My Aim in Life

There are two things to aim at in life: first, to get what you want, and after that to enjoy it. Only the wisest of mankind achieve the second. Logan P. Smith People have set their own aim depending upon their abilities. Some people are doctors, engineers, Charter Accountants, pilots, teachers and many more. Our life is too short so we have to strive to attain our aim with all our hard work. The main objective for achieving the aim is to get material pleasures, mental happiness as well as satisfaction. Once a person chives his aim he can live a prosperous life.The mere act of aiming at something big, makes you big. Charcoal Nehru My aim in life is neither to collect money nor for fame. It is my desire to become a well-qualified doctor. I do not just wish to be an ordinary doctor. The world remembers with thankfulness the name of the man who gave to the world vaccination. The world will remember forever the man who gave us penicillin. As a doctor I want to serve the humanity. Don't ai m for success if you want it; just do what you love and believe in, and it will come naturally.David Frost have an ambition to do something in this world so, great as the doctors and the courageous founders did in the past. I would like to give the world some new drugs and injections that will cure some of the diseases that people are still suffering from. An aim in life is the only fortune worth finding. Robert Louis Stevenson know, my profession is very dignified and it will help me to get peace and satisfaction in life. It provides us best chances of service. Sympathy to human being is the sympathy to one own self. Quotations About this essay. Future favors the bold.An early death is better than an aimless life. A noble aim is simply a noble deed. My goal in life is to survive. Everything else is just a bonus. The greater danger for most of us lies not in setting our aim too high and falling short; but in setting our aim too low, and achieving our mark. Michelangelo The aim of ar t is to represent not the outward appearance of things, but their inward significance. Aristotle. Aim above morality. Be not simply good, be good for something. My Aim in Life There are two things to aim at in life: first, to get what you want, and after that to enjoy it. Only the wisest of mankind achieve the second. Logan P. Smith People have set their own aim depending upon their abilities. Some people are doctors, engineers, Charter Accountants, pilots, teachers and many more. Our life is too short so we have to strive to attain our aim with all our hard work. The main objective for achieving the aim is to get material pleasures, mental happiness as well as satisfaction. Once a person chives his aim he can live a prosperous life.The mere act of aiming at something big, makes you big. Charcoal Nehru My aim in life is neither to collect money nor for fame. It is my desire to become a well-qualified doctor. I do not just wish to be an ordinary doctor. The world remembers with thankfulness the name of the man who gave to the world vaccination. The world will remember forever the man who gave us penicillin. As a doctor I want to serve the humanity. Don't ai m for success if you want it; just do what you love and believe in, and it will come naturally.David Frost have an ambition to do something in this world so, great as the doctors and the courageous founders did in the past. I would like to give the world some new drugs and injections that will cure some of the diseases that people are still suffering from. An aim in life is the only fortune worth finding. Robert Louis Stevenson know, my profession is very dignified and it will help me to get peace and satisfaction in life. It provides us best chances of service. Sympathy to human being is the sympathy to one own self. Quotations About this essay. Future favors the bold.An early death is better than an aimless life. A noble aim is simply a noble deed. My goal in life is to survive. Everything else is just a bonus. The greater danger for most of us lies not in setting our aim too high and falling short; but in setting our aim too low, and achieving our mark. Michelangelo The aim of ar t is to represent not the outward appearance of things, but their inward significance. Aristotle. Aim above morality. Be not simply good, be good for something. My Aim in Life ARTICLE IN PRESS Microbiological Research 161 (2006) 93—101 www. elsevier. de/micres Changes in microbial and soil properties following amendment with treated and untreated olive mill wastewater Ali Mekki, Abdelha? dh Dhouib, Sami SayadiA Laboratoire des Bioprocedes,Centre de Biotechnologie de Sfax, BP: ‘‘K’’ 3038 Sfax, Tunisie ? ? Received 8 June 2005; accepted 15 June 2005 KEYWORDS Microbial community; Olive mill wastewater; Polyphenols; Soil respiration Summary We investigated the effect of untreated and biologically treated olive mill wastewater (OMW) spreading on the soil characteristics and the microbial communities.The water holding capacity, the salinity and the content of total organic carbon, humus, total nitrogen, phosphate and potassium increased when the spread amounts of the treated or untreated OMW increased. The OMW treated soil exhibited signi? cantly higher respiration compared to the control soil. However, the C-CO2/Ctot ratio decre ased from 1. 7 in the control soil to 0. 5 in the soil amended with 100 m3 haA1 of untreated OMW. However, it slightly decreased to 1. 15 in the soil amended with 400 m3 haA1 of treated OMW.The treated OMW increased the total mesophylic number while the number of fungi and nitri? ers decreased. Actinomycetes and spore-forming bacteria were neither sensitive to treated nor to untreated OMW. The total coliforms increased with higher doses of treated and untreated OMW. A toxic effect of the untreated OMW appeared from 100 m3 haA1. This toxicity was more signi? cant with 200 m3 haA1, where micro? ora of total mesophilic, yeasts and moulds, actinomycetes, and nitri? ers were seriously inhibited except for total coliforms and spore-forming bacteria. & 2005 Elsevier GmbH.All rights reserved. Introduction The olive mill wastewater (OMW) is a critical problem, especially in the Mediterranean area, where the olive cultivation is widespread and huge amounts of this ef? uent 30 millions m3 yA1 worldACorresponding author. Tel. /fax: +216 74 440 452. wide and 500 000 m3 yA1 in Tunisia alone, are annually produced (Sayadi and Ellouz, 1995; Casa et al. , 2003). This waste contains an enormous supply of organic matter, COD between 40 and 210 g dmA3 and BOD5 between 10 and 150 g dmA3 (Feria, 2000). Some characteristics of this materialE-mail address: sami. [email  protected] rnrt. tn (S. Sayadi). 0944-5013/$ – see front matter & 2005 Elsevier GmbH. All rights reserved. doi:10. 1016/j. micres. 2005. 06. 001 ARTICLE IN PRESS 94 are favourable for agriculture since this ef? uent is rich in organic matter, nitrogen (N), phosphorous (P), potassium (K) and magnesium (Mg). The organic fraction of this wastewater includes sugars, tannins, poly phenols, poly alcohols, pectins, lipids, and proteins (Mulinacci et al. , 2001; LesageMeessen et al. , 2001). For these reasons, increasing attention has been given to ? d the best methods to spread OMW on agricultural lands and to recyc le both the organic matter and the nutritive elements in the soil crop system. Moreover, agricultural irrigation with wastewater ef? uents became a common practice in arid and semiarid regions, where it was used as a readily available and inexpensive option to fresh water (Angelakis et al. , 1999; Oved et al. , 2001). Fresh OMW was used as a fertilizer in the horticulture and in the olive cultivation (Cox et al. , 1997; Ben Rouina et al. , 1999; Ammar and Ben Rouina, 1999; Cereti et al. , 2004).However, biodegradation of this waste in the nature is dif? cult because it contains a strong antibacterial effect exerted, by various phenolic compounds (Yesilada et al. , 1999; Sayadi et al. , 2000; Rinaldi et al. , 2003). Before its utilization in the irrigation, OMW was treated by several processes such as aerobic treatment, anaerobic digestion and composting process (Sayadi and Ellouz, 1992, 1995; Ehaliotis et al. , 1999; Paredes et al. , 2000; Kissi et al. , 2001; Marques, 2001; Casa et al. , 2003; D’Annibale et al. , 2004). Some Mediterranean countries established laws about soil capability to endure theOMW application, particularly in Italy (Law N1 574, 1996). The maximum amount of OMW tolerated in the ? elds is 80 and 50 m3 haA1 for OMW obtained by centrifuge and pressure extraction techniques, respectively (Law N1 574, 1996). The addition of such compounds may cause signi? cant shifts in the structure and the function of the microbial community, which in turn may in? uence the viability of the soil for agriculture. The effect of the OMW on the physical and chemical characteristics of the soil are well documented (Cabrera et al. , 1996; Cox et al. 1997; Sierra et al. , 2001; Zenjari and Nejmeddine, 2001; Rinaldi et al. , 2003). However, these studies did not deal with the effect of this waste on the microbial community of the soil (Moreno et al. , 1987; Paredes et al. , 1987; Kotsou et al. , 2004). An integrated approach using a pre-treatment of the OMW with the white-rot fungus Phanerochaete chrysosporium followed by an anaerobic digestion was developed in our laboratory in order to reuse the ef? uent in agriculture (Sayadi and Ellouz, 1995). Thus, the aim of our work was to investigate A. Mekki et al. he effect of untreated and biologically treated OMW on the soil characteristics and on the microbial communities. Materials and methods OMW origin The fresh OMW was taken from a three-phase discontinuous extraction factory located in Sfax, Tunisia. Biological treatment of OMW The treated OMW was obtained with an integrated process based on aerobic fungal pre-treatment using P. chrysosporium DSMZ 6909 followed by a decantation step then anaerobic digestion (Sayadi and Ellouz, 1995). The characteristics of the treated and untreated OMW are given in Table 1. Table 1.Chemical and physical properties of untreated and biological treated OMW Parameter pH (25 1C) Electric conductivity (25 1C) (dS mA1) Salinity (g lA1) Colour (absorbance 395 nm) UV absorbance 280 nm BOD5 (g lA1) COD (g lA1) Glucose (g lA1) Residual solids (g lA1) Total solids (%) Total volatiles (%) Total suspended solids (g lA1) Volatiles suspended solids (g lA1) Nitrogen (g lA1) Phosphorous (g lA1) Potassium (g lA1) o-di-phenols (g lA1) Total poly phenols (g lA1) Residual oils (g lA1) Toxicity by LUMIStox (% inhibition) Untreated OMW 5. 46 8. 7 5. 9 82 368 34. 117 12 26 11. 4 9. 3 8. 9 6. 5 1. 58 0. 84 5. 2 8. 395 9. 200 9. 2 100 Treated OMW 7. 6 11. 3 9. 7 44 38 4. 5 21. 9 ND ND 2. 5 1. 42 3. 5 2. 7 1. 72 1. 12 4. 4 1. 265 1. 578 Not detected 38 ARTICLE IN PRESS Changes in microbial and soil properties following amendment 95 Study sites and sampling The study area consisted in a ? eld of olive trees located in Chaal at 60 Km to the South-West of ? Sfax, Tunisia, North latitude 341 30 , East longitude 101 200 . The mean annual rainfall is 200 mm (Ben Rouina et al. , 2001). The ? eld was divided in ? ve plots.Three experimental plots P1, P2, and P3 we re annually amended in February with 50, 100, and 200 m3 haA1 of untreated OMW respectively (Ben Rouina, 1994). The plot P4, was annually amended with 400 m3 haA1 of the treated OMW. The ? fth plot, plot C, was not amended and served as control. Soil samples were collected from different parts of each plot from 0 to 10 cm deep, using a soil auger. All soil samples, taken from each plot were then mixed, air-dried, sieved with a mesh size of 450 mm and stored at 4 1C prior to use. Water content was immediately determined before airdrying the sample. xtracted with 1 M solution of ammonium acetate (pH 7) using a soil/solution ratio of 1/10 (w/ v). The suspension was analysed with an inductively coupled plasma atomic emission spectrometer (ICP-AES, ARL 3580). Microtoxicity determination The microtoxicity test consisted in the inhibition of the bioluminescence of Vibrio ? scheri LCK480 using the LUMIStox system (Dr. Lange GmbH, Duesseldorf, Germany) and according to ISO 11348-2 (1998). Pe rcentage inhibition of the bioluminescence was achieved by mixing 0. 5 ml of OMW and 0. 5 ml luminescent bacterial suspension.After 15 min exposure at 15 1C, the decrease in light emission was measured. The toxicity of the OMW was expressed as the percent of the inhibition of bioluminescence (%IB) relative to a non-contaminated reference. A positive control (7. 5% NaCl) was included for each test. Physicochemical analyses Analysis of ortho-diphenols: The ortho-diphenols concentration in the OMW was quanti? ed by means of Folin-Ciocalteau colorimetric method (Box, 1983) using caffeic acid as standard. The absorbance was determined at l ? 765 nm. Analysis of total polyphenols: OMW was centrifuged at 7000 rpm for 20 min.The supernatant was extracted three times with ethyl acetate. The collected organic fraction was dried and evaporated under vacuum. The residue was extracted two times with dichloromethane in order to remove the non-phenolic fraction (lipids, aliphatic, sugars). The liq uid phase was discarded while the washed residue was weighed and analysed by gas chromatography coupled with the mass spectroscopy technique to con? rm the phenolic structure of the extracted compounds. COD was determined according to Knechtel (1978) standard method. BOD5 was determined by the manometric method with a respirometer (BSB-Controller Model 620 T (WTW)).Dry weight and moisture content were determined by weighing samples before and after drying overnight at 105 1C. Organic matter was determined after furnacing samples at 550 1C for 4 h. Total carbon and nitrogen were determined by dry combustion (TOC Analyser multi-N/C 1000). Ca, K, Na, and Mg analyses, the air-dried soil was Respirometric test Biological activity in the soil was achieved by measuring CO2 evolution in the aerobic condition ? (Ohlinger, 1995). The soil sample was humidi? ed to 50% of its water holding capacity and incubated at 30 1C in the dark. The CO2 evolved was trapped in an NaOH solution and titrated with HCl.Microbial estimation Ten grams of the soil sample was suspended in an erlenmeyer ? ask containing 90 ml of a sterile solution (0. 