Animal Farm, Snowball Essay

He led a revolution, became a scapegoat, and was exiled from his home lane. This person was Leon Trotsky, a Russian Marxist revolutionary. In the novel Animal Farm, Trotsky came out through a pig named Snowball. Throughout the novel, Trotsky is brought up more and more through snowball. Leon Trotsky is represented through Snowball by the many life events they had in common. Snowball was chased away from the farm and became an exile by Napoleons trained dogs. In Trotsky’s life, he too became an exile from his home. He sent away and banned from returning. In addition, Napoleon claimed that all the ideas that had come from Snowball were actually all his own creations. â€Å"One of them all but closed his jaws on Snowballs tail, but Snowball whisked it free just in time. Then he put on an extra spurt†¦ slipped through a hole†¦ and was seen no more†(68). This is a quote from the scene where Snowball becomes banned from the farm. After Snowball takes charge over the farm for some time, his comrade, Napoleon comes to despise him. Snowball and Napoleon never agree on anything. Napoleon did not want the animals to side with Snowball, he always argued against Snowballs ideas and was never friendly towards him. What also went on was Napoleon, showing his hatred for Snowball, examined the layouts Snowball had made for the windmill and urinated over the plans. Napoleon showed his disgust by urinating on something that was important to Snowball. â€Å"†¦looked closely at every detail of the plans†¦ then suddenly he [Napoleon] lifted his leg, urinated over the plans, and walked away†¦Ã¢â‚¬ (65). Obviously the action that Napoleon just committed shows hatred for Snowball. After Snowball was gone from the farm, he became a scapegoat for Napoleon. It was suddenly Snowballs fault that the windmill had collapsed. Napoleon needed a reason for it to have fallen, and who better to blame than Snowball, that way the animals would want revenge by building a stronger one; exactly what Napoleon wanted. In addition, it was announced that Snowball had been sneaking onto the farm to steal corn, break eggs and what not. Whatever bad thing that occurred was automatically put on Snowball by Napoleon. â€Å"Whenever anything went wrong it became usual to attribute it to Snowball†(88). With hardly ever any proof, Snowball was always the scapegoat. In conclusion, it is obvious how Snowball went through the events of Leon Trotsky’s life. From having his ideas stolen to becoming a scapegoat, he led the life of a famous revolutionary leader, though it wasn’t a very good life, he made a big impact on all of his comrades and will never be forgotten.

Discuss the causes of World War I Essay

The most prominent factors which led to World War 1 were nationalism, militarism, imperialism, the Balkan and Morocco crises, and the alliance system. As luck would have it, these factors either started in response to, or because of each other. The alliance system was one of the last factors to emerge before the war. The alliance system was a main cause of World War 1; it came into play because of a few factors, and did not cause the war alone. Nationalism, the love and support of one’s country, has always existed. During this time, nonetheless, it took part in the culmination of one of the most famous wars in history. As so much pride was devoted to countries, it made the potential for peace between past rivals less likely. It also meant that most nations, particularly the great powers, would rather fight a war than back down from a rival’s diplomacy. Since no country felt easy about fighting in a war alone, nationalism was a contributing factor to the alliance system. Allies provided a lot of ease with the growing militaries in almost every country. Militarism, a policy of aggressive military preparedness, in this period of time gave all countries great reason to feel the heavy weight of a looming war. Great Britain had a naval policy to have the largest military force hands down. That, along with the predominate feeling of war, provided countries with a strong reason to create an incredibly strong military force. This led to an arms race, which made the impending war seem certain. The military planning in some countries also caused an increased fear of war. Military machines were being developed; each country was appointing a staff of experts. The greatest problem with this was the fear that the expert would precipitate war under a looming timetable. The alliance system was born from these two factors. If two or more countries are allied with each other they have a better chance of defeating their common enemy if war was declared. They also have a higher likelihood of winning if they have alliances providing support. Imperialism is defined as the control of people by another politically, economic exploitation, or the imposition of culture on another group. This not only played a large part in the creation of the alliance system, but it  also created enemies for many countries, which were grounds for war. For example, Austria wanted to dominate the Balkans in order to check for propaganda coming from Serbia. Germany supported Austria in its Balkan policy because it wanted to exploit the rich resources of Asia Minor, and had to have a peaceful route through the Balkans to get there. In this way, it led to the alliance of Germany and Austria when war was in the near future. Imperialism led countries to have conflicting national interests as well, which also led to war. Each country thought they were right and wanted to convert other cultures to be more like their own. With nationalism, militarism, and imperialism all showing a large presence at the same period, a solid ground was formed for the alliance system to build itself on. The Dual Alliance between Germany and Austria was formed, the Triple Alliance between Austria-Hungary, Germany, and Italy was created, and the Triple Entente was created between France, Russia, and Great Britain. Although the Triple Entente was not an official alliance, they all maintained a very close understanding, and were viewed by many as a threat. The crises in Morocco and the Balkans had a devastating result because it was one right after the other. The 3rd Balkan crisis led to what most would say was the immediate cause of the war. It was what caused the most damage, possibly only because it was followed soon after the first two. On June 28, 1914, the Black Hand, a Bosnian revolutionary, assassinated the heir to the Austrian throne, Archduke Francis Ferdinand. In retaliation, Austria decided to end the South Slav separatism, and issued an ultimatum. Austrian officials must be allowed to collaborate in the investigation and punishment of the assassinators. Austria, with the support of Germany, then declared war against the Serbs, since they had refused the ultimatum. Then, on August 1, 1914, Germany demanded that Russia’s military mobilization cease, and when Russia refused, Germany declared war. Russia then declared war on France, convinced that it would enter anyway. Germany was devastated when Great Britain entered the war. As one country declared war on another all alliances were brought into the war, and the First World War soon took place, thus, the alliance system  holds the greatest responsibility for the breakout of a world war. However, the alliance system might have never occurred had it not been for nationalism, militarism, and imperialism. Furthermore, the Morocco and Balkan crises did not directly cause the war, but they were used as justification for the war to begin. That’s why, many factors contributed to the formation of the alliance system, which led to tension between enemy countries, and the third Balkan crisis paved the way for the Great War to begin. Western Civilization: Since 1500, Chapters 13-29, Vol. 2 : Jackson J. Spielvogel (Paperback)Wikipedia

Exploring Dramatic Arts Essay Example | Topics and Well Written Essays - 750 words

Exploring Dramatic Arts - Essay Example Dr Vivian is stern at most times with her students. For example, when one of her students ask for a deadline extension of an essay due to the demise of her grandmother, Dr Vivian responded in a very unsympathetic way: â€Å"Do what you will, but the paper is due when it is due† (Edson, â€Å"Think Tank: About Life, Death and the Pause That Separates Them†). Little did she realize that her unconforming attitude would later cause her own distress. Another character is Susie Monahan, a registered nurse who took care of Dr Vivian during her last moments. Her role in the play is just as important as the other major characters in a sense that she subtly revealed the main message of the play, that is, to realize that intellect is just part of being a human, and that there are other things that should not be discounted: kindness, love, and care. Other character like Jason, who was a former student of Dr Vivian, can be labelled as a non-biological offspring of Dr Vivien. As her former student, Jason absorbed so much of the resounding principles of Dr Vivian for intellect and education. Jason turns out to be a significant element in the play that induces Dr Vivian to recognize her mistakes as an individual and as a teacher. Jason sees Dr Vivian as nothing but a sick body when he yelled to Susie, â€Å"She's Research! â€Å" (Cohen, â€Å"Margaret Edison’s Wit: An Audience Guide†). Jason made Dr Vivian realize that being human needs not just wit or knowledge but also things that are simple; real. The play Wit written by Margaret Edson affords me a whole new understanding of life. It introduces me to what is more important: things that are more important than intellect, fame or money. After reading the play, I realized that every person who walks this world should preclude himself or herself from taking a step outside of reality. Dr Vivian escaped from reality when she entirely bent all her focus to literature and on becoming the best scholar in her field; and started to stay away from normalcy. She lost the common human trait of sympathy and compassion. She developed the thought that every person can live a single existence and that there is no such thing as a multi-faceted life. Later she understood that, intellect or wit is just a portion of one’s being. It should not override other essential things that make a human being a human being. While it is also beneficial to be knowledgeable about your chosen field, it should not come at the expense of your existential truth. Personally, I would say Dr Vivian, the lead character of the play Wit, and I are very much alike. I always believe in the gain you can get out of sharpening your knowledge on a particular field of knowledge. Like Dr Vivian, I relatively developed a personality that is averse to living a life that embraces minimalism. I would say that one can be more useful if he or she knows a lot of things; and even when it comes to the most sensitive and confro nting issues of life, like death, superior intellect and deep grasp of the philosophical notions of life will simply let death pass by without causing any distress or anxiety. Nevertheless, Dr Vivian and I also have characteristics that, I would say, are not similar. Dr Bearing, because of her concentration to knowledge and intellect, she failed to recognize other aspects of her being. She only values her brain, which for her, is her most important organ. She displays unfeeling and stubborn behaviour to the people surrounding her. I have not gone this far. While Dr Vivian and I are very mu

