biannually between the USA and the European team. The tournament was founded in 1927 by Samuel Ryder and has continued to the present day. The competition was originally held between the USA and the British teams, but then in 1973 the rules changed to allow the British team to field Irish golfers. The competition finally extended in 1979 to allow all European golfers to play for the new European team. The competition has been contested once every two years since 1927 except during WWII. Since 1979, the tournament has been played on 11 occasions between the USA and Europe. The inaugural tournament was played at Worcester Country Club in Worcester, Massachusetts. USA were the first team to lift the trophy as they triumphed over Britain 91/2-21/2. The Ryder Cup has been contested at 28 different venues. No course has hosted the cup more than twice. The only time the cup was not conte sted was during the duration of WWII. Ryder Cup Venues Worcester CC USA wins -25 Moortown GC, Leeds GB/Ire/Eur wins-8 Sciote CC, Ohio Southport and Ainsdale GC, England Ridgewood CC Portland GC, Oregon Ganton GC, Scarborough Pinehurst CC Wentworth GC Thunderbird CC, Palm Springs Lindrick GC, Yorkshire Eldorado CC, Palm Desert Royal Lytham and St Annes GC East Lake CC, Atlanta Royal Birkdale GC, Southport Champions GC, Houston Old Warson CC, St Louis Muirfield, Scotland Laurel Valley GC, Ligonier Greenbrier, Virginia Walton Heath GC, Surrey PGA National GC, Palm Beach Gardens The Belfry, Sutton Coldfield Muirfield Village GC, Ohio The Ocean Course, Kiawah Island Oak Hill CC, New York Valderama GC, Sotogrande, Spain Brookline CC, Newark The Trophy In 1927, Samuel Ryder presented the Ryder Cup to Great Britain's Professional Golfers Association as the prize for an international competition between American and British professional golfers. In 1927, the Ryder Cup was valued at 250 GBP. Today it is valued at $13,900. The Ryder Cup is 17 inches tall and weighs just over four pounds. The golfer depicted on top of the trophy is Abe Mitchell, friend and private instructor of Ryder. Rules, Format and Terminology The Ryder Cup is played by the Rules of Golf determined by the USGA and applied by the PGA of America. Several types of matchplay are used during the Ryder Cup , including foursomes (two man teams taking alternate shots), fourball (betterball) and singles (18 holes at matchplay). The order of play during the first two days of the competition (foursomes or fourballs) is determined through mutual agreement of both teams captains. There are a total of 28 matches . Matchplay Guidelines Matchplay is a game played by holes. A hole is won by the team which holes its ball in the fewer strokes. Score is kept by the number of holes up (won) and the number of holes remaining. (Example: US is 2-up with 6 holes to play). When a team is up (winning) by more holes than there a re holes left to play the match is closed out and a point is awarded to the winning team. One point is awarded for each point won. If a match is tied or ?halved' through 18 holes of play, each team receives 1/2 a point. A total of 28 points are contested in Ryder Cup competition. If a match is currently tied while in competition, then it is considered all-square. A match is considered ?dormie' when one side is up by the exact number of holes that remain. A player/twosome is said to be 2-up thru 10 after winning two more holes than their opponents through 10 holes. A player/twosome is said to win the match 2-up after winning two more holes than their opponents thru 18 holes. A player/twosome is said to win 3 and 2 after winning 3 holes more than their opponents with only 2 holes left to play, assuring victory. FAQ's What are Concessions? A stroke, hole or an entire match can be conceded at any time prior to the conclusion of the hole or match. Concession of a stroke, hole or match ca nnot be declined

Geo

Geo Assignment #1 Pr ©cis of World Population Beyond Six Billion Throughout this century, the population has grown at a very fast pace. It is predicted that over the next century the population will continue to increase. Majority of the increase in the population will come from less developed regions. As the next century approaches, the population of the world will have different demographic trends. To find out what accounts for these differences, we must discover what causes the population to change. There are many factors linked to population change. These factors include economic growth or decline, public health, education, status of women and family services. The change in one of these factors may cause a change in another. As the population continues to grow there is a major concern about the rapid rate of growth and the large increase in population size.Before 1900 there was a great struggle for human survival.English: World Population by Continent and 10 Most...

Reflective Nursing in ctitical care Account of an intubation Essay

Reflective Nursing in ctitical care Account of an intubation - Essay Example That is to say, nursing has a more active role to play in the health care delivery system than the past and nursing, as a profession is 'accountable' today. The patient in this case was admitted for an acute exacerbation of COPD with the complications of Atelectasis and Cor pulmonale. Chronic obstructive pulmonary disease (COPD), also known as chronic obstructive lung disease (COLD), is a term used to describe progressive lung diseases, which include emphysema, chronic bronchitis and chronic asthma.The common symptoms of COPD are progressive limitations of the airflow into and out of the lungs and shortness of breath. Emphysema and chronic bronchitis are closely related and patients with COPD may have both, which affects lung function, preventing the lungs from bringing oxygen to the body and getting rid of carbon dioxide. Atelectasis is a condition where there is a collapse of part or all of a lung by blockage of the bronchus or bronchioles or by very shallow breathing. Atelectasis can be both acute and chronic. Acute atelectasis is the recent collapse of the lung and is primarily notable only for airlessness. In chronic atelectasis, the affected area is often characterized by a complex mixture of airlessness, infection, bronchiectasis, and fibrosis. The most common cause of atelectasis is an obstruction of a large bronchus. Smaller airways also become blocked. The obstruction is caused by a plug of mucus, a tumor, or an inhaled foreign object inside the bronchus. Alternatively, the bronchus is also blocked by a tumor, enlarged lymph nodes, or a significant amount of pleural effusion or pneumothorax in the pleural space. When an airway becomes blocked, the air in the alveoli beyond the blockage is absorbed into the bloodstream, causing the alveoli to shrink and retract. The collapsed lung tissue commonly fills with blood cells, serum, and mucus and becomes infected. Acute atelectasis is a postoperative complication, especially after chest or abdominal surgery. Cor pulmonale is the failure of the right side of the heart caused by prolonged high blood pressure in the pulmonary artery and right ventricle of the heart.The left side of the heart exerts a higher level of blood pressure to pump blood to the body.Whereas, the right side pumps blood through the lungs with a lower pressure. Thus, any condition that leads to prolonged high blood pressure in the arteries or veins of the lungs causes a condition called pulmonary hypertension.This pulmonary hypertension is not tolerated by the right ventricle of the heart and thus fails to properly pump against these abnormally high pressures leading to cor pulmonale.Chronic lung diseases like COPD or other conditions like Obstructive sleep apnea,Central sleep apnea,Cystic fibrosis causing prolonged low blood oxygen can lead to cor pulmonale.The symptoms include shortness of breath,wheezing, coughing, swelling of the feet or ankles,exercise intolerance,chest discomfort, cyanosis,distension of the neck veins indicating high right-heart pressures,abnormal fluid collection in the abdomen, enlargement of the liver,swelling of the ankles and abnormal heart sounds.