2% of sodium polyphosphate (NaPO3)n in distilled water, pH 7. 0) and 10 g of sterile glass beads (1. 5 mm diameter). The ? ask was shaken at 200 rpm for 2 h. Serial 10-fold dilutions of the samples in a 0. 85% NaCl solution were plated in triplicate on PCA at 30 1C for total bacterial counts, on Sabouraud containing chloramphenicol at 25 1C for yeasts and moulds, on DCL at 37 1C for total coliforms, and on soil extract agar at 30 1C for actinomycetes.Soil extract agar was prepared as follows: 1 kg of soil was added to 1 l of distilled water and agitated energetically. Supernatant was ? ltered. Its pH was adjusted to 7 and sterilized at 121 1C for 20 min twice. A 200 ml of this extract and 20 g of Agar-agar were added to 800 ml of distilled water and sterilized at 121 1C for 20 min. Penicillin G, Cycloheximide, Ampicillin and Nistatin were dissolv ed in water and sterilized by ? ltration (0. 22 mm) and ARTICLE IN PRESS 96 were added at ? nal concentration of 1, 50, 10 and 50 mg lA1, respectively.For spore-forming bacteria counts, aliquots were heated for 10 min at 80 1C before spreading on PCA and incubation at 37 1C. Ammonia and nitrite-oxidizing bacteria were enumerated by the most probable number (MPN) procedure (Trolldenier, 1995). Culture tubes supplemented either with ammonium or nitrite were inoculated with serially diluted soil suspension. After an extended incubation of 4 weeks at 28 1C, acidi? cation of the medium was recorded by taking colour change as an indication for growth of ammonium oxidizers and the absence of nitrite as an indication for growth of nitrite oxidizers.Subsequently, the MPN was calculated in accordance with the table of MPN values. The total nitri? ers count was the sum of the oxidizers of ammonium and of nitrite. Each soil sample was analysed in duplicate and the dilution series were plated in triplicate for each medium. All these counts were expressed as colony forming units (CFU) per gram of dried soil (24 h at 105 1C). The total nitri? ers count was expressed as MPN per gram of dried soil. A. Mekki et al. high content of phenolics (9. 2 g lA1). This toxicity was reduced to 38%IB in treated OMW which contained only 1. 8 g lA1 of phenolics. The COD (21. 9 g lA1) of treated OMW remained high and far exceeded the standard for direct discharge to a natural water body. Several costly steps are necessary if we want to reach the Tunisian standard (0. 09 g lA1). The treated OMW contained appreciable concentrations of N, P, and K. This ef? uent was free of pathogens, relatively not toxic and contained low concentrations of heavy metals. Apart from COD, BOD5 and black colour, the quality of treated OMW was high and could be used for irrigation after ? eld tests.Analytical results of soils pro? les A darker soil colour was observed in the plots amended with OMW. After drying, the amended soils showed higher compactness and hardness. Soils were sampled and analysed in a particularly dry year in Tunisia. Only weak precipitations were recorded in February, May and November. The soil water content was very weak and it varied between 0. 8% and 1. 15% in the samples collected in September (Table 2). The pH increased to 9. 2 when P4 soil was amended with treated OMW and slightly decreased to 7. 4 when P3 soil was amended with raw OMW.Table 2 shows also that salinity of the amended soil increased proportionally with quantity of treated or untreated OMW. The content of the nutrients as total carbon (Ctot), total nitrogen (Ntot), P, K, Mg and humus increased after spreading Results Characterisation of the ef? uents Untreated OMW totally inhibited V. ?scheri (Table 1). This toxicity was essentially due to its Table 2. Results of the air-dried soils characterization C 89. 82 7. 44 2. 74 1. 14 7. 9 69 0. 02 0. 001 0. 14 0. 25 0. 02 14. 70 0. 23 0. 0312 2. 001 4 8. 7 P1 ND ND ND Characteristics 9 8 Particle size > > Sand = < distribution ? ? clay > > ; : in control soil Silt Moisture content (%) pH (KCl) Salinity (mg kgA1) P (mg gA1) P (water soluble) (mg gA1) K (mg gA1) Mg (mg gA1) Na (mg gA1) Ca (mg gA1) Ntot (mg gA1) N-NH4 (mg gA1) Ctot (mg gA1) Humus (mg gA1) C/N P2 ND ND ND 1. 15 7. 6 336. 5 0. 08 0. 016 1. 60 0. 40 0. 03 16. 20 0. 95 0. 055 15. 504 31 16. 32 P3 ND ND ND 1. 07 7. 4 447. 5 0. 08 0. 12 1. 80 0. 37 0. 04 15. 80 0. 91 0. 089 16. 999 34 18. 68 P4 ND ND ND 0. 82 9. 2 473 0. 05 0. 027 2. 42 0. 33 0. 31 14. 70 0. 45 0. 088 4. 001 8 8. 89 1. 13 7. 9 240 0. 03 0. 003 1. 05 0. 35 0. 17 19. 80 0. 56 0. 044 8. 002 16 14. 29P1, P2, and P3: Soils amended with 50, 100, and 200 m3 haA1 of untreated OMW respectively; P4: Soil amended with 400 m3 haA1 of the treated OMW. The plot C was not amended and served as control. ND: not done. ARTICLE IN PRESS Changes in microbial and soil properties following amendment the treated or untreated OMW. The C /N ratio remained constant in the soil amended with treated OMW while it increased proportionally in the soils amended with untreated OMW. Phenolic compounds migrated in soil according to their molecular mass. Polyphenols were adsorbed in the soil upper layers while monomers migrated in depth.Indeed phenolic monomers were detected at 1. 2 m depth 1 year after irrigation with untreated OMW (data not shown). C-CO2 18 16 C-CO2 and Ctot (mg g-1) 14 12 10 8 6 4 2 Ctot C-CO2/Ctot 1. 8 1. 6 1. 4 C-CO2/Ctot 1. 2 1 0. 8 0. 6 0. 4 0. 2 0 C P1 P2 Soil P3 P4 97 Soil respiration A respirometric test was achieved on soils sampled in September. CO2 production increased with OMW amendment (Fig. 1). For the treated OMW, a more pronounced CO2 production rate was shown since the ? rst week of incubation. However, for the untreated OMW, the start-up of the CO2 production was delayed to the 3rd week of respiration.The speci? c respiration rate expressed as the ratio of C-CO2/Ctot for the different soil samples is shown in Fig. 2. The amendment of the soil with 200 m3 haA1 increased the carbon content to 17 mg gA1 while the speci? c respiration remained very low. However, the amendment with 400 m3 haA1 of treated OMW did not much affect the speci? c respiration of the soil. 0 Figure 2. Speci? c respiration C-CO2/Ctot, cumulative CCO2, and total carbon Ctot of the soil samples studied. shown). An increase in the total micro? ora count was observed in P1, P2 and P4 in all dates of sampling (Table 3).However, at 200 m3 haA1 of untreated OMW, the total bacterial counts remained much higher compared to the control soil, but lower compared to the other doses of OMW. Effect on soil microbiology Viable mesophilic micro? ora Generally, the total micro? ora increased with the soil humidity. OMW enhanced the water holding capacity of the soil. The soil water content increased when the OMW dose increased (data not 12 Viable yeasts and moulds micro? ora In comparison with the control soil, an o verall high CFU of fungi in the soil amended with untreated OMW was found (Table 4).In all dates of sampling, the fungal CFU number decreased when OMW increased but remained much higher than the control soil except for biologically treated OMW which had a lower CFU than the control. We noted that the pH of OMW leaving the anaerobic reactor ranged between 7. 6 and 8. This pH increased to 8. 7 during its storage at ambient temperature. After amendment with treated OMW, the pH of the soil increased to 9. 2. Such pH value is considered as detrimental for the fungal growth. C P1 P2 P3 P4 mg C-CO 2 g -1 (dry soil) 10 8 6 4 2 0 0 5 10 15 20 25 30 Viable total nitri? rs Soils C, P1 and P2 showed broadly comparable nitri? er MPN numbers. However, a decrease in viable nitri? ers count was observed in P3. This decrease was more signi? cant in P4 (Table 5). Time (d) Figure 1. Cumulative respiratory activity as mg CO2 gA1 dry soil of different samples incubated over 28 days at 28 1C in the dark. Viable actinomycetes The actinomycetes CFU number increased when OMW doses increased up to the dose of 100 m3 haA1. At 200 m3 haA1 of untreated OMW, the CFU number remained higher than C and P1 (50 m3 haA1). However, it was lower than P2 (100 m3 haA1) (Table 6).ARTICLE IN PRESS 98 Table 3. Aerobic heterotrophic bacteria counts CFU ( A 104) gA1 in the different plots Feb C P1 P2 P3 P4 3472 8574. 95 12177. 11 6673. 9 9075. 3 May 6974. 05 7774. 52 8975. 32 7274. 23 10175. 93 Jun 24. 571. 44 45. 572. 67 57. 573. 38 5773. 35 7974. 64 Sep 1570. 88 48. 572. 85 65. 573. 85 43. 572. 55 6073. 52 Nov 21. 571. 26 8374. 88 16179. 46 9275. 4 15879. 29 A. Mekki et al. Data expressed as mean value (three replicates) and standard deviation for colony forming units per gram of dried soil. Table 4. Fungi counts in the different plots CFU ( A 104) gA1 Feb May 370. 5 11. 573. 64 571. 58 4. 671. 45 1. 8570. 58 Jun 370. 95 1775. 38 1574. 75 1173. 48 2. 8570. 9 Sep 1. 370. 41 15. 574. 9 1073. 17 4. 171. 2 9 1. 7470. 55 Nov 2. 770. 85 14. 774. 65 13. 574. 27 11. 273. 55 1. 3570. 42 C P1 P2 P3 P4 3. 571. 11 1073. 17 5. 571. 74 7. 572. 37 1. 8270. 57 Table 5. Nitri? ers counts MPN (x104) gA1 in the different plots Feb May 4. 770. 62 4. 570. 59 4. 270. 55 2. 870. 37 0. 4870. 063 Jun 3. 270. 42 3. 470. 45 2. 670. 34 1. 770. 22 0. 5170. 07 Sep 2. 870. 37 2. 470. 31 2. 470. 31 1. 170. 14 0. 0770. 009 Nov 3. 870. 5 3. 170. 41 2. 870. 37 1. 170. 14 0. 70. 11 C P1 P2 P3 P4 3. 670. 47 2. 670. 34 270. 26 1. 970. 25 0. 4670. 06 Table 6. Actinomycetes counts CFU ( A 104) gA1 in the different plots Feb May 2. 170. 28 14. 571. 93 18. 572. 46 1872. 39 17. 572. 33 Jun 270. 26 871. 06 15. 572. 06 1271. 59 15. 672. 07 Sep 270. 26 1071. 33 10. 571. 39 5. 570. 73 12. 2971. 63 Nov 3. 570. 46 12. 871. 7 17. 272. 29 14. 771. 95 15. 772. 09 C P1 P2 P3 P4 0. 670. 08 770. 93 1171. 46 570. 66 13. 2971. 77 Viable spore-forming bacteria and total coliforms The spore-forming bacteria increased with the increase of OMW doses (data not shown).For P4 soil, it shifted from the CFU gA1 number ranging from 0. 28 to 1. 12 A 104 in the control soil to CFU gA1 number ranging from 1. 1 to 2. 12 A 104 in P4 amended with 400 m3 haA1 of treated OMW. Total coliforms are well known as contaminant indicator bacteria in wastewater and soil. The number of the total coliforms was very low in the control soil. It increased when the treated or untreated OMW quantity increased (data not shown). Discussion This study attempted to demonstrate that soil amended with different concentrations of OMW showed modi? ation of its structure and its texture. The acidity of the untreated OMW was compensated by the soil carbonate alkalinity. The carbonates at the same time became bicarbonates, moved and accumulated in deeper horizons as was shown by Sierra et al. (2001). The increase of the salinity in the soil could result from the main ionic species, sodium chloride and sulphate, coming from the treated or untreated OMW. This is in line with previous ? nding ARTICLE IN PRESS Changes in microbial and soil properties following amendment (Paredes et al. , 1987; Sierra et al. 2001). Hence, in long-term applications, replacement of the soil calcium by the cations of Na, K and Mg could lead to the degradation of the soil structure and the formation of saline soils as was suggested earlier by Zenjari and Nejmeddine (2001). Biologically treated OMW had a pH48, and the alkalinity of this waste was not regulated (buffered) by the soil components. Soil porosity was reduced by the combined effect of the suspended solids and the COD formed by highly polymerised polyphenolic compounds such as humic acid-like substances (Cox et al. 1997). Consequently, soil plugged and became impermeable which led to a reduction of the soil aerobic community such as fungi and actinomycetes. This ? nding con? rms the reported correlation between the soil pH and the ( change in community composition (Frostegard et al. , 1993; Perkiomaki and Fritze, 2002). ? ? The increase of nutrient contents, Ctot, Ntot, P Mg , and K at all OMW treated plots, may have a bene? cial effect on the soil fertility. The OMW treated soil exhibited a higher respiration rate compared to the control soil.Nevertheless, when taking into account the added organic carbon, this activity was not in proportional ratio. Speci? c respiration expressed as C-CO2/Ctot decreased from 1. 7 in the control soil to 0. 5 in the soil amended with 100 m3 haA1 of untreated OMW. Yet, it slightly decreased to 1. 15 in the soil amended with 400 m3 haA1 of treated OMW. This can be explained by the fact that the phenolic compounds may inhibit the soil respiration, especially in the high OMW doses, and thus neutralize the favourable in? uence of its higher nutrient contents as was demonstrated by Sierra et al. 2001), Cox et al. (1997), Cabrera et al. (1996), and Paredes et al. (1987). In simple terms, the inhibition of soil respiration could be caused by the fact th at the big amount of carbon added to the soil was unavailable to the micro? ora under the effect of its strong adsorption or its reaction with the components of the soil. This disproportion could not be due to the added salt because despite the high content of salt in P4 (473 mg kgA1) compared to that in P3 (447. 5 mg kgA1), the former had a nearer speci? c respiration rate to the control plot C which contained only (69 mg kgA1).Addition of the untreated or the biologically treated OMW to the soil created some modi? cations in the average values for total number of microorganisms and their repartition. Results showed an initial increase in the numbers of CFU in most micro? ora groups after the OMW amendment, excepted for nitri? ers which decreased. In line with this ? nding, Paredes et al. (1987) reported also an increase in the total viable counts in the soil polluted with OMW. The overall low CFU number 99 observed in the P3 soil could be explained by the OMW dose becoming high an d toxic (Capasso et al. 1995). The chemolithotrophic ammonia-oxidizing bacteria (AOB) are responsible for the ? rst ratelimiting step in nitri? cation in which ammonia (NH3) is transformed to nitrate (NOA) via nitrite 3 (NOA). The AOB play a critical role in the natural 2 nitrogen cycle (Oved et al. , 2001; Mendum and Hirsch, 2002). This micro? ora could be affected by a variety of chemical conditions including aromatic compounds and salts. Indeed, the number of nitri? ers shifted from the CFU gA1 number ranging from 2. 