Dental Health Essay Example | Topics and Well Written Essays - 1500 words

Dental Health - Essay Example In a prison there is lot of limitations for such things. "In the past, the provision of dental services in prisons has been of variable quality. For this reason, the Strategy for Modernising Dental Services for Prisoners in England was published in 2003. Every Prison was required, in consultation with the local primary care trust, to develop a Dental Action Plan for improving their dental service. 4.75 million over three years was allocated towards the implementation of these plans." (Harvey, S. et al. 2005). The authorities must provide dental check up for at least 200 to 250 prisoners per week. The dental service needs to be universal based on clinical needs and must provide all sorts of services to the patients, but inside the prisons it has certain limitations for providing all sorts of dental services. In case of trauma to the face or cheeks the person may present with severe bleeding and the prisoner should be taken to the emergency department, but this must be in line with the local health care provisions and according to the security policies in the prison. In acute dental pain is advisable to take the person to a dentist within 24 hours or at least to an appropriate practitioner within 24 hours. The prisoner needs routine follow up with in six weeks in all most every case and this is also restricted by certain prison policies. The incidence of untreated dental disease in pris... THE CHALLENGES The incidence of untreated dental disease in prisoners is much high when compared with that of the general population, so the dental health needs of prisoners is much high. Since the prisoners neglect their oral health for such a very long time the problem may in the most aggravated form. "While dental care is a critical component of overall quality health care, many prisoners enter correctional facilities in the United States with little history of good dental hygiene and even less history of access to dentists for routine dental examinations. As a result, the incarceration experience presents opportunities for inmates to receive quality dental care, often for the first time in their lives. Dental care delivered by correctional dentists is complicated, however, by the array of serious dental conditions and difficult to treat dental problems in clinical settings". (Vaughan, M.S. et al. 2006) The poor nutritional status may also aggravate the problem. Smoking must be prevented in high risk cases. "The higher proportion of drug users in prison compared to general population can also explain the greater need for dental treatment. Methadone users in particular have a high level of oral disease". (Rotary. et al. 2007)Another important problem is that the dental care sessions may be shorted by security problems. Other important issues in dental health care include the lack of space in prisons, insufficient staff for treatment, lack of funding for health promotion and outdated facilities for health care in prisons. A report published in Sage Journal describes that there is variation in dental care provided to the prisoners. "Forty-five

Analyze two pictures Essay Example | Topics and Well Written Essays - 750 words

Analyze two pictures - Essay Example In this image, Nauman uses the literal depicting of linguistic performativity method in order to achieve layers of potential meaning to the viewer. Notions of identity and body, the role played by language, artistic process and the phenomena of spatial awareness and participation of the viewer can be said to be the most recurring themes in the Nauman’s artwork. Comparing the time this photograph was taken and when the â€Å"Self Portrait† by Albrecht Durer, 1500 was painted, it can be seen as a daring art since it is colored and digital, and that time they were considered to be artless and perfunctory in nature. It brings out the notion that the artist of the image was engaging insolently with the limits of discourse and art practice (Danto 149). In comparison with the oil painting, the photography can be identified to represent non-art functions even though it denies the autonomy and authorship of art. With the image acknowledging the representation of language through letters in art and manipulating power of the language, Nauman brings the notion that language in photography can function as a tool for guiding people in the society. Of course, language, images are inseparable from language as representation and can be invaluable source material in any artist’s future works that the pivot of the language instability by use of documentation through the camera. Therefore, this kind of Nouman’s art, transformed the world of art by bringing an installation or digital art. In the Eating my words photography, the tacitly mute Nauman derides the notion that, the image depicts self-expression in the context of art as well as to the public or viewer (Morgan 152). In the photography, language and the way it relates to the visual content of the photograph are seen as the central actors directed cleverly by Nauman. Following an innovative, rigorous approach, Nauman explores vario us means of expression and is considered

Literature review Essay Example | Topics and Well Written Essays - 2000 words - 3

Literature review - Essay Example al 2012). For an average individual, buying services and products is a routine and normal behaviour. For compulsive consumers, incapability to control an overwhelming force defines their buying behaviour. It also leads to substantial and always severe results. A compulsive consumer does not derive his or her utility from a service or product but from psychology during purchase power. For the last twenty years, a strong series of investigation in consumer activities has been in discussion of compulsive consumption phenomenon. This was to show it negative results both in the society and to an individual (O’Guinn et. al 2011). Compulsive consumers accrue unmanageable and vast debt amounts which create emotional and economic problems for them. Incapability to settle off debts then turns into a creditor’s problem. Therefore, the importance of devising and understanding intervention methods to manage and control this activity is vital. Other discussion in this paper has made a focus on marketing strategies and tactics’ role as a risky factor in promotion of compulsive consumption. Consequently, it focuses on marketing role in fostering and promoting this problem activity. This paper therefore, reassesses the literature on the problem behaviour as well as summing up the outcomes in three areas: why do consumers behave in this manner, what are the predictors of compulsive consumers and relations with marketing strategies? The marketing ethics as a risky factor in compulsive consumptions is in the discussion. Compulsive consumption The concept of compulsive consumption in literature has a definition of repetitive, chronic purchasing behaviour which takes place as a reaction to negative feelings or events (O’Guinn & Faber 1989). As individuals purchase compulsively, they buy excess product quantities that they cannot afford and do not require (Hoyer & Maclnnis 2007). This is regarded as a reaction to resolve negative feelings, inner deficienci es or unlikeable life experiences (Faber & O’Guinn 1992). This feeling pushes a consumer to buy goods to help clear negative feelings like frustration and stress (Scherhorn 1990). A compulsive consumer is therefore, motivated to buy goods to clear the negative feelings via alterations in self esteem or arousal level and consequently obtain utility from buying process (Hassay & Smith 1996). To be simple, compulsive consumers act on uncontrollable, powerful urges to purchase (Yurchisin & Johnson 2004) Why do individuals buy compulsively? Recent research has concentrated majorly on identification of personality character associated to compulsive consumption (Shoham & Brencic 2003). For instance, (Valence& Fortier, 1988) say that compulsive consumers have a low self-esteem which make one fantasize, put value on material and high depression levels obsession and anxiety ( Koran et. al 2006) along disappointment, frustration and stress. The fantasy in compulsive consumption has been a point of concentration for researcher. Through fantasy one is able to move away from pessimistic feelings and accept oneself in the society (Faber & O’Guinn 1989). It also allows for rehearsal of expected positive results and a way to avoid concentrating on negative issues. Moreover, when one’ Literature Review Essay Example | Topics and Well Written Essays - 8250 words Literature Review - Essay Example To develop an efficient labelling scheme that can handle an ordered tree-structured data model, various scholars have focused on the aim of developing a labelling scheme that is efficient and effective in handling both static and dynamic XML documents and these approaches are discussed below. In the introductory chapter of this thesis, there were specific objectives which defined the motivation of this study, and its goals. The first area of literature relevant to this goal is an overview of labelling schemes. The second part of the literature review presents and discusses other labelling schemes that have commonly been used with XML documents. The first theme is different from the second because in the first, only the overall approach to the functionality of the schemes are presented but in the second, there will be more detail into the schemes by reviewing the strengths, weaknesses and limitations with these other labelling schemes. By so doing, it exposes the research challenges. Lastly, the literature review will identify the weaknesses and limitations of other labelling schemes to propose alternative ideas for new scheme which helps to address the identified weaknesses and limitations. Section 3.2 of the chapter provides an overview of the labelling schemes, while Section 3.3 presents common labelling schemes used to XML data along with their strengths and weaknesses, such as prefix-based schemes (Section 3.3.1), interval-based schemes (Section 3.3.2), multiplication-based schemes (Section 3.3.3) and vector-based schemes (Section 3.3.4). Section 3.4 discusses the scheme’s characteristics to be seen in any ideal scheme. Section 3.5 summarises the literature review and Section 3.6 concludes the chapter. There are four major schemes that are overviewed in this section. These are prefix-based schemes,