8 to 4. 7 A 104 in the control soil to CFU gA1 number ranging from 0. 46 to 0. A 104 in P4 amended with 400 m3 haA1 of treated OMW. Some authors reported that higher pH is not favourable for some phylogenetic groups of nitrifying bacteria (Kowalchuk et al. , 2000). Moreover, some residual polyphenolic compounds present in treated OMW may be toxic for this sensitive category of microorganisms (Peredes et al. , 1987). Actinomycetes and spore-forming bacteria play a sig ni? cant role in the organic matter cycle in nature, by virtue of their considerable powers and ability to break down complex organic molecules. Actinomycetes counts were strongly enhanced by treated and untreated OMW amendment.The introduction of organic pollutants, which can potentially act as toxic substances and nutrient sources, was shown to preferentially stimulate speci? c populations (Atlas et al. , 1991). The increase of the CFU count of spore-forming bacteria were in accordance with the earlier investigations of Paredes et al. (1987) who reported an increase in spore-forming bacteria counts but a decrease in the proportion of this population in the community from 10% to 12% in the control soil to 0. 02% in the polluted soil with OMW. Fungi populations are known by their considerable depolymerising enzymes and their resistance to recalcitrant substances.The OMW enhanced fungi, the most important organisms decomposing lignin and polyphenols (Scheu and Parkinson, 1994; Borken et al. , 2002). Consequently, this population was favoured in plots P1, P2 and P3 where pH and C/N ratio were also more favourable compared to the control. This observation con? rms previous ? ndings by Perkiomaki and Fritze (2002) and Joergensen et al. (1995). ? Conclusion Based on previous studies and our results, we suggest that the effect of the long-term use of OMW in the ferti-irrigation on the soil microbial commu- ARTICLE IN PRESS 00 nity, the soil fertility and the soil physico-chemical properties remain unclear. Yet, speci? c attention must be devoted to the irrigation potential of treated OMW with explicit reference to the major crops of agricultural interest. The following guidelines should be adhered to the OMW spreading on soil A. Mekki et al. Box, J. D. , 1983. Investigation of the Folin-Ciocalteau phenol reagent for the determination of polyphenolic substances in natural waters. Water Res. 17, 511–522. Cabrera, F. , Lopez, R. , Martinez-Bordiu, A. , Dupuy de Lome, E. , Murillo, J. M. , 1996.Land treatment of olive oil mill wastewater. Int. Biodeterior. Biodegrad. 38 (3-4), 215–225. Capasso, R. , Evidenti, A. , Schivo, L. , Orru, G. , Marcialis, M. A. , Cristinzio, G. , 1995. Antibacterial polyphenols from olive oil mill waste waters. J. Appl. Bacteriol. 79, 393–398. Casa, R. , D’Annibale, A. , Pieruccetti, F. , Stazi, S. R. , Giovannozzi Sermanni, G. G. , Lo Cascio, B. , 2003. Reduction of the phenolic components in olive-mill wastewater by enzymatic treatment and its impact on durum wheat (Triticum durum Desf. ) germinability. Chemosphere 50, 959–966. Cereti, C. F. , Rossini, F. Federici, F. , Quaratino, D. , Vassilev, N. , Fenice, M. , 2004. Reuse of microbially treated olive mill wastewater as fertiliser for wheat (Triticum durum Desf. ). Bioresource Technol. 91, 135–140. Cox, L. , Celis, R. , Hermosin, M. C. , Beker, A. , Cornejo, J. , 1997. Porosity and herbicide leaching in soils amended with oli ve-mill wastewater. Agri. Ecosyst. Environ. 65 (2), 151–161. D’Annibale, A. , Casa, R. , Pieruccetti, F. , Ricci, M. , Marabottini, R. , 2004. Lentinula edodes removes phenols from olive-mill wastewater: impact on durum wheat (Triticum durum Desf. ) germinability.Chemosphere 54, 887–894. Ehaliotis, C. , Papadopoulou, K. , Kotsou, M. , Mari, I. , Balis, C. , 1999. Adaptation and population dynamics of Azotobacter vinelandii during aerobic biological treatment of olive-mill wastewater. FEMS Microbiol. Ecol. 30, 301–311. Feria, A. L. , 2000. The generated situation by the O. M. W. in Andalusia. Actas/Proceedings-Workshop Improlive2000-Annex A1. ( ( (( Frostegard, A. , Baath, E. , Tunlid, A. , 1993. Shifts in the structure of soil microbial communities in limed forests as revealed by phospholipid fatty acid analysis. Soil Biol. Biochem. 25, 723–730. ISO 11348-2, 1998.Water quality – Determination of the inhibitory effect of water samples on the light emission of Vibrio ? scheri (Luminescent bacteria test) – Part 2: Method using liquid-dried bacteria Joergensen, R. G. , Anderson, T. H. , Wolters, V. , 1995. Carbon and nitrogen relationship in the microbial biomass of soils in beech Fagus sylvatica L. forest. Biol. Fert. Soils 19, 141–147. Kissi, M. , Mountadar, M. , Assobhei, O. , Gargiulo, E. , 2001. Roles of two white-rot basidiomycete fungi in decolorisation and detoxi? cation of olive mill waste water. Appl. Microbiol. Biotechnol. 57, 221–226. Knechtel, R. J. 1978. A more economical method for the determination of chemical oxygen demand. Water Pollut. Control (May/June), 25–29. Kotsou, M. , Mari, I. , Lasaridi, K. , Chatzipavlidis, I. , Balis, C. , Kyriacou, A. , 2004. The effect of olive oil mill    do not exceed 50 m3 haA1 yA1 of untreated OMW and to decrease the dose of treated OMW up to 100 m3 haA1 yA1 to avoid the increase of the soil salinity. integrate a polishing tertiary treatment of OMW for reducing the residual coloration and toxicity of the ef? uent. frequently till and avoid dry soil conditions to maintain a maximal activity of the soil micro? ra. Acknowledgments This work was supported by Inco-med project ‘‘Mediterranean usage of biotechnological treated ef? uent water’’ ICA3-CT-1999-00010. The authors would like to thank: ‘‘Institut de l’Olivier de Sfax’’ and Dr Bechir Ben Rouina for their permission to use the experimental plant of OMW amendment at Chaal farm. ? References Ammar, E. , Ben Rouina, B. , 1999. Potential horticultural utilization of olive oil processing waste water. Acta Horticult. 474 (2), 741–744. Angelakis, A. N. , Marecos Do Monte, M. H. F. , Bontoux, L. , Asano, T. , 1999.The status of wastewater reuse practice in the Mediterranean basin: need for guidelines. Water Res. 33 (10), 2201–2217. Atlas, R. M. , Horowitz, A. , Krichevsky, M. , Bej, A. K. , 1991. Respons e of microbial populations to environmental disturbances. Microb. Ecol. 22, 249–256. Ben Rouina, B. , 1994. Repercussions agronomiques de ? l’epandage des margines comme fertilisant. Interna? tional conference on Land and Water Resources Management in the Mediterranean Region II, 583–594. Ben Rouina, B. , Taamallah, H. , Ammar, E. , 1999. Vegetation water used as a fertilizer on young olive plants. Acta Horticult. 74 (1), 353–355. Ben Rouina, B. , Gargouri, K. , Taamallah, H. , 2001. L’utilisation des margines comme fertilisant en agriculture. Journees Mediterraneennes de l’oliviers. ? ? ? Nimes, France 6–7 & 8 Avril. Borken, W. , Muhs, A. , Beese, F. , 2002. Changes in microbial and soil properties following compost treatment of degraded temperate forest soils. Soil Biol. Biochem. 34, 403–412. ARTICLE IN PRESS Changes in microbial and soil properties following amendment wastewater (OMW) on soil microbial communities and suppre ssiveness against Rhizoctonia solani. Appl. Soil Ecol. 26, 113–121. Kowalchuk, G. A. Stienstra, A. W. , Heilig, G. H. , Stephen, J. R. , Woldendorp, J. W. , 2000. Molecular analysis of ammonia-oxidizing bacteria in soil of successional grasslands of the Drentsche A (The Netherlands). FEMS Microbiol. Ecol. 31, 207–215. Law N1 574, 1996 (Legge 574, 11/11/1996). Norme sull’utilizzazione agronomica dei re? ui oleari. Gazzetta Uf? ciale N. 265 del 12 novembre, 1996. Lesage-Meessen, L. , Navarro, D. , Maunier, S. , Sigoillot, JC. , Lorquin, J. , Delattre, M. , Simon, J. -L. , Asther, M. , Labat, M. , 2001. Simple phenolic content in olive oil residues as a function of extraction systems.Food Chem. 75 (4), 501–507. Marques, I. P. , 2001. Anaerobic digestion treatment of olive mill wastewater for ef? uent re-use in irrigation. Desalination 137, 233–239. Mendum, T. A. , Hirsch, P. R. , 2002. Changes in the population structure of b-group autotrophic ammonia oxidizing bacteria in arable soils in response to agricultural practice. Soil Biol. Biochem. 34, 1479–1485. Moreno, E. , Perez, J. , Ramos-Cormenzana, A. , Martinez, J. , 1987. Antimicrobial effect of waste water from olive oil extraction plants selecting soil bacteria after incubation with diluted waste.Microbios 51, 169–174. Mulinacci, N. , Romani, A. , Galardi, C. , Pinelli, P. , Giaccherini, C. , Vincieri, F. F. , 2001. Polyphenolic content in olive oil waste waters and related olive samples. J. Agri. Food Chem. 49, 358–3514. ? Ohlinger, R. , 1995. Soil respiration by titration. In: ? Schinner, F. , Ohlinger, R. , Kandeler, E. , Margesin, R. (Eds. ), Methods in Soil Biology. Springer, Berlin, pp. 95–98. Oved, T. , Shaviv, A. , Goldrath, T. , Mandelbaun, R. T. , Minz, D. , 2001. In? uence of ef? uent irrigation on community composition and function of ammoniaoxidizing bacteria in soil.Appl. Environ. Microbiol. 67, 3426–3433. Paredes, M. J. , Mo reno, E. , Ramos-Cormenzana, A. , Martinez, J. , 1987. Characteristics of soil after 101 pollution with waste waters from oil extraction plants. Chemosphere 16, 1557–1564. Paredes, C. , Roig, A. , Bernal, M. P. , Sanchez-Monedero, M. A. , Cegarra, J. , 2000. Evolution of organic matter and nitrogen during co-composting of olive mill wastewater with solid organic wastes. Biol. Fert. Soils 32 (3), 222–227. Perkiomaki, J. , Fritze, H. , 2002. Short and long-term ? ? effects of wood ash on boreal forest humus microbial community.Soil Biol. Biochem. 34, 1343–1353. Rinaldi, M. , Rana, G. , Introna, M. , 2003. Olive-mill wastewater spreading in southern Italy: effects on a durum wheat crop. Field Crops Res. 84, 319–326. Sayadi, S. , Ellouz, R. , 1992. Decolourization of olive mill waste-waters by the white-rot fungus Phanerochaete chrysosporium : involvement of the lignin-degrading system. Appl. Microbiol. Biotechnol. 37, 813–817. Sayadi, S. , Ellouz, R. , 1995. Roles of lignin peroxidase and manganese peroxidase from Phanerochaete chrysosporium in the decolorization of olive mill wastewaters.Appl. Environ. Microbiol. 61, 1098–1103. Sayadi, S. , Allouche, N. , Jaoua, M. , Aloui, F. , 2000. Detrimental effects of high molecular-mass polyphenols on olive mill wastewater biotreatment. Process Biochem. 35, 725–735. Scheu, S. , Parkinson, D. , 1994. Changes in the bacterial and fungal biomass C, bacterial and fungal biovolume and ergosterol contents after drying, remoistening and incubation of different layers of cool temperature forest soils. Soil Biol. Biochem. 26, 1515–1525. Sierra, J. , Marti, E. , Montserrat, G. , Cruanas, R. , Garau, M. A. , 2001.Characterization and evolution of a soil affected by olive oil mill wastewater disposal. Sci. Total Environ. 279, 207–214. Trolldenier, G. , 1995. Nitri? ers by MPN method. In: ? Schinner, F. , Ohlinger, R. , Kandeler, E. , Margesin, R. (Eds. ), Methods in Soil Biology. Springer, Berlin, pp. 32–36. ? ? Yesilada, E. , Ozmen, M. , Yeslada, O. , 1999. Studies on the toxic and genotoxic effect of olive oil mill wastewater. Fresenius Envir. Bull. 8, 732–739. Zenjari, A. , Nejmeddine, A. , 2001. Impact of spreading olive mill wastewater on soil characteristics: laboratory experiments. Agronomie 21, 749–755. My Aim in Life There are two things to aim at in life: first, to get what you want, and after that to enjoy it. Only the wisest of mankind achieve the second. Logan P. Smith People have set their own aim depending upon their abilities. Some people are doctors, engineers, Charter Accountants, pilots, teachers and many more. Our life is too short so we have to strive to attain our aim with all our hard work. The main objective for achieving the aim is to get material pleasures, mental happiness as well as satisfaction. Once a person chives his aim he can live a prosperous life.The mere act of aiming at something big, makes you big. Charcoal Nehru My aim in life is neither to collect money nor for fame. It is my desire to become a well-qualified doctor. I do not just wish to be an ordinary doctor. The world remembers with thankfulness the name of the man who gave to the world vaccination. The world will remember forever the man who gave us penicillin. As a doctor I want to serve the humanity. Don't ai m for success if you want it; just do what you love and believe in, and it will come naturally.David Frost have an ambition to do something in this world so, great as the doctors and the courageous founders did in the past. I would like to give the world some new drugs and injections that will cure some of the diseases that people are still suffering from. An aim in life is the only fortune worth finding. Robert Louis Stevenson know, my profession is very dignified and it will help me to get peace and satisfaction in life. It provides us best chances of service. Sympathy to human being is the sympathy to one own self. Quotations About this essay. Future favors the bold.An early death is better than an aimless life. A noble aim is simply a noble deed. My goal in life is to survive. Everything else is just a bonus. The greater danger for most of us lies not in setting our aim too high and falling short; but in setting our aim too low, and achieving our mark. Michelangelo The aim of ar t is to represent not the outward appearance of things, but their inward significance. Aristotle. Aim above morality. Be not simply good, be good for something.

Alabama Air Case

1. State any business problem that the enterprise needs to resolve: Darden Restaurants needs to manage a supply-chain of highly perishable items such as seafood, over 35 countries, while managing costs and product quality. Furthermore, the company needs to ensure a strict protocol of inspection and quality assurance throughout the supply chain. 2. Briefly summarize relevant background information from the case. Darden restaurant owns popular brands such Olive Garden and Red Lobster, comprising of 1400 restaurants in the US. These are 300 million meals served annually with purchases from 35 ountries. The average shelf life of the food item is 4 days and temperature of 34 degrees must be ensured at each step of the way. 3. Describe how the enterprise dealt with its issues and their relevance The airline executives have decided to use Statistical Process Control tools to measure the airlines on-time performance and to guage how it is doing in relation to the rest of the airline industry. The Data: WeekLate FlightsFraction Late 120. 02 240. 04 3100. 1 440. 04 510. 01 610. 01 7130. 13 890. 09 9110. 11 1000 1130. 03 1240. 04 1320. 02 1420. 02 1580. 08 620. 02 1730. 03 1870. 07 1930. 03 2020. 02 2130. 03 2270. 07 2340. 04 2430. 03 2520. 02 2620. 02 2700 2810. 01 2930. 03 3040. 04 120 4. Using a 95% confidence level plot the overall percentage of late flights p, and the upper and lower control limits. p =Total Number of errors Total Number of Sample p=120=0. 04 (100)*(30) sigma=SQRT(((. 04)*(1-. 04))/100) sigma=0. 02 UCL=p + 2*. 02=0. 08 LCL=p – 2*. 02=0 Using 95% Confidence leve l (z=2), we plot a control chart for the fraction of late flights for ezch week. We also superimpose the industry upper and ower control limits of . 1 and . 04 repectively: The Fraction of flights late on Week 3, 7, 8 and 9 fall above the UCL of . 08 for Alabama Air. For each of these weeks management needs to get detailed data on what the problems were with the flights that were late. The fact that 3 out of the 4 weeks where the process was out of bounds were consecutive point to non-random causes for the issue. Management can conclude that they are doing better than the industry averages since the industry industry control limits are higher than the Alabama Air ones.