Assignment Example | Topics and Well Written Essays - 500 words - 25

Assignment Example Significance of Human Resource Management FunctionIn the health sector, human resource management function cannot be underestimated. The human resources seek to enhance the patient’s satisfaction and the quality of services. Quality in health care is defined in two ways; sociocultural quality and technical quality. Technical quality entails the impact the available health services can have on the overall health condition of the population. Sociocultural quality refers to the level services’ acceptability in order to satisfy the patient’s expectations. The above-mentioned functions are performed by the human resource, and they cannot be run smoothly without their intervention. Formulation of a better strategy to manage the organization functions is one of my interests in the field of human resources. The health sector is faced with many problems that require the assistance of a human resource manager. Some of these issues include workforce training issues, and hea lth care workforce composition and distribution. My interest will be to solve these issues in the position of a human resource. The role I can perform well in human resources is the operational and employee advocacy role. Employees face a number of problems that require the intervention of the human resource. This is because I am capable of taking into consideration the employee’s concerns and issues effectively. A role that can be a challenge to me is the administrative role. It will be a challenge since I require a more involving role.

2page and a long essay Example | Topics and Well Written Essays - 1000 words

2page and a long - Essay Example This saw many tensions and it were at this time where activist were trying to preach against discrimination. Black Americans were moving to other towns to look for jobs and employment. It was at this stage that slavery was made illegal and amenities were scarce for the black Americans. The most common jobs for the blacks was cotton picking, and they were no school ready to accept the blacks as they were still viewed as slaves who had nothing good to offer it as this point that the white settlers would sign a pact not to sell any land to the blacks though the court had already abolished the discrimination law. It is at this time that landowners who were mostly the white would underpay and would also beat the black Americans and even kill them if they were found to have broken the law. Rampant cases of black Americans by their employers were not seen as a strange thing, and it is at this of this that activists and human rights were very active. Discrimination among the blacks brought about rebellion and theft and shackles neighborhood came up. This was after the whites refused to sell the land the blacks would go on to live in their zones. The whites viewed the blacks a parasites and illiterates who would not survive on their own. Rural to urban migration became rampant, and this was caused by the need to look for better opportunities agrarian revolution had taken place and blacks were tired of the cotton picking jobs that were could not match their expenses. Its importance to the American history is the steps they went through all those fighting and discrimination has made America stronger as a country the fighting of racism the sprouting of estates viewed as a no for the whites proved that hatred and racism was real. It shows the way why America should foster love and fight racism as this would strengthen them and not divide them. Institutions are also built to promote love and also sportsmanship. It is evident

Counselling in workplace Essay Example | Topics and Well Written Essays - 5000 words - 1

Counselling in workplace - Essay Example More important, it will develop an understanding of how this affects both employees and the corporation so the correct types of designs can be used for creating the right work space. Traditionally, workers are brought into a career field through either a formal education or by gaining a specific amount of experience. It is expected that once one is placed in a given position, they use skills and training which has already been developed to create the right approach. However, employees also need to accommodate to individual preferences of businesses while acquiring skills which fit to different job descriptions and expectations in the work force. Even though there are learning processes which are required, most businesses don’t focus on providing education and skill sets for employees to grow within a corporation, causing difficulties in growth for employees and the given corporation. There is limited information that is given to those that are working within a given environment and which require specific types of information. The inability to understand learning in the work environment as well as its effectiveness with employees is some of the limitations involved. This is combined with problems that arise in understanding how to incorporate various training methodologies for effective outcomes. The work environment culture, expectations with job performance and the outcomes which occur are often not regarded as one which requires education and training. This overlooked option for businesses then limits the ability to reach different options for change and growth within a company. The purpose of this study will be to examine the effectiveness of learning in the workplace as well as whether it makes an impact over the way in which a business functions. There will also be an examination of the types of learning which can be

Social interaction Essay Example for Free

Social interaction Essay Stereotyping may lead to prejudice and discrimination. Prejudice is to pre-judge a person or a group of people in a certain way before you get to know the facts. For example in the case of Ms Brown she may feel prejudice towards the people of the new neighbourhood. She does not know them and may judge them all in one way. Categorise all as one instead of seeing individuals. Discrimination is to act on that judgement. In Ms Browns case she may feel prejudice to the natives of the new neighbourhood. They have different life styles which could cause slight conflict between them. What Ms Brown believes to be the right way of life, the people in the neighbourhood may disagree. Prejudice could occur. In order for Ms Brown to discriminate against her new neighbours she must act on that prejudice. Ms Brown may experience frustration when moving house. This could be due to several reasons. Although been a lone parent was Ms Browns choice it may make life difficult at this moment in time as she has the move to do alone. Whilst frustration and aggression are related, frustration does not always lead to aggression. Gross R et al (2000:67) Aggression can be reinforced where as frustration is a natural emotion. Aggressive behaviour can be aroused by other aspects then frustration. How could this effect Ms Browns situation. Elliott in 1977 conducted a study with a class room of children. The aim was to show the children how it felt to be discriminated against. Elliott told the children that pupils with blue eyes were inferior. Within days the experiment showed the children with blue eyes had become withdrawn and school work slipped, whereas the children with brown eyes became more and more aggressive towards blue eyed children. This experiment shows how easy it can be to discriminate against others and how aggression can occur. Ms Brown may have been raised in a racist family; her parents could have reinforced the prejudice towards black people. Social learning theory suggests that behaviour is learned. People are not born aggressive; they adapt aggression through direct experience or by observing others. In reference to M Cardwell et al Psychology for A2 Level Bandura conducted an experiment also involving children. Using a blow up doll, some of the children were exposed to adults behaving aggressive towards the doll. The bobo doll experiment showed that children copied the behaviour of adults. Those who witnessed aggressive behaviour toward the doll carried out similar aggressive acts. Whereas the children who were not exposed to the violence on the doll were not aggressive towards it. This experiment suggests that, people will copy behaviour. Is aggression learned? The social learning theory is contradicted by the Relative Deprivation Theory. This can be explained as, what we believe to be the standard we should receive and the standard we actually get. Moving house is hard work and stressful, things do not always go as planned. Ms Brown may become frustrated with the situation. An experiment conducted by Sherif in 1961, involved a group of eleven and twelve year olds. The children were divided into two groups and housed separately. As a result they became close friends and found a sense of identity within that group. The two groups were brought back together and after several competitions between them they acted very negatively towards each other. Each group felt as though they deserved to win the competitions more than the others. If people feel deprived of something to which they feel entitled, they become frustrated and perhaps aggressive. the Ku Klux Klan was founded in 1866; just after the American civil war it attracted mainly poor whites who believed that their livelihood was threatened by the newly freed black slaves. Gross R et al (2000:25) In the case of the ku Klux klan it eventually lead to murdering black people for no reason other than the feeling that maybe white people were been deprived of something because of black people. In 1992, a riot broke out in Los Angeles; it claimed more the 50 lives. The reason behind the riots was the acquittal by an all white jury of four police men who had been accused of badly beating a black motorist. If the police men had received punishment for their actions then the black society would not have felt deprived of justice, then the riots would not have occurred. A sense of perceived relative deprivation can also come about as a result of improvement in the recourses and opportunities made available to a group.

The Design Of Toughened Glass Columns Physical Education Essay

The Design Of Toughened Glass Columns Physical Education Essay Glass has clinched the attention of engineers and architects in recent years despite its brittle nature. As well as its aesthetic allure, the increasing knowledge of this material allows structural boundaries to be pushed and endless possibilities to arise. Glass facades, beams, and stairs are some of the structures that have been explored with. However, the prospect of using a glass column as a structural component, as opposed to an ornamental role, is of increasing interest. Various structural glass types are available and have proven to be sufficient, but toughened glass reigns as the strongest type, yet its capability to spontaneously shatter can also prove to be a liability. What is Glass? Glass is an inorganic, non-crystalline, solid, transparent material, renowned for its brittleness. Its molecular structure attributes to its brittleness, making it weak in tension (Chen; Lui, Ch.29) and without an ability to redistribute load or absorb impact energy. Potentially, glass is very strong, even exceeding the strength of structural steel. However, due to glass having fairly low fracture toughness, this is only achievable when glass contains no defects, as freshly drawn fibre might be (Rice; Dutton, 33). Glass does not yield, instead it fractures and its failure is stochastic, meaning that prediction for failure is based upon risk or statistics (ISE, 11). Glass does not adhere rigorously to stoichiometry as crystalline materials do, due to the ability to incrementally alter the properties of glass continuously by adding components/substances to modify its properties. For instance, adding potassium oxide to silica will change the glass properties (Clare, Ch.23). Although described as a solid, glass is rather a subset of the solid state. It is essentially an elastic solid below its transformation region, i.e. the glass transition state, and a liquid above it, glass has the attributes of a liquid apart from the ability to flow (Clare, Ch.23). There is a range of intricacies inherent within glass composition; this will later prove to greatly explain the complexities of glass behaviour. A Look at Glass Chemical and Physical Composition Unlike many other materials, glass consists of a geometrically irregular network of silicon and oxygen atoms, with alkaline parts in between (fig.1.4) (Haldimann; Luible; Overend, 4). As glass is an inorganic product of fusion, it consists of a number of chemical components. The chemical composition of glass has a significant impact on glass viscosity, the melting temperature Ts and the thermal expansion coefficient ÃŽÂ ±T of glass (Haldimann; Luible; Overend, 4). One of the main attributes of glass is its resistance to corrosion by acid and water (Chen; Lui, Ch. 29). There is a vast variety of different types of glass, however, the most prevalent type of glass in construction (approximately 90%), is soda lime silica glass (Dewhurst Macfarlane and Partners), and for other special applications, borosilicate glass is used. However, depending on the purpose for the glass, other types are available, such as Lead glass, borosilicate glass, glass fibre, vitreous silica, alminosilicate g lass, alkali-barium silicate glass, technical glass, glass ceramics, optical glass and sealing glass, to name but a few (Glass Online). Borosilicate glass consists of mainly silica (70-80%) and boric oxide (7-13%) with small amounts of the alkalis (sodium and potassium oxides) and aluminium oxide. Borosilicate glass has a considerably low alkali content, and hence, has an appreciable level of chemical durability and shock resistance (Glass Online). The chemical components of soda lime glass are as follows: 70% 74% SiO2 (silica) 12% 16% Na2O (sodium oxide) 5% 11% CaO (calcium oxide) 1% 3% MgO (magnesium oxide) 1% 3% Al2O3 (aluminium oxide) (Glass Online) Regardless of the specific type, the main constituent of glass is silica sand (Chen; Lui, Ch. 29). Sand alone can be used to make glass at a temperature of 1700oC; but the addition of other minerals and chemicals significantly lowers the melting temperature (Glass Online). For instance, the melting temperature for pure silica is approximately 1710oC, but it drops to 1300-1600oC through the addition of alkali (Haldimann; Luible; Overend, 4). Glass consists of a network formers and modifiers Fig. 29.1. Silicon and oxygen ions are bonded together (formers) forming a three dimensional structural network of sodium, potassium, calcium and magnesium (modifiers) ions (Chen; Lui, Ch. 29). Sodium carbonate (Na2CO3), known as soda ash, is added to create a mixture of 75% silica (SiO2) and 25% of sodium oxide (Na2O), which will reduce the temperature of fusion to about 800oC (Glass Online). However, this concoction means the glass is produces water glass, meaning it is water-soluble. To give the glass stability, chemicals such as (CaO) and magnesium oxide (MgO) are added; which is achieved by adding limestone, which results in a pure inert glass (Glass Online). The viscosity of the liquid glass during the cooling phase increases constantly until solidification is achieved at about 1014Pas. The temperature at solidification is called glass transition temperature Tg and is about 530oC for soda lime silica glass. Contrasting crystalline materials, the transition between liquid and solid states occurs over a particular temperature range, instead of a single precise temperature (Fig. 1.5, Table 1.3). Small amounts of iron oxides are responsible for the greenish colour of soda lime silica glass. A reduced iron oxide content results in an extra clear glass, which is known as low iron glass, and is readily available (Haldimann; Luible; Overend, 6). Essentially, the composition of glass varies to appease a particular product and production method, which requires the raw materials to be weighed and mixed properly; as the consistency of the composition is vital in glass production (Glass Online). The essential physical properties of soda lime silica and borosilicate glass are summarised in Table 1.5. Optical properties depend on the thickness of the glass, the chemical composition, and the applied coatings. The most prominent of the glass properties, is its very high transparency within the visible range of wavelengths (ÃŽÂ »= 380-750nm). However, for different glass types, the exact profiles of non-transmitted radiation spectrum differ, but are in the wavelengths outside and near the infrared band (Fig. 1.6). A large percentage of UV radiation is absorbed as a result of O2 reaction in the glass, but long-wave infrared radiation (ÃŽÂ » The Making of Glass Essentially, glass is produced by rapid melt quenching of raw materials (reference); there are currently various methods by which glass is produced. The float process Fig 1.1 is the most practiced glass production method used today, which produces flat glass, attributing to 90% of the production worldwide. Although the steps vary, it is simply melting at 1600-1800oC, forming at 800-1600oC and cooling at 100-800 oC Haldimann; Luible; Overend, 1). The Pilkington Brothers introduced the float process in 1959. It has several advantages, such as low cost production, vast availability, superior optical quality, and allows for large stable glass panes to be manufactured. The production process is shown in Fig 1.2. Glass is produced by melted raw materials in a furnace at 1550oC. Subsequently, the molten glass is poured continuously at 1000oC on to a shallow pool of molten tin whose oxidation is prevented by inert atmosphere consisting of hydrogen and nitrogen. (Haldimann; Luible; Overend, 2 ). The glass floats onto the tine and spreads forming a smooth flat surface, with an even thickness of 6-7mm; it gradually cools and is drawn onto rollers, then entered into a long oven called a lehr that is heated at a temperature of 600oC. The thickness of the glass can be controlled within a range of 2-25mm, through adjusting the speed of the roller, whereby, reducing the speed increases the glass thickness. The glass is slowly cooled to prevent residual stresses being induced in the glass, after annealing, automated machines inspect the glass to check for obvious defects and imperfections. The glass can then be cut to a standard size of 3.21mÃÆ'- 6.00m, and stored. A disadvantage that arises from this method is that there is a discrepancy between the two faces of a glass sheet. Apparent diffusion of tin atoms into the glass surface occurs on the tin side, which could influence the behaviour of this surface when it is glued. The mechanical strength on the air side is greater tha n on the tin side, which occurs because of the transport rollers interacting with the tin side in the cooling area. This interaction with the rollers can reduce the strength of the glass as it can create surface flaws (Haldimann; Luible; Overend, 2). Fracture Mechanics in Glass As glass is unable to yield plastically ahead of fracture results in the fracture strength being highly sensitive to stress concentrations. To achieve accurate characterisation of the facture strength of glass, the nature and behaviour of the flaws must be integrated, as a result of surface flaws causing high stress concentrations (Haldimann; Luible; Overend, 49). The stress of glass is time dependent; yet, humidity causes stress corrosion resulting in flaws slowly growing when bared to a positive crack opening stress. Essentially, this is when a glass element is stressed below its momentary strength, fails after the time needed for the critical flaw to grow to its critical size (Haldimann; Luible; Overend, 49). These flaws are either inherent in the glass or a result of cutting, drilling, grinding, or an impact from the environment; humidity heightens the growth of cracks. Due to the cut edges in annealed glass being weaker than its flat surfaces, annealed glass beams are designed w ith lower stresses than glass plates. The onset of fast fracture is represented by this general equation: à Ã†â€™Ãƒ ¢Ã‹â€ Ã… ¡ (à Ã¢â€š ¬a)= à ¢Ã‹â€ Ã… ¡ (EGc) (ISE, 57) Where a is the half length of the crack, E is the Youngs Modulus and Gc is the toughness of the glass Gc has units of kJ/m2 and is the toughness of the glass, sometimes known as the critical strain energy release rate. The equation