Investigation on the Influence of the Recession towards Online Retail Literature review

Investigation on the Influence of the Recession towards Online Retail Shopping - Literature review Example Retailing mainly aims at providing an innovative way of shopping experience for the consumers with due regards to their preferences to a large extent. The basic strategy of retailing intends to deliver the best quality service for a longer period of time. In the current era, the retailing industry plays a significant role as a major contributor to the GDP growth of any economy. It is further noted as one of the fastest growing and most promising industries in the global region (Purohit & Kavita, 2009). It was further stated by Chan (2007) that retailing is considered to be the ultimate connection between the end-users and the production of various goods. With the assumption that the end-consumers are not quite huge in number or population and are immobile as well as uninformed, the firms operating in the retail industry should focus on various attributes. These attributes to be considered by the retailing forms include the geographic regions of the targeted market, the price visibili ty of the consumers, quality assurance, and product portfolio among others. It is in this context that by considering these attributes, a retail firm is likely to gain better understanding of the market trends and consumer behaviour (Frieden & Roche, 2006). Difference between Traditional and Online Retail With due consideration to the development of the retail industry, its structure can be classified in two segments, such as the traditional retail industry and the contemporary retail industry. As stated by Frieden & Roche (2006), traditional retail is highly developed in small areas of towns and cities of various geographical regions which fundamentally concentrate on the physical distribution of commodities with minimum role to play by technology. Traditional retailing stores reduce the cost of shopping as it brings the products within the reach of the customers, mostly in their local residential area. Certain significant aspects such as assurance of the selected products, its pri ce, and promotional features among others are primarily taken into account by the traditional retailers. Traditional retail system also concentrated on direct selling channels which provided with bargaining opportunities to the customers but incurred considerable costs for the distributors (Chan, 2007). It is worth mentioning that in the contemporary retail marketing, various products are offered including the categories such as food and grocery, wet groceries, and apparel among others that increases the growth of modern retailing. It mainly aims at developing different types of strategies and selling the products as well as services by minimizing the cost of the product. This enables the contemporary retail channels to offer the consumers a vast and complete range of products as per their request and at a cheaper rate than that available through traditional stores. The supermarkets also bear same kind of strategies and are analyzed in an effective manner for an efficient developmen t of traditional retailers. Another advantage presented by the retail stores can be regarded as the accessibility of various national brands as well as internationally renowned brand in the particular market segment (Berni & et. al., n.d.). This increases the customer satisfaction to a large extent

Building Community as a Leadership Discipline Dissertation

Building Community as a Leadership Discipline - Dissertation Example Such leaders avoid acting in a dictatorial manner. They are usually motivated while working in settings characterized by facts, whereby they can apply theories and their expertise as well as analytical skills. They set achievable goals that are understandable by everyone. These are achieved through the allocation of roles to the employees, and supervising to ensure that the process follows the right track while adhering to organizational policies. They respect the management hierarchy, whereby each level of management is significant in the process.  Due to the fact that an organization has to be faced with dilemmas, the structural leader is usually faced with situations whereby a balance has to be established between the external environment and the organizational practices. Such a leader usually focuses on plain and consistent thinking in order to deal with organizational problems as well as utilization of the available opportunities (Bolman and Deal 2008). This is dependent to a large extent on the environment that the leader works in. A favorable working environment is usually a derivative of the predecessors in the organization’s management. The structural leader ensures that he leaves an enabling environment once he leaves an organization. This facilitates learning in the leaders who come thereafter. On the other hand, he ensures that the present leaders within the organization, especially those working under him have such leadership qualities as him/her. The organizational strategy is usually developed through structural Leaders, who are keen on the working framework, environment, the realization of organizational goals, testing as well the necessary reforms within the organization.

Uncle Tom's Cabin Essay Example | Topics and Well Written Essays - 250 words

Uncle Tom's Cabin - Essay Example The novel depicts the harsh reality of slavery while also showing that Christian love and faith can overcome even something as evil as enslavement of fellow human beings. The character Uncle Tom-African American maintains his integrity and refuses to betray his fellow slaves at the cost of his life. His firm Christian principles in the face of brutality made him a hero to whites. To the contrast his tormentor; Simon legree, the Northern slave-dealer turned plantation owner, enraged them with his cruelty. The enactment of emancipation proclamation in January 1863 capped two years of increasing support for emancipation in New York City. Although republicans attempted to keep abolitionist from taking a leading role in New York’s anti-slavery politics, by 1862 abolitionist speakers drew huge crowds, black and white in the city. Increasing support for the abolitionist, and emancipation led to anxiety among New York’s pro-slavery white supporters of the Democratic Party, particularly the Irish. From the time of Lincoln’s election in 1860, the Democratic Party had warned the New York’s Irish and Germany residents to prepare for the emancipation of slaves and the resultant labor competition when Southern Black would supposedly flee

SEMESTER AT SEA Research Paper Example | Topics and Well Written Essays - 1500 words

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Breach of Professional Accounting Ethics Essay Example | Topics and Well Written Essays - 500 words

Breach of Professional Accounting Ethics - Essay Example Enron Corporation was an energy company established in 1985 with headquarters in Houston, Texas. To diversify its business portfolio for long-term investments, it had created Special Purpose Entities (SPEs). According to the EITF 90-15 rule, 3% of the capital for the creation of these SPEs should come from an outside investor. Enron Corporation misused the rule and received the required amount from internal company managers or their wives. The Auditor of the Corporation- Arthur Andersen, in order to remain loyal to the company executives and remain an ‘independent auditor’, provided consultancy to the Corporation and provided misleading and incorrect details of financial audits of the Corporation, which ultimately lead to the Company filing bankruptcy in December 2001, due to millions of debts concealed from stakeholders (Rittenberg et al, 2009, p. 427). The platform for the bankruptcy of Enron was set when its top managers and executives bent the accounting standards fo r their personal gains. In order to diversify its business portfolio, Enron took a fatal turn by deciding to be an energy broker. For this purpose, it started entering into separate contracts with sellers and buyers, thereby profiting from the difference in the prices of the commodities. Keeping its books closed from investors and stakeholders, Enron entered into risky ventures and the accomplice, in this case, was the auditing firm- Arthur Andersen, who concealed the actual position and standing of the Corporation from the outside world. Later on when the differences were tried to be matched, Enron posted mammoth losses running into billions of marks, which spelled demise for it. The Enron scandal is considered to be one of the biggest securities and accounting ethics fraud registered in history. The Securities and Exchange Commission (SEC) was handled the responsibility to examine thecompanies in overstating their financial health.

Advocacy Grantmaking and civic organizations Essay

Advocacy Grantmaking and civic organizations - Essay Example Presently, thousands of advocacy, grant making and civic organizations have been formed primarily to serve the different groups and societies. In United States, these kinds of organizations exist in all states and are working with an aim of bettering the lives of the communities by openly addressing issues that afflict the people through service, civic engagements and independent actions. The organizations are diverse spanning the political field of ideas and entail all aspects of human interest including environmental conservation, homeless shelters advocates and day care centers (Center for Lobbying in the Public Interest, 2010). There are also organizations that address people’s concerns through sports and while others stands for the rights of particular groups in the society such as the rights of employees or a social group. Advocacy, grant making and civic organizations are collectively known as collectively known as nonprofits, not-for-profit sector, independent sector, third sector, philanthropic sector, social sector or the voluntary sector. The paper will explore different groups within the nonprofit sector and the issues they addressed. Moreover, it will assess the work environment in the industry (Center for Lobbying in the Public Interest, 2010). All the non-profit organizations are established to serve the interests of its members. However, all the organizations have varying goals which are used to categorize them. The US Bureau of Labor Statistics categorizes the non-profit industry into four segments: business, labor, professional, political and related organizations; social and civic organizations; social advocacy organizations and grant making and giving services. Business, professional, labor, political and allied organizations is the largest segment in the non-profit sector and offered approximately 423, 300 jobs in May 2004 as was

The use of Graphic Novels as an Educational Tool Research Paper

The use of Graphic Novels as an Educational Tool - Research Paper Example One school of thought holds that the nineteenth-century Swiss Artist Rodolphe Topffer was the first cartoonist in the modern sense. Scott McCloud argues in Understanding Comics that the Bayeux Tapestry, which was probably created in the eleventh century, is an example of sequential visual narrative and therefore counts as comics† (Wolk 29). However, it seems that the audience remains unaffected by such scholarly debate over inception of comics as a separate art form; rather they are more concerned over deriving the pleasure of reading and involving themselves with the ambiance created through color, expression, and beautifully crafted emotions. Prior to the Great War II, American comic market was mainly dominated by superheroes. However, the situation started changing gradually since the post-Great War II period, as the Japanese Manga comics first intruded the market. At the initial stage heroes with humane attribute did not have the capacity to combat the superheroes but it did not take much time that manga heroes emerged as triumphant against American superheroes. Another benefit of these Japanese manga comics was that those were highly appreciated by women and teenage girls section of the society. David Okum observes, â€Å"Japanese manga developed a strong following after World War II. The themes and stories reflect popular culture and national tastes†¦.There is a wide audience of women, men, boys and that accepts comics and animation as just another medium of storytelling. Manga is produced for every possible group and interest† (Okum 8). No matter how much it is discussed about massive audience patronage i n favor of the graphic novels or manga, but the enormity of such popularity does not become clear unless we come across proper statistical data of the existing market condition of the manga comic.