shows that fast fracture will happen when in a material subjected to a stress à Ã†â€™, a crack reaches some critical size a or alternatively, when material containing cracks of size a is subjected to some critical stress à Ã†â€™. This is a mathematical representation of the trend in annealed glass to be stronger under short-term loading rather than long term. The purpose of glass modification processes such as toughening and heat strengthening is to prevent glass from experiencing tension in surface to avoid crack growth, so that fracture mechanics calculations need not be considered Fig 5.3. Professor Inglis (1913) discovered that a slot, hole, or notch in a metal plate was likely to reduce strength by a greater value than that predicted from simply considering the reduction in tensile area. It was proven that the stress field near the discontinuity is exaggerated by an amount that is reliant upon the radius of curvature relative to its length perpendicular to the stress field. The discontinuities or randomly distributed flaws across the surface are known as Griffith Flaws. Griffith flaws are apparent on the surface of glass, but the strength of the glass is coinciding with the presence of visible defects, which is usually the origin of the cracks that occur under an applied tensile stress. Accidental contact can damage the edges of a glass plate more significantly than any other region of the glass. The deflection or bending of the glass is usually able to absorb the energy from an impact on a glass face but an edge impact is resisted by the full in-plane stiffness of t he glass plate or beam and produces greater damage impulse. Once load is applied, stresses develop and concentrate at the tips of flaws or cracks, which usually go undetected by the naked eye. Griffith claimed that crack propagation occurs if energy release on crack growth is adequate enough to supply all the energy that is needed for the growth of cracks. Mathematically this is stated as à Ã†â€™c=à ¢Ã‹â€ Ã… ¡EGc/à Ã¢â€š ¬a Where à Ã†â€™c is the stress required to fracture a plate with a crack of length 2a, E is Youngs Modulus and Gc is the critical elastic energy release ratio or toughness of the glass, with units of energy per unit plate thickness and per unit crack extension. This expression signifies the occurrence of fast fracture when a material is under stress that results in a crack of the size a. It is maintained by some that glass is able to reverse crack damage, i.e. heal a microcrack, if it reverts back to an unstressed state. On the other hand, the surface condition of glass sheet alters each time it is cleaned due to new microcracks surfacing. Therefore, the notion of damage reversal is up to the engineer to decide whether it is reliable in design (ISE, 57). Over time, momentary strength of loaded glass decreases, even if only subjected to static loads. This is a quintessential concept to grasp for the structural use of glass, and was demonstrated by Grenet (1899). Flaw and glass properties, stress history and the crack velocity-stress intensity relationship govern the growth of a surface flaw (Haldimann; Luible; Overend, 50). Structural Behaviour and Failure Characteristics of Glass Upon failure, glass does not yield, it fractures, and the failure is stochastic, meaning that the predicted failure is based on risk or statistical analysis (ISE, 11). However, glass is very strong, even stronger than steel. But the inherent low fracture toughness means that this optimum level of strength is only achievable when the glass is free from all defects. Ultimately, glass is brittle, without the ability to redistribute load or absorb energy (Rice; Dutton, 33). Due to the brittle nature of glass, it is important for the designer to have an insight into how the structure will behave if one or more of the glass elements fail; most importantly the safety implications should be assessed (ISE, 55). Fig 5.1 At low stress levels, the majority of materials tend to abide by Hooks law, in that stress and strain are proportional. Yet, a higher stress levels the material deforms plastically, but as glass is a brittle material, it simply fractures without warning instead. The mechanical properties of glass are displayed in Table 29.1 (Chen; Lui, Ch.29). The theoretical strength of glass is usually approximately a tenth of it elastic modulus. The density of the cracks rather than the theoretical breakage stress governs the failure stress of glass, whereby; glass compressive strength can reach a value of 10,000MPa, demonstrating that whilst in compression it is very strong. Conversely, in tension it fails, and this usually occurs when stress levels are less than 100MPa. It is the general consensus that glass failure originates from crack growth and surface flaws, where the stress is concentrated, as demonstrated in Fig 29.5 (Chen; Lui, Ch.29). To gain scope of how differently glass behaves relative to the most commonly used construction material, steel, is to observe the behaviour displayed in stress-strain curve: Glass molecular structure influences its mechanical properties, particularly its random irregular network of silicon and oxygen atoms. Its structure allows for no slip planes or dislocations so that macroscopic plastic flow transpires before fracture (Haldimann; Luible; Overend, 49). Glass failure is most likely to be initiated by surface cracks, because these tend to have the worst geometries and are subjected to the highest stresses due to bending. If the loads to which the glass is subjected do not create enough surface tension to overcome the surface compression, no crack will propagate. Toughening, therefore, increases the effective strength and impact resistance of the glass. Should an external load overcome the precompression and cause a crack to propagated, then the stored energy due to prestress will cause the cracks to spread immediately in all directions and the pane of the glass will fragment explosively (Rice; Dutton, 33). Static fatigue of glass, also known as sub-criti cal crack growth is a phenomenon of glass. An applied sub critical stress causes cracks of flaws to slowly grow with time, until a length is reached, at this point the stress intensity at the crack tip reaches a critical value. Consequently, rapid fracture occurs due to the highly strained atomic bonds swiftly breaking at the crack tip. Stress corrosion is a term used to describe the relationship between the crack growth velocity and the stress intensity factor. Apart from applied stress, there are a number of factors that hasten slow crack growth, such as alkaline solutions and increasing temperature (ISE, 56). Plastic flow is not possible in glass, therefore when the glass surface is in a state of tension; the flaws produce high stress concentrations. The flaws are random and can take any path; therefore the failure strength can only be determined through statistical analysis. Therefore, the basis of risk of fracture of glass that is determined does not give assurance that the glass can withstand the designed load. Strength of glass relies on the load duration and environmental conditions; Fig 29.6 shows the strength-time relationship (Chen; Lui, Ch. 29). The time to failure and applied stress relationship is expressed mathematically as à Ã†â€™nT= constant Where à Ã†â€™ is stress T is duration and n is a constant (ISE, 56). The value of n varies, and Sedlack (1995) as well as Pilkington Glass Consultants recommend n = 16 for design purposes. This equation suggests that loads applied at an exceedingly long duration will allow allowable stresses to decrease to insignificant values. However, in reality, this is not true (ISE, 56). Unlike steel that yields and flows when locally overstressed, glass breaks when it is overstressed. For that reason, it is vital that the designer attempts to eradicate possible design features that may result in stress concentrations. Such as bolted glass has been developed in such a way that, stress concentrations are avoided around the bolts; this attention to detail cannot be readily detected (ISE, 58). To avoid force being transmitted from glass to another material, as this causes stress concentrations to develop; soft setting blocks, fibre gaskets, and protective brushes have been implemented to limit this (ISE, 58). Glass is almost perfectly elastic, linear and is isotropi c, and is not subjected to fatigue (Haldimann; Luible; Overend, 8). Glass only fails by brittle fracture, and cycling loading can cause the growth of cracks. Most materials have a fatigue limit, whereby there is stress amplitude where facture does not happen or fracture only happens after a great number of cycles (>108). Additionally, although many materials have a fatigue ratio, which is the ratio of the fatigue limit to yield strength, but since glass does not yield, this attribute is obsolete (ISE, 58). As glass fails in tension or by buckling, the highest tensile stresses that occur from applied loads should be considered when finding the elastic stability of glass element. Applied compressive stresses can cause tensile strains, but tensile strains can even occur as a result of the Poissons effect from compressive stresses (ISE, 60). Glass failure occurs when the tensile stress is equal or greater than the characteristic strength, which can be calculated using Eqn 29.5. The memb rane stress is constant across the thickness of the plate, whilst the bending stress can be taken as varying linearly. Thus, superimposing the membrane and bending stresses can determine the total stress on the glass (Chen; Lui, Ch. 29). Furthermore, the deflection of glass elements is an important aspect to consider; and such behavioural patterns like toughened glass deflecting more than annealed glass (even when of the same strength) due to toughened glass being considerably thinner, should be taken into consideration (ISE, 56). Glass plates are typically thin so they demonstrate large displacements. The use of thin plate linear bending theory will produce incorrect results. Therefore, the large deflection theory should be used instead to calculate the maximum stress when checking stress against failure. Failure generally is taken to be at the point when the maximum tensile stress equals the glass fracture stress (Chen; Lui, Ch.29). Glass can be quite sensitive to any impact and will result in fracture; the common causes of glass breakage are: Excessive stress form wind pressure or other loads Thermal stress due to differential temperature on different parts of the pane Buckling due to large compression Surface or edge damage Deep scratches or gouges Severe weld splatter Direct contact with metal (e.g. window aluminium frame) Impurities like nickel sulphide (NiS) Excessive deflection bringing glass in contact with other hard objects. (Chen; Lui, Ch. 29) Hence, the strength of glass relies on these aspects: the duration of the applied load, environmental conditions, humidity, size of the stressed area, the distribution of stresses across the stressed area, the condition of the surfaces and edges of the glass (ISE, 57). Prestressing glass, notably by heat-strengthened and toughened are the two basic types, enables the glass to maintain compression on the surface, therefore, eliminating crack propagation (ISE, 59). Survival probability of scratched glass loaded at a constant rate Eqn; Time dependence of glass strength Eqn Fig 5.4 Fig 5.5 Fig 5.6 The Different Types of Structural Glass Glass, itself, is highly susceptible to fracture, which results in a lot of shattered glass, and ultimately, health and safety implications. The fracture of glass stems from the surface flaws. Thus, the industry has developed various modification methods to achieve an increase in the practical strength of glass, by introducing local high compressive stresses near its surfaces (Chen; Lui, Ch.29). By common practice, these modifications are usually implemented on float glass. Tinted Glass Tinted glass is also known as heat-absorbing glass, and is produced by colorant being added to normal clear glass. Light transmittance varies depending on colour and thickness, with a range between 14 to 85%. As a result, tinted glass is not and heat-strengthened glass is typically used when making tinted glass (Chen; Lui, Ch.29). Coated Glass Placing layers of coating onto a glass surface makes coated glass, and there are two types: the solar control (reflective) and the low emissivity types. Structural strength of coated glass is only indirectly affected when the thermal stress is altered, but coated glass is more associated with its energy absorption and light transmission attributes. Therefore, to prevent excessive thermal stress, heat-strengthened glass should be used to produce coated glass (Chen; Lui, Ch.29). Wired Glass A common misperception is that wired glass is stronger than unmodified annealed glass, due to the wires being seen as reinforcement. However, the wires actually induce cracks and weaken the glass. Yet, wired glass is able to hold together upon being broken (ISE, 22). Wired glass is produced when a steel mesh is implemented onto the molten glass during the rolling process (the rolling portion of the flat glass process). It has a high rate of breakage due to sunlight, and hence is weak in resisting thermal stress. Although it is still weak in resisting thermal stress, polished wired glass is used for fire rating since after it breaks, it sticks to the wire mesh and prevents smoke passing. Figure 29.8 shows a damaged wired glass panel under sunlight (Chen; Lui, Ch.29). Annealed Glass Annealed glass panels do not have any heat treatment (Chen; Lui, Ch.29); it is produced using the float process (as described previously) (ISE, 22). It is usually used when large glass panels need to be used, and it is too large for any heat treatment (Chen; Lui, Ch.29). The behaviour of annealed glass is typically perfectly elastic until fracture occurs. Upon fracture, large, sharp shards emerge which are dangerous. However, annealed glass panes do not spontaneously fracture, and due to alternate load paths across the glass pane, it may not fall out of its frame upon failure. Although there is no creep or fatigue in the metallurgical sense, slow crack growth occurs as a result of cyclical loading, whereby, if this glass is under permanent loading, the deformation increases with below 3% over a 50-year period. Imposed strains, such as bending and thermal stresses, as well as instant impact, causes elastic deformation resulting in brittle fracture of annealed glass (ISE, 22). Annealed glass is not very strong, so it is weak in thermal resistance. The allowable stress is approximately 15N/mm2 (Chen; Lui, Ch.29). Fig 2.4 Fig 2.5 Fig 2.6 Heat-Strengthened Glass Heat-strengthened glass is created using a similar process to toughening, with the exceptions that there is a lower cooling rate (Haldimann; Luible; Overend, 12) and the level of the produced prestress is lower. The fracture behaviour, however, is more akin to that of annealed glass rather than toughened (ISE, 24), with larger fragments than that of thermally toughened glass (Haldimann; Luible; Overend, 12). The compressive surface stress for heat-strengthened glass lies in a range between 24 and 69N/mm2 and European Standards quote that the pattern of breakage ranges between 25 to 40N/mm2 (ISE, 24). Heat-strengthened glass is commonly used in laminated glass assemblies, but the nature of its large fracture pattern causes a significant remaining load-bearing capacity upon failure of the glass. The stress gradient depends on the thickness of the glass and as the glass must be cooled down gradually, thus, thick glasses (exceeding 12mm) cannot be heat-strengthened using the toughening p rocess (Haldimann; Luible; Overend, 12). Laminated Glass Laminated glass is two or more glass panes bonded with an interlayer of polyvinyl butyral (PVB) or resins, such as acrylic. The thickness of the interlayer varies between 0.4mm to 6mm. A disadvantage of laminated glass is the validity of composite action. Although usually only two layers are bonded, over 25 layers have been effectively bonded coming at 100mm thick. Laminates can integrate many thicknesses and arrangements to suit a certain requirement. Most importantly, many different types of structural glass can be arranged in the laminated formation, including toughened, annealed, heat-strengthened and bent glass for example. However, toughened and heat-strengthened glasses both cause small amplitude waves as a result of the rollers used in the process. This in turn, enhances the separation between the laminated glasses and ultimately the PVB is impractical. Therefore, resin laminating should be instead. When using a PVB interlayer, the sheets of glass have the PVB interjected bet ween them and then this sandwich travels through an oven of about 70oC, and then passes between rollers which squeeze out the excess air from the bonding. The laminated glass is then placed in an autoclave, heated at 140 oC and at a pressure of 0.8N/mm2. It is possible to manufacture laminated glass at a maximum of 6m by 3m. In resin laminating, the two principal resins are acrylic and polyester. The glass sheets are held together at a right distance apart using double-sided tape around the perimeter. The resin can then be poured in between the two sheets, and once the air has been extracted the open edge can be sealed, and the laminate is stored horizontally to allow the resin to cure and solidify. The curing occurs through UV light or chemical reaction. The size that can be manufactured using this method is dependable on available glass pane sizes (ISE, 24). The structural behaviour of the laminated glass varies, depending on the duration of the load. Hooper (1973) demonstrated that the duration of the loads affected the behaviour of the laminate. With short-term loads the laminate acted compositely, whilst with long-term loads, the load was shared between the two glass sheets, in proportion to their relative stiffnesss, as a result of the deformation of the interlayer (ISE, 24). To determine this behaviour, the deflection of the panel under a specific load should be measured and then compared to the deflection calculated using finite element software. This would allow for the equivalent thickness used in the software to be adjusted to give the same deflection measured, in order to determine the equivalent thickness of the laminated glass pane that should be used for optimum design (Chen; Lui, Ch.29). An increase in the temperature, results in the interlayer softening and a reduction in the composite behaviour. Laminated glass is highly valuable as it offers various performance benefits. For instance, if one or both of the layers are impacted and breaks, the interlayer prevents penetration and allows any broken glass to stay bonded to the interlayer. Additionally, an increase in the thickness of the interlayer increases the penetration resistance of the glass (ISE, 24). Fig 29.9 Displays laminated glass behaviour once broken (Chen; Lui, Ch.29). Toughened Glass Chemically Toughened Glass: Chemically toughened glass implements the principle of a compressive surface layer preventing crack propagation, where the compressive layer is a result from an ion exchange process. Therefore, flat glass that contains sodium ions is immersed in a molten salt bath (electrolysis baths (ISE, 23)), of potassium nitrate. As the temperature of the molten salt is insufficient to permit structural relaxation, the potassium ions force themselves into the sodium sites, consequently, putting the surface under compression (Clare, Ch.23). Although it is an advantage that unlike thermal toughening, thinner glass sheets can be toughened, it results in thinner compressive layers, which are less robust than the thicker layer created through thermal toughening (ISE, 23). Also, the strength of glass can be increased by ten times depending on glass composition (Clare, Ch.23). Thermally Toughened Glass: Thermal toughening of glass is achieved by heating annealed (float) glass plate to about 620-650oC, whereby it begins to soften at this point (ISE, 23). The outer surfaces are then cooled rapidly by cooled air blasts, and the exterior layers quickly cooled and contracted. A thin layer of high compress stress the surface occurs, with a region of tensile stress at the centre of the glass (Fig 29.7). The parabola represents the stress distribution across the thickness of the glass pate, which is also in self-equilibrium. The physical properties of the particular glass used and the geometric shape of the glass governs the exact shape of the curve. Toughened glass has a bending strength is three to five times