Us History LO 23-27 Essay Example for Free

Us History LO 23-27 Essay The Secession of the South was not, initially, a matter of bloodshed. In the beginning the movement toward secession was based solely on legal and political grounds. In the North, te newly elected President Abraham Lincoln vowed to preserve the Union but also vowed not to be the first to spill blood over the crisis of secession. In the South, however, the feeling of euphoria mixed with antagonism toward the North which swept over the Southern states resulted in a crisis-within-a-crisis when the issue of Fort Sumter became the unforeseen trigger of the Civil War. By 1861, in the newly seceded states, the only remaining property in Union hands were two obscure forts in the Florida Keys along with Fort Pickens on an island at the mouth of Pensacola Bay and Fort Sumter on an island in Charleston harbor. Fort Sumter had become a commanding symbol of national sovereignty in the very cradle of secession, a symbol that the Confederate government could not tolerate if it wished its own sovereignty to be recognized by the world. Would Lincoln use force to defend Sumter? 1 In fact, the issue of Fort Sumter was resolved by violence with the Fort surrendering after a short period of bombardment from Confederate forces. This early victory for the South would prove to be pyric in nature as it touched off a larger conflict which they could not hope to win. Only the Southern resourcefulness and conviction in their right to secession prolonged the war as long as it could be prolonged, as the North commanded a superior economy, superior manpower, and superior armaments from the wars beginning to its end. Question 2: Explain the various internal political conflicts in the North, focusing on Copperheadism and the 1864 campaign. By the time of the 1864 elections, there was a strong sentiment brewing in the North for finding an end to the Civil War, whether or not this end would bring about the immediate reintegration of the Southern States into the Union. The Democratic party in tye North chose to run McClellan as a probable peace candidate against Lincoln. This , in turn, brought upon accusations that McClellan was a Souther Sympathizer or a copperhead as they were often called in the A Civil War era. Copperheadism, in fact, became a core issue of the Persidential election; as Union military victories portended a continuation of Lincolns war-policy, Far to the north George B. McClellan digested the news of Atlanta as he wrote his letter accepting the Democratic nomination. If he endorsed the platform, or said nothing about it, he would by implication commit himself to an armistice and negotiations. McClellan felt great pressure from the partys peace faction to do just that 2 Basically, an armistice was desired by certain peace factions in the North who were painted as copperheads by their detractors who supported the continuation of the war. True copperheads were those in the North or border states who were Southern sympathizers. The 1864 election turned out to be a referendum on the war itself, obviously, with McClellan having been successfully painted by his opponents as a peace candidate and perhaps even a copperhead. The Democrats Janus face toward the war presented Republicans with an easy target. 3 Question 3: Explain why the North won the Civil War and why the South lost. The South suffered a military defeat which wa exacerbated by its inabiolity to gain International, specifically European, recognition and thus the ability to break the Union naval blockade and open up to international commerce. The military defeat of the South was total. The Civil War is often called â€Å"the first modern war. † It saw the introduction of rapid-fire weapons. Trenches were first used extensively in battle. The railway and the telegraph were first used in a large-scale war. The campaigns of Lee, Jackson, Grant, Sherman, and Joseph E. Johnston were studied aboard for new concepts of strategy and tactics. At sea, ironclad ships and rifled cannon had made the wooden navies of the world obsolete. Few observers at the start of the American Civil War imagined the ultimate de-evolution of the war from its psuedo-Napoleonic beginnings with armies in formation maneuvering along classical military lines to achieve a tactical advantage. Because so many of the generals on both sides of the war derived their knowledge of battlefield tactics from the same sources, particularly Jomini, and also because many of the generals on either side received training at West Point, the wars beginning gave but a small hint of the total war which would be achieved by the close of 1865. In fact, the realization that much more than battlefield victory would be necessary to put down the Southern rebellion was slow to be reached by Lincolns generals. It was Sherman, perhaps, who first understood the underlying economic nature of the war, realizing that the Union with its superior material and financial power would ultimately prevail. However, his conception of how to convince the South of this truth was founded on a concept of total war, a strategic approach first used on the famous march to the sea. During this late period of the war, Sherman envisioned a dazzling campaign to march his army across Georgia to the sea, tearing the Confederacy asunder, and destroying everything in his path. (Ades, 226) The ensuing destruction wrought havoc and despair on the civilian population of the South and undermined the Souths economic and psychological ability to survive. The idea of war as a psychological tool of destruction was both new and devastatingly powerful. It turned out that the Georgia countryside had an abundance of supplies for Shermans 62,000 strong army. Nearly all the fighting took place on Southern soil, so that section suffered heavy war damage. Some regions, such as central Georgia and the Shenandoah Valley, were deliberately ravaged. Freeing of the slaves added a property loss estimated at $2 billion. The Federal government spent more than $6 billion on the war; the Confederacy, perhaps $ 2 billion. Both sides sustained heavy casualties. There were far more deaths caused by disease than by combat. Estimated total deaths are 360,000 for the union army and 260,000 for the Confederate army.