How to say no Summary :: essays research papers

Chapter 1- Saying No: The Basics In the first chapter of How to Say No Without Feeling Guilty, the authors present the basics of saying no. But why say no? Many times people are persuaded into doing things they don’t want to do, simply because they can’t find the right words to say no. Another reason why people don’t say no is because they are afraid of what the person will think of them if they say no. I can understand this, because many times I have found myself doing things for people because I couldn’t think of a good excuse to get myself out. After reading the first chapter, I learned the basic techniques to politely saying no. The first one is surprisingly simple—just buy more time. If you can put off your decision to accepting a request from someone, you then have the time to really think about what it will take to satisfy the other person. One of the phrases they suggested was, â€Å"I need to find out if I work first†. As a college student, my work schedule is anyth ing but consistent, so that phrase will be great for me to use. Another suggestion was to say you have a â€Å"policy† against doing something. It’s good because it lets the person know how important it is to do what you need to do. But for me, I don’t think this would be any good, because my friends wouldn’t buy the fact that I have a â€Å"policy†. The prevention technique seemed like it would be a good one. I have a friend who whenever I see, he always wants to go out to a bar and drink. I normally don’t mind, but if I go over to visit him and I’m not in the mood to go out, he will insist that we go anyways. Prevention would be good in this case because if I don’t feel like going out that night, I should probably just avoid this friend entirely. Lying to someone in order not to hurt them, or the face-saving excuse is also a good tactic. If an unattractive girl were to ask me out, I wouldn’t tell her no because I thought she was unattractive. I would probably tell her that I have a lot of work to do for the next couple of months, and I don’t really have time to be going out with her.

Effects of CTelevision Broadcasting :: Essays Papers

Effects of CTelevision Broadcasting The television is one of the most widely known and utilized inventions of the twentieth century. As its popularity has grown, its effect on how people, especially children, view the world around them has become more prominent and recognized. â€Å"To suggest that children growing up in the 1990s live in a different world than the one their parents or grandparents experienced is not only to state the obvious, but to understate the obvious.† Increasing popularity of television between the generations is partly responsible for the changes. Television is at the center of a multimedia society. Television is especially prominent because it reaches children at a much younger age than other mediums. (Asamen 9) Television becomes a firm staple in most children’s lives a considerable amount of time before formal education begins. Children as young as six months react to television’s sights and sounds. â€Å"For young children, a major determinate of what... they view is w hat... their parents view.† This measure of coviewing decreases with age â€Å"as does the time spent with parents in other activities.† (Bryant 231) Television and Time Control It is generally recognized that television dominates a lot of children’s time, more than any other waking activity. TV watching is often paired with other activities, such as talking, reading, and studying though. The effects of television on children vary, depending on the programs watched and â€Å"when and with whom† they watch it. It also depends on how often and how much the child watches television. (Bryant 227) Research on the effect has been sparse. "Recently, some investigators have taken account of the role played by television in family as planned or default activity, as subject matter for discussion and argument, as the occasion for parental regulation and for children's assumption of increasing responsibility for controlling their own time use." The media has taken on a partial role in raising children, just as church and school did in the past. (Bryant 227) "Children's use of television is influenced by structural factors in their lives." Children who attend day care, for example, are less likely to watch large amounts of television than those who are home all day long. Other factors of how much television children watch are if they have access to all stations or a VCR, education, social class, and ethnicity. "[Researcher's] efforts to analyze family influences on viewing rest on some general assumptions about television use.

Charles Dickens Hard Times Essays -- Charles Dickens Hard Times Essay

Charles Dickens' Hard Times Charles Dickens's Hard Times is one of the most important novels in the Victorian Age. He presents an industrial society in nineteenth century in England. In this age, England prospers in manufacture and trade because of high technologies. It is also a time of trouble. Industrial development causes terrible conditions of a working class. The workers are poor and work hard. Women and children work for many hours. Dickens also presents bad social condition through his work and also shows lives of city people and industrial society in Coketown in England. In Hard times, Dickens has a compassion for the workers and calls for the readers' sympathy by showing the workers' hardships through Stephen Blackpool, a worker who is honest, innocent, generous and full of integrity. However, facing dead-end situations, Stephen Blackpool is the most pathetic figure. Stephen Blackpool is the most suffered and submissive worker. Although he is good, skilful and diligent power-loom weaver, his life is not much improved, but he has to work for survival. Dickens presents that most of Coketown citizens are workers. He says that they are " generically called ' the Hands'- a race who would have found more favor with some people, if the Providence had seen fit to make them only hands, or, like the lower creatures of the seashore, only hands and stomachs- lived a certain Stephen Blackpool, for forty years of age." Dickens comments on the terrible lives of workers. The word " generically" presents that the workers can't rise in the world because they have no education and have not enough money to make their lives better and comfortable. Their children must face the hardship such as working hard and ... ...asks for solution to improve the workers' lives because this is an important problem. The setting increases the compassion for Stephen. It is dark and silent. Everybody mourns for him, and the darkness symbolizes sorrow and death. This picture also shows Rachael's love for Stephen. She kneels on the grass, clasp his hand and tries to comfort although he hurts badly and is going to die. This picture shows the relationship between Stephen Blackpool, his wife and Rachael. Stephen and Rachael love each other, but he can't divorce his wife because of the high expense in lawsuit that he can't afford. Rachael is good and generous woman who takes care of Stephen's wife. She is like an angel, light and shining star. On the contrary, his wife is helpless and alcoholic. She increases Stephen's burden and tries to commit suicide, but Rachael can save her life.