Principles of the WTO

Principles of the WTO The General exceptions provide a list of measures that countries can enforce. These measures are a necessity [1]to protect basic and fundamental socio-economic and political interests to protect the character and integrity of a nation. The term necessary was discussed by a previous panel albeit in context to article XX (d) and held that a contracting party could not justify a measure inconsistent with GATT as necessary if there were reasonable available alternative measures that were less inconsistent with GATT provisions.[2] Trade liberalization being the fundamental objective of the WTO comes in direct conflict with national policies and interest of member states article XX of GATT provided exceptions that serve as justification for member states to enforce measures for safeguarding their interests. The WTOs founding and guiding principles remain the pursuit of open borders, the guarantee of most-favoured-nation principle and non-discriminatory treatment by and among members, and a commitment to transparency in the conduct of its activities[3]. The pursuit of a free market and open trade creates a conflict of interest on a national and international level. National policies implemented by governments occasionally do not conform to products and ideals of the international market, an example can be seen between western and eastern governments whereas betting as an industry is accepted in most of the countries, Islamic states such as Pakistan do not allow betting and as such foreign investors cannot run gambling businesses as gambling is prohibited under sharia law. What is generally accepted in one geopolitical area is not considered a norm by another state. It then becomes a challenge to maintain a balance between policies that are a governments legitimate objectives and non-discrimination against foreign competition and objectives that are inconsistent with the ideals of free trade.[4] The appellate body in US-Shrimp best summarized this by stating; a balance must be struck between the right of a Member to invoke an exception under Article XX and the duty of that same Member to respect the treaty rights of the other Members[5] Chapeau Article XX consists of a preamble called the chapeau and subsequent subparagraphs. The Chapeau was introduced into the exceptions article of the commercial policy chapter of the draft ITO Charter during the London session of the Preparatory Committee a delegation in the conference suggested that uncertainty in the protection clause is not desirable as it leaves these provisions open to abuse. To prevent abuse this excerpt to article 32[XX] was introduced[6]; The undertakings in Chapter IV of this Charter relating to import and export restrictions shall not be construed to prevent the adoption or enforcement by any Member of the following measures, provided that they are not applied in such a manner as to constitute a means of arbitrary discrimination between countries where the same conditions prevail, or a disguised restriction on international trade. The suggestion was generally accepted subject to its review to the wording specifically on whether the scope should be limited to import and export restrictions.[7]The amendments were made and the GATT was signed on the 1947 in Geneva and came into effect in 1948,which eventually led to the Uruguay round agreement establishing the WTO in 1994[8]. The historical map of the chapeau is significant as it highlights its objective. Concisely, the chapeau is in place to prevent abuse of the exceptions under article XX to justify a measure that is inconsistent with the General agreement. The chapeau combats this problem through two requirements that must be met by a member invoking the exception. First a measure provisionally justified under one of the sub-paragraphs of article XX must not be applied in arbitrary or unjustifiable discrimination means between countries where the same provisions prevail. This condition involves a prohibition on any measure that has a disproportionate economic impact on products from certain countries when compared to its impact on competitive products from other countries.[9] In Us-Shrimp, the appellate body laid out conditions that must exist for arbitrary or unjustifiable discrimination to be established (1) the application of the measure at issue must result in discrimination;(2) this discrimination must be arbitrary or unjustifiable in character; and (3) this discrimination must occur between countries where the same conditions prevail.[10] The Similar conditions test however will in essence fail in instances where the factors relevant to the measure are significantly different. However in US-Shrimp(1998) the Appellate body held that in circumstances where different conditions between countries prevail, the rigid and inflexible application of the measure may constitute and arbitrary discrimination.[11]The second Justification is discretionary in nature, it is independent of the objective in measure. The effect of this dual justification is to enhance the regulatory autonomy of WTO members.[12] Secondly this measure must not be applied in a manner that constitutes a disguised restriction on international trade[13]. This measure is not clear and panels have not been able to find a certain means on clarifying on the same. It is difficult to ascertain the objective of a measure as the Appellate Body found in Japan-Alcoholic Beverages (1996).[14] However in US-Gasoline (1996)[15] the panel held that disguised restriction can be identified when read with arbitrary discrimination and unjustifiable discrimination. The disguised restrictions amount to arbitrary or unjustifiable discrimination in international trade when taken under the under the guise of a measure formally within the terms of an exception listed in Article XX.. The test used to determine the presence of Arbitrary or unjustifiable discrimination can be used to identify disguised restrictions. The Panel in EC-Asbestos (2001) stated that a restriction which formally meets the requirements of Article XX(b) will constitute and abuse if such compliance is in fact only a disguise to conceal the pursuit of trade-restrictive objectives.[16] These requirements ensure that members submit substantive legitimate claims that do not prejudice the rights of other members to the treaty. Article XX should not be used as a disguise to abscond from the obligations of the general agreement but as an avenue to maintain the balance between rights and obligations of the members to the General agreement. Article XX reflects on the principle of good faith. It ensures fair dealings are undertaken through the obligations of the general agreement. It instils a sense of Duty on the members to respect each others rights while giving them an avenue to further their objectives on a national level[17]. However despite the attempts to limit abuse of the provision, the general exceptions have become the subject of most WTO disputes. In US-Gasoline (1996) the appellate body stated the exceptions under article XX can be invoked as a matter of legal right, however caution should be taken in its use. The exception should not be used in a manner that frustrates the legal obligations of the holder in the General agreement. The provision must be applied reasonably with due regard to the party claiming the exception and the legal rights of the other parties concerned[18]. From the above analysis, the Chapeau was introduced as a firewall. It provides a legal justification for measures that meet the requirements listed in it. The application of the same becomes a subject of dispute as it is difficult to satisfy all the members due to conflicting interests. The Appellate body in US-Shrimp year?addressed the ideal means of application by stating; The task of interpreting and applying the chapeau is, hence, essentially the delicate one of locating and marking out a line of equilibrium between the right of a Member to invoke an exception under Article XX and the rights of the other Members under varying substantive provisions (e.g., Article XI) of the GATT 1994, so that neither of the competing rights will cancel out the other and thereby distort and nullify or impair the balance of rights and obligations constructed by the Members themselves in that Agreement. The location of the line of equilibrium, as expressed in the chapeau, is not fixed and unchanging; the line moves as the kind and the shape of the measures at stake vary and as the facts making up specific cases differ. The chapeau should be used as a balancing provision, on one hand it provides a right for members to invoke an exception to protect their National interests and on the other hand it should ensure members meet their obligations. The margin that separates the two is not fixed, it is based on the circumstances of each case. An objective? Approach is taken considering the prevailing conditions of each case to ensure the appropriate equilibrium is maintained. Article XX can be invoked by a member when a measure has been found to be inconsistent with another GATT provision, this will be a justification of the inconsistency and will have to be backed with evidence to disprove the claim. Article XX can be construed to be an Omnibus Clause as it covers all provisions in the GATT 1947.The wording of the preamble, reflects the same nothing in this agreement shall be construed to prevent the adoption or enforcement of measuresà ¢Ã¢â€š ¬Ã‚ ¦ In US-Section337 Tariff Act (1989) stated that measures satisfying the conditions set out in article XX are permitted even if they are inconsistent with other provisions of GATT 1947.Article XX however provides limited and conditional exceptions listed in the respective sub paragraphs inconsistent with another provision of the General agreement.[19]The conditional limitations serve two functions, first they are necessary to maintain a balance between obligations under GATT and National Policies, and secondly they prevent abuse of the obligations under the guise of protectionism[20]. Article XX can be invoked by a member only when a measure by that member has been found to be prima farcie[21] inconsistent with another provision the complaining party has to submit sufficient evidence supporting this claim, the burden then shifts to the defending party that has to provide evidence to disprove this claim. The burden of proof to show that a measure has been violated lies with the party invoking it in Canada Import, Distribution and Sale of Certain Alcoholic Drinks by Provincial Marketing Agencies [22] and the 1994 report in United States Measures Affecting the Importation, Internal Sale and Use of Tobacco[23] In the former the panel concluded that with the exception of the listing and delisting of practices in Ontario, the United States had not substantiated its claim that Canada still maintained listing and delisting practices inconsistent with Article XI of the General Agreement. The latter In view of the Panels analysis, the Panel considered that the evidence did not support the complainants claim that the DMAs penalty provisions were separate taxes or charges within the meaning of Article III:2 furthermore the Panel concluded that the evidence did not demonstrate that Section 1106(c), Fees for Inspecting Imported Tobacco, mandated action inconsistent with Article VIII:1(a) of GATT 1947. Both cases reflect the Panels Jurisprudential approach on the burden of proof in which previous and subsequent panels have maintained that the burden of proof rests on the party making a complaint, the burden then shift to the defending party that has to provide evidence to disprove this claim.   Jurisprudence from the AB has laid down a two-tier test for the application of Article XX in a dispute. In US Gasoline 1996 the Appellate Body established the two-tier test involved a provisional justification by reason of characterization of the measure and appraisal of the same measure under the introductory clauses of Article XX[24] First, a Panel has to consider whether the respective measure falls within the scope of subparagraphs (a) to (j) In AB report in Korea-Measures Affecting Imports of Fresh, Chilled and Frozen Beej [25]; The Panel focussed on whether the dual retail system is necessary to ensure compliance with the law under the Unfair competition Act which on the face of it was inconsistent with provisions of the WTO. It examined enforcement measures where fraudulent misrepresentation has occurred and found that the dual retail system was not used. Instead Korea used a traditional enforcement system which was reasonably available and as such it could not fall under Article XX (d) and as such could not justify the dual retail system as a necessity under Article XX (d).A measure has to be within the scope of Article XX for it to be enforceable. The second test is whether a measure meets the requirements of the chapeau under article XX, and was necessary to achieve the respective objective. In AB report in European Communities Measures Affecting Asbestos and Asbestos-Containing Products[26]; The AB disagreed with the panels findings that considering the evidence relating to health risks associated with the product, under Article III: 4 nullifies the effect of Article XX (d) of GATT, It however held that Article XX (d) allows members to adopt and enforce a measure, Inter alia necessary to protect human life and health although that measure is inconsistent with another provision. Under Article III:4, evidence relating to health risks may be relevant in assessing the competitive relationship in the marketplace between allegedly like products. The same, or similar, evidence serves a different purpose under Article XX (b), namely, that of assessing whether a Member has a sufficient basis for adopting or enforcing a WTO-inconsistent measure on the grounds of human health. This ruling sheds light on the authority of article XX in GATT, if a measure satisfies the requirement of the chapeau and is inconsistent with another article in the Agreement, a member will be able to adopt and enforce a measure to achieve the objective that is, in this case to protect, human life. The end justifies the means. Articles under GATT should be interpreted independently and with respect to the relevant provision. The AB held that provisions satisfy the article XX if they are necessary to adopt and enforce a necessary measure under Article XX (a)-(j)à ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã‚ ¦.. It is a generally accepted principle of interpretation that exceptions are to be interpreted narrowly under the principle of (singular non sunt extendena)[27]however the Appellate Body has adopted a flexible approach in EC-Measures Concerning Meat and Meat Products (Hormones) 1998, the Appellate Body stated that characterizing a treaty provision a an exception does not justify a stricter or narrower interpretation of that provision[28]. Jurisprudence shows that ABs have adopted a less restrictive approach in a way that balances between commitments and exceptions. This approach takes after the ordinary meaning of interpreting treaties where a treaty shall be interpreted in good faith and in accordance with the ordinary meaning to be given to the terms of the treaty in their context and in light of its object and purpose[29]. This Approach was used in the US Gasoline (1996) and US-Shrimp (1998) where the panel stated that: the context of article XX (g) includes provisions of the rest of the General Agreement including particular Article .conversely, the context of Articlesà ¢Ã¢â€š ¬Ã‚ ¦ includes Article XX, accordingly, the phrase @relating to the conservation of exhaustible natural resources may not be read so expansively as seriously to subvert the purpose and object of Article II: 4.Not may Article III:4 be given so broad a reach as effectively to emasculate Article XX (g) and the policies and interest it embodies. The relationship between the affirmative commitments set out in e.g. Articles I,II and XI, and the policies and interests embodied in the General Exceptions listed in Article XX, can be given meaning within the framework of the General Agreement and its object and purpose by a treaty interpreter on a case-to-case basis, by careful scrutiny of the factual and legal context in a given dispute, without disregarding the words actually used by the WTO members themselves to express their inten t and purpose[30]. The approach taken by the AB entails to maintain a balance between it then takes various factor in consideration, first it aims to facilitate the fundamental WTO objective of trade liberalization, second balancing member interests, General rules of interpretation, which inter alia include giving light to the context and meaning of the preamble. SCOPE As discussed earlier on, it is clear that article XX is a universal exception and the scope of application is broad. Article XX unlike other exceptions is not interpreted in the strict and narrow sense.[31] The main question that has arisen is whether article XX can be used to justify inconsistencies with obligations set out in Agreements other than GATT 1994.[32] To understand this scope of article XX in this context it is essential to understand its historical objective. During the GATT negotiations, the negotiators took the a la carte approach, which meant that members could not choose particular items but had to take everything that was offered, in contrast, during the Uruguay rounds the negotiators introduced the single undertaking approach, where membership of the WTO was made contingent on accepting all treaties as a package.[33]The members had to Join all agreements administered by the WTO[34].The aim of the shift was to consolidate disciplines negotiated in earlier rounds to all WTO members. The single undertaking idea is ingrained in the WTO ideology, it was introduced to curb fragmentation of international agreements (a La Carte).as a consequence all agreements under annex 1A of the WTO Charter were consolidated to into one document, the WTO Charter. There is no express provision in the GATT 1947 or any of the agreements under annex 1A that shows a correlation between the two. However in the event of a conflict between the two the latter shall take precedence. Lex specialis agreements take precedence over Lex generalis agreements[35]. The ambiguity on this contentious issue was shown in the AB report United States -Measures relating to shrimp from Thailand (DS343), United states-Customs Bond Directive for merchandise subject to Anti-Dumping/countervailing Duties[36]. India raised a valid point by questioning whether a defence under Article xx (d) was available to the United States to justify a measure found to constitute a specific action against dumping under Anti-Dumping agreement. The panel answered this by stating we do not express a view on the question of whether a defence under Article XX (d) of the GATT 1994 was available to the United States. The panel failed to give a definitive answer. However most recently in the in China-Publications and Audio-visual products[37] China invoked Article XX (a) to Justify the inconsistent trading rights commitments in paragraph 5.1 of Chinas Accession protocol. As in the Case of the US-Customs Bond directive[38] the panel decided to first measure whether the measures met the requirements of Article XX (d) rather than expressly on the availability of Article XX as a defence. However the Appellate Body did provide a definitive answer and criticized the panels reliance on the arguendo in answering the  Ãƒâ€šÃ‚   in question.[39] The Body observed that the provisions that China seeks to justify have a clearly discernible, objective link to Chinas regulation of trade in the relevant products. In the light of this relationship between provisions of Chinas measures that are inconsistent with Chinas trading rights commitments, and Chinas regulation of trade in the relevant products, we find that China may rely upon the introductory clause of paragraph 5.1 of its Accession Protocol and seek to justify these provisions as necessary to protect public morals in China, within the meaning of Article XX (a) of the GATT 1994.In light of the above China could rely on Article XX to Justify measures in a WTO agreement other than GATT 1994 in this case, Chinas accession Protocol. Specific Exceptions under Article XX of the GATT 1994 Subparagraphs (a)-(j) of Article XX lists detailed and specified exceptions for measures inconsistent with other provisions of GATT 1994.The specified exceptions provide a comprehensive list of grounds[40] that can be used to justify an inconsistent measure. The wording of various terms in the exceptions denotes a difference objective. As analysed in US-Gasoline the appellate Body stated that: In enumerating the various categories of governmental acts, laws or regulations which WTO Members may carry out or promulgate in pursuit of differing legitimate state policies or interests outside the realm of trade liberalization, Article XX uses different terms in respect of different categories. It does not seem reasonable to suppose that the WTO Members intended to require, in respect of each and every category, the same kind or degree of connection or relationship between the measure under appraisal and the state interest or policy sought to be promoted or realized. Each and every subparagraph enjoys a certain amount of autonomy, in this respect they serve a different purpose and as such should be interpreted in their ordinary meaning in accordance with the general rules of interpretation. Article XX (a) On the offset, the issue of public morals and international trade proves to be a problematic. Public morals differ between states, the relativity is bound to conflict with norms and rules set out in international practice. Article XX(a) as an exemption is designed to allow a nation to participate in the international trade while preserving certain aspects of its sovereignty over its domestic, political and legal order.[41]It is a provision that maintains self-preservation. The issue of public morals invites a sense of ambiguity, broadening its scope of application, it becomes important to underline a basis for an interpretation of its meaning within the context of international trade. The problem is there have been few decisions and scholarly articles touching on this exception.[42] In US-Gambling (2005) the stated that the term public morals denotes standards of right and wrong conduct maintained by or on behalf of a community or nation, the content of the concept of public morals can vary from member to member, depending upon a range of factors, including prevailing social, cultural ,ethical and religious values and members should be given some scope to define and apply for themselves the concept of public morals in their respective territories, according to their own systems and scales of values. This definition was adopted by the panel in China-Publications and Audio-visual products (2010). The panel then set the ground work for a GATT inconsistent measure to be justified under Article XX(a) it stated the measure must be designed to protect public morals and necessary to fulfil the that policy objective.[43] The lack of jurisprudence with this article is bound to create problems in the future. It is clear that it is impossible to set a baseline for what is morally right or wrong. This exception is solely aimed at maintaining the sovereign integrity of a member. Article XX (b) The scope of paragraph XX (b) is not definitive however it is clear that sanitary and phytosanitary measures were the principal measures that occupied the minds of the drafters[44]This is clear in the Sanitary and Phytosanitary Measures (the Sps Agreement) where the preamble states; Preamble to the Sps Agreement that refers to Article xx (b): Desiring therefore to elaborate rules for the application of the provisions of GATT 1994 which relate to the use of sanitary or phytosanitary measures, in particular the provisions of Article xx(b) This article concerns measures that are necessary to protect human, animal or plant life or health. Jurisprudence on the application of Article XX (b) relies on three requirements: (i) Whether the policy reflected in the measure falls within the range of policies designed to achieve the objective of protecting human à ¢Ã¢â€š ¬Ã‚ ¦ life or health. In other words, whether the measure is one designed to achieve that health policy objective; (ii) whether the measure is necessary to achieve said objective; and (iii) whether the measure is applied in a manner consistent with the chapeau of Article XX.[45] The requirement is relatively straightforward and hasnt created problems with interpretation. The adjudicators must determine if a risk exists and analyse the degree of risk caused by the product[46]. This risk has to have a direct relation to the measures taken, to do this, the Appellate Bodies have examined, the design and structure of the measure and it has become apparent that the measures undertaken to achieve this objective are broad. In Japan-Alcoholic Beverages II the Appellate Body stated: the aim of a measure may not be easily ascertained, nevertheless, its protective application can most often be discerned from the design, the architecture and the revealing structure of a measure[47] In Brazil-Retreaded Tyres (2007), Brazil submitted a claim that the accumulation of waste tyres creates a perfect breeding ground for disease carrying mosquitoes which posed a substantial risk through the transmitting of diseases such as dengue and yellow fever. The accumulation of waste tyres also created the risk of tyre fires and toxic leaching. Brazil argued also argued that the risk posed to animals was high due to mosquito-borne diseases and numerous toxic chemicals and heavy metals contained in the pyrolytic oil released from tyre flames.[48] The panel accepted Brazils argument and concluded that, Brazils Policy of reducing exposure to the risks to human, animal or plant life or health arising from the accumulation of waste tyres falls within the range of policies covered by Article XX (b).[49] The correlation between a measure and a policy can be adduced from the analysis of the objective. Measures that have no subjective relations are often required to fulfil the policy objective on health policies. The scope is broad and can easily invite protective measures under the guise or Article XX (b). Secondly For a measure to fall under the ambit of Article XX (b), has to meet the necessity requirement and meet the requirements of the chapeau.[50] In addition the description of the necessity requirement with respect to the chapeau.[51]However in order understand the necessity requirement within the meaning of Article XX(b) the Appellate body in Brazil-Retreaded[52] tyres stated that, a panel must consider the importance of the interests or values at stake, the extent of the contribution to the achievement of the measures objective and its trade restrictiveness. In this balancing approach, a balance of probabilities taking into account all relevant factors assists the adjudicator reach an appropriate decision. However other texts argue that this is not a balancing or proportionality test, rather it is a reasonable test, whether a reasonable regulator could have adopted the measure it did[53]. This approach is narrow and takes on a defensive approach, I do not agree with this view as it limits the rights of a member to achieve a policy objective. In this situation protection of national interests specifically relating to health policies. The more vital or important the common interests or values pursued, the easier it would be to acc

Caste System In India Essay -- essays research papers

The caste system, or Varna, of India, came about when the Aryan speaking Nomadic groups came to India about 1500B.C.. The Aryan priests divided society into a caste system with four parts. This system determined Indian occupations. The priests and teachers were the highest caste. The second in rank were rulers and warriors, with merchants and traders third in rank. Last were the workers and peasants who were born to be servants to the other three castes. People could not change their caste. They had to marry and socialize with people from their own caste. This is very different from the class system of America.   Ã‚  Ã‚  Ã‚  Ã‚  In the United States class is determined by how much wealth you have, not usually by your occupation. The three classes are the upper class, middle class, and lower class. Most Americans fall into middle class or lower class with the very wealthiest people in the upper class. There is one section of the upper class, which is considered old money. These are families that have inherited fortunes from their relatives and are a small part of what is called high society. In American society you are not forced into one class. You can work in any job to make your fortune and are not stopped from performing any job that you would like to do just because you were born into lower or middle class. Our system is also not based on religion like the Indian caste system is.   Ã‚  Ã‚  Ã‚  Ã‚  Another group in India’s caste system are the ...

Family Portrayal in the Film The Castle Essay -- essays research paper

The Castle is a movie primarily about a family sticking together and their fight for the right to live in their own home. The Castle’s portrayal of family is both positive and negative. The Castle depicts many positive images of the family throughout the movie. From the very start of the film, it is easy to see that the Kerrigans are a very close knit family. They always eat their dinner together, with the TV turned ‘down’, and talk about their day. Around the dinner table the family shows support for each other, and recognizes anything a family member may have achieved, like when Darryl beams with pride telling the family about how Dale dug a hole. The family also sets aside time after dinner for the family to watch TV together. Although only small things, these simple actions portray a positive image of the family. Another aspect of the film that depicts a positive image of family is the family’s support for Wayne. Although Wayne is serving an eight year prison sentence for armed robbery, Darryl, Sal, Tracey, Steve and Dale are still proud and supportive of him. Dale regularl...

Eurocentrism Essay

Eurocentrism can be defined as the idea that the Roman and Greek cultures gave rise to the modern explosion of ideas and learning. Within this idea is contained the notion that the origins of Greek culture lie strictly within the borders of what is currently considered Western Europe, making the ancestors of Western Europeans responsible for all the progress of the modern world (Dussel, 465). This idea is considered by modern historians to be false and based not on factual accounts but rather on the distortion of history by colonizers (Blaut, 10). This distortion of history is based on the Inside-Outside or Center-Periphery models of civilization which pinpoint an area of the world as the peak of civilization, and the areas outside of it as barbaric. This model depicts Greater Europe as the insider area which contained the civilized culture, and it posits a gradual diffusion of that culture to the other parts of the world surrounding it. Yet this model presents an erroneous view of the world’s process of civilization. The ideas that are based on the models above tend to identify Europe on the one hand as being civilized and making strides in scientific and technological advancement. On the other hand, this view places the world outside of Europe in a position of stagnancy, with knowledge remaining static unless ideas were learned from Europe. This idea also gives rise to an ethnocentric idea of â€Å"European† intellectualism as being the reason for the centralization of knowledge within that area. It also gives rise to the antipathetic idea of non-West European culture as necessarily consisting of inferior ideas which might be described as â€Å"savage, atavistic, uncivilized [and] evil† (Blaut, 16). The truth is very different, however, as the Greek and Roman cultures that contributed to the â€Å"civilization† of Europe must give attribution for its ideas to a wide array of cultural influences whose origins span areas as far as Africa and Asia (Dussel, 465-468). According to Dussel, Europe cannot claim Greece as a part of its earliest origins. Furthermore, during the height of Greek cultural dominance, awareness existed in the Greek world of the progressive nature of the Egyptian (African) and Turkish (Asian) civilizations (Dussel, 465; Yurco, 1). Yet, while this Greek center civilization was aware of the existence of civilized Africans and Asians, their knowledge of what is now Modern Europe was minimal and the area considered to be populated by â€Å"the uncivilized, the non-political and the non-human† (465). The idea that Greece bequeathed civilization to Rome and to Europe is false. Rather, a dichotomy existed between the Latin (West) and Greek (East) cultures, and this configuration did not include a strict conception of Europe. The Greek culture was dominated in classical times as much by the Arab (Muslim) culture as it was by the Byzantine (Christian) culture. Therefore, the Aristotelian basis of civilization was historically strongly connected to the Middle Eastern and even Asian (Turk) civilizations (466). What actually occurred to lead to the development of civilization in Europe is based on an interplay of cultures from all over the continents of Africa and Eurasia. Such thinkers as Thomas Aquinas and Albertus Magnus relied heavily on the ideas that came from the Turkish-derived Aristotelian ideas (Dussel, 466). The ideas generated by Aristotle were actually studied in what is now modern-day Iraq (Baghdad) before Aquinas became exposed to them. Indeed, Aquinas’ exposure came only after the Muslims in Spain translated these works into the Latin vernacular. The arrival of these works in Paris during the late 1100s B. C. marks the initial period in which differentiation occurs between Europe and Africa/Asia (466). The Crusades, which followed during this era, therefore may be seen as the first attempt made by Europe to become dominant in the newly differentiated territories of Africa and the East—and these campaigns might be considered failures (466). Eurocentric ideas concerning the Old World can therefore be seen to be a myth based on the colonially driven histories that have been passed down in the recent past. The failure of the Crusades might be seen as a way in which Europe itself was kept out of the civilization encompassed by the Turkish and Muslim regions, which spread their dominance from Morocco to India and even to the Philippine island of Mindanao. Even the Roman Empire, which dominated Europe for centuries, never penetrated to become the center of civilization in the African and Asian worlds (Dussel, 466). Before this time, the only empire that came close to being dominant and of Eurasian origin are the Hellenistic empires. Yet these empires are not one and the same as Europe, and never gained as large a dominance as the Muslims had after them (467). In contrast to the Eurocentric model of civilization is the strong Turkish (Muslim) civilization—historically represented by the term â€Å"Asia† (Blaut, 20). This area, which later became known as the Ottoman Empire, was dominant within its region. It even began conquering territory into south-eastern Europe, and this idea falsifies the theory of all civilization issuing from Europe. Even in the sixteenth to eighteenth centuries, European presence in the African and Asian continents was merely a matter of trade rather than dominance. The idea of a Eurocentric world actually found root only during the nineteenth century when colonization occurred in areas of the Old World (India, Asia, African and China). During this period, the multifaceted Greek culture was adopted and re-classified as European. The Greek culture is then identified with that of the Romans and then the two are placed at the center of the world’s historical civilization. It is at this point that Europe is able to emerge as the world’s intellectual benefactor. However, the fact that at this point no united â€Å"world history† existed and their location made it impossible for them to be central in providing for the surrounding territories an impetus toward civilization (468). Colonization in the nineteenth century can be seen as the chief mechanism through which Eurocentrism has been able to become dominant in global thinking. In order to maintain the colonial thrust, European colonizers were prompted to create ideologies that support the dominance that European countries had gained in their respective colonies. Religious, social, and scientific ideas that were spawned during that time gave rise to the Eurocentric ideas that are extant even in modernity. According to Blaut, â€Å"A [Christian] missionary might have great love and respect for the people among whom he or she worked, but could not be expected to believe that the culture and mind of these non-Christians was on par with that of Christian Europeans† (24). The social and legal theories being fashioned at the time were created by those who were in charge of making the policies that the theories should support. Therefore, intellectual history became biased in its outlook regarding the comparative worth of the cultures that stand alongside the European culture. However, in the disciplines of economics and anthropology ideas and truths were discovered which did not fit well with the tendency toward Eurocentrism. Such ideas as equilibrium and stasis developed in Keynesian economics. In geography, stasis was found to be a natural occurrence in regionalism. Theories of equilibrium and stability were embodied in such anthropological ideas as functionalism, while cultural relativism â€Å"declared in essence that each culture has intrinsic worth† (Blaut, 27). However, within the discipline of Anthropology, political motives can be found for publicizing the fact of cultural relativism, though tempered with a Eurocentric overtone. The notion of the intrinsic worth of the culture would have the effect of discouraging unrest, while the Eurocentric overtones would have the complementary effect of evoking gratitude in the heart of the colonists toward the colonizers (27). Overall, however, colonial indoctrination has been characterized by a teleological view of the West’s advancement, which is responsible for the benefits accorded Latin American, Asian, and African nations. Many other cultures outside of Europe experienced great progress and civilization throughout history. Yet, the result of inattention to the civilization status of Europe and other regions at other time periods has given rise to contemporary confusion surrounding these cultures. One such problem can be found in the misunderstood racial composition of Egyptians. In fact, the analysis of the racial composition of the Egyptian royalty gives credence to the idea that multiculturalism existed in the Egyptian civilizations of the past. Peoples from lands traditionally connected with Europe became traders and settlers in Egypt—and this underscores the centrality of this civilization during the ancient times. Such centrality naturally rebuts the idea behind Eurocentrism. However, the fact that interbreeding led to the Europeanized features of many of the Egyptian drawings and mummies has helped fuel the myth that European cultures played all the dominant roles in the civilizations of the past (Yurco, 2). Eurocentrism involves the idea that civilization was generated from a European center and somehow diffused to the other areas of the world. This idea finds its strength in the recent dominance that Europeans have had in the several continents of the world. Colonialism needed justification, and the method by which this was done involved the creation of ideas and systems that placed Europeans at the forefront of history. It involved the Europeanization of the Greek cultures and the oversimplification of the factors leading up to the current socio-political state of the world. Furthermore, the fact that world history has been written down and propagated mainly during the period European dominance has facilitated the Eurocentrism that can now be seen in the historical understanding of the world.