Analyse the Strengths and Weaknesses of Spain by 1516 Essay

There were considerable differences between the Hispanic kingdoms within the Iberian peninsula. It was divided by language and religion, governed by different political institutions and ruled by monarchs with conflicting foreign interests. Both Aragon and Castile had very little in common. The economies varied in strength in different parts of Spain, for example Catalonia was in decline whilst Valencia was in the recovery stage. The marriage of Isabella and Ferdinand in 1469 dramatically changed the course of Spain. The Queen was a determined and quick-witted woman, with a ‘street-fighter’s instinct for survival’. She guaranteed privileges to nobles and town authorities, promised to restore law and order and was the only claimant with an undisputed right to the throne. Ferdinand played a role in leading Isabella’s troops against the Portuguese and French invasions and recaptured rebellious towns, all helping to stabilise the crown. His brother also aided Isabella by commanding the Hermandad meaning that although his father died, no Aragonese nobles contested the crown. Royal authority had declined during the weak rule of Henry IV and it needed to be asserted and there was also the problem of law and order (lots of disorder in Castile due to the 5 years civil war). There were still supporters of Joanna; a minority of the nobility had fought against Isabella e.g Marquis of Vienna. The Hermandad at least brought some justice to the countryside, which benefited Castilian towns as well as law-abiding landowners. Hermandades had never been controlled so extensively by the Crown, it significantly contributed to the improvements in local administration. Corregidores were also having an impact (administrators of cities and districts with both administrative and judicial powers). They were used by the Catholic Monarchs to strengthen royal authority rather than revive local responsibility Ferdinand and Isabella travelled extensively in Castile. They spent relatively little time in Aragon in his 37-year reign (7 years). This was a very important means of asserting royal authority by showing themselves to their subjects and establishing an effective working relationship with their nobility and to discipline any troublemakers. Ferdinand and Isabella visited every Castilian town at least once. Ferdinand tried to increase royal authority over Aragonese towns by trying to introduce new procedures for the election of municipal offices. His idea of sending royal governors to towns was rejected preventing royal authority encroaching. Isabella was able to have a greater effect on improving local administration than her husband. She tried to protect, by intervention, town people from impressive nobles and nominated jurados to sit on town councils. She persisted with the idea of Corregidores in towns, despite opposition, and the number of towns with them increased (Toledo for instance enjoyed a long period of peace largely due to Gomez Manrique, its Corregidore.). Their authority varied, some governed entire regions, and others had a limited impact. However, overtime they became more corrupt lowering the standards of local administration. The civil war left deep scars and required close supervision to work effectively. Both Isabella and Ferdinand dispersed justice personally. The Hermandad was unpopular and it demanded taxation on local people for its maintenance. It was officially dissolved in 1498 as nobles increasingly disliked it (didn’t want too much crown influence). The crowns political strength lay into relationship with the nobility. Ferdinand and Isabella however, due to incompatible promises in the 1470’s, were in a different situation as some families expected rewards for their role in the civil war. This often contradicted what Isabella had said about protecting the rights of the towns. Isabella decided to harness the power of the nobility and tried to regain land given out by Henry IV. Isabella and Ferdinand on a smaller scale in Aragon gave the nobles rights to collect sales tax and confirmed their exemption from direct tax. This guaranteed their social and economic position. Also nobles who had fought against Isabella in the civil war were given fair agreements such as the Marquis of Vienna in order to preserve social stability. Those on her side were awarded with for example dukedoms guaranteeing their continuing support. Although some nobles maintained control of regional politics, which was a big threat to the crown as they had no standing army, whereas most nobles kept retainers. An example of when the crown and nobility worked together to ensure the stability of the country was the Granada between 1482 and 1492. Some of the nobility actually served in the war and fought on behalf of the crown against the Muslims. The war helped to enhance royal prestige. However, outbreaks of civil disorder and violence in Castile in the early years of the sixteenth century suggest that royal administration was beginning to break down. Nobles became better educated and there was an emergence of letrados (lawyers). Most Castilian and Aragonese peasants enjoyed a period of relative prosperity, with wage rises, stable prices and plenty of employment in the countryside. Town life was changing rapidly, Castilian merchants experienced a dramatic increase in trade and commerce, which led to a growth in business and rising prosperity for those in work. However, due to an increase in population town authorities were faced with the problem of vagrancy where people wonder from place to place and don’t usually have a home. The Catholic Monarchs intended to enhance the welfare of their subjects. They maintained the Mesta’s monopoly and continued wool trade, which was high in demand in the Low Countries. Taxes on wool and sheep and the establishment of trade links with America (gold bullion), proved extremely beneficial. Maintaining the quality of Castile’s coinage and establishing a currency common to both kingdoms, monetary if not economic unity was achieved. Overseas trade was strengthened with Venice as a base, and the financial status and prosperity of Barcelona recovered from the effects of the civil war in the 1460s. However the Spanish economy had a number of weaknesses, poor communications (bad roads, mountainous), a network of internal customs duties and inland tolls and resistance to state intervention in effecting changes in agriculture, guilds and industry. Regionalism was a very powerful force and applied to the economy. There was no significant attempt to integrate the two economies, for example, trade with Americas was a Castilian monopoly (intensified hostility between two kingdoms, threat of inflation and decline in currency). The only measure that was taken was the standardisation of the currency in 1497. The Spanish Crown failed to protect and promote its native industries and focused too much on exportation of wool than developing its textile industry. Also, the persecution of the Conversos and Jews (many of them were skilled craftsmen) damaged wool trade, while the silk trade was damaged with war in Granada (mudejars were main producers of silk, many were killed while others emigrated). Spanish wealth and commercial gains from the New World could potentially fall through due to its lack of incorporation.

Teacher and Grandmother

Interestingly, the person who had the most impact on my life was my grandmother. My grandmother was a retired College Principal, but for me she was always my Grandmother. She taught me the kinds of things that school teachers never could teach in the classroom. Because my parents were at work and my grandmother was retired, I spent a lot of time with her. She was a mother, a grandparent and a teacher at the same time. She always prepared an interesting activity for the day. We visited museums, theatres, went to the zoo, visited the library, watched movies or just stayed at home and did something fun together. She always created the proper schedule with the weather and my age in mind. I loved the way she could find the tone and the language with me, keeping in mind my capacity. She had a good sense of humor and always tried to cheer me up when she saw lack of interest or tiredness. The biggest lesson I learned from her was how to be a happy and independent child. She let my free spirit wander, making me curious and adventurous. She never lectured me or gave me boring speeches; she always found ways to engage my interest through stories and examples from her life. It were very important for her. She wanted my imagination to grow and explore different ideas and topics in my head. When I could not read by myself, she was the one who introduced me to picture books, and when I went to first grade she sat down with me and held my hand during my discovery of reading independently. My Grandmother was the first person who put a pencil in my hand. First we drew and colored together, and then slowly I learned how to form my letters and to write my name down before I started my school education. As I mentioned before, my parents had to work, so my Grandmother picked me up from school everyday. When we arrived home we always had snack and then a little free time before we sat down to do my homework. If I had a difficult assignment, for example from chemistry or physics, we tried to associate with baking as a science, or made an experiment to see how it could work in real life. She never disciplined me. How it worked between us was very natural; she was older and wiser, I was little and hungry for knowledge. I admired her knowledge, life experience and her enthusiasm; I asked question after question, begged for stories of her life and never let her sit down for a moment. She tried to keep up with me and never complained of being tired and I was never bored. I was the engine of her life and she was the educator in mine. When I was older and went to stay at overnight camps during the summer, she wrote me letters every single day. I learned how important it was to keep contact, communicate and express my feelings and ideas in writing. My grandmother made a huge impact on my life: I learned how much I should appreciate life everyday. I learned how I can make changes if I have an open and curious heart.

Obscenity Law

The vague, subjective, and indeterminate nature of Canadian obscenity law has been called â€Å"the most muddled law in Canada. † Recognizing that consistency and objectivity are important aspects in the running of any successful legal system, the Supreme Court of Canada has attempted to systematically clarify and modernize obscenity law. The ruling in R. v. Butler marked the transformation of the law of obscenity from a â€Å"moral-based† offence to a â€Å"harm-based† offence. The courts are now asked to determine, as best they can, what the community will tolerate others being exposed to, on the basis of the degree of harm that may flow from such exposure. Harm, in this context, means the predisposition to antisocial conduct. When probing beyond superficial appearances, it is clear that the modernizing moves made by the Canadian judiciary, in introducing the community standard of harm test to enforce obscenity law, are mere rhetorical covers for the continued protection of conventional morality. The determination of â€Å"community standards† is left primarily to the subjective judgment and hunches of criminal justice personnel. In this context, the standard to which obscenity laws are based can be uncertain and ill defined, making it very difficult to ensure consistency in the application of the obscenity law and to ask the public to abide by standards that are not clearly demarcated in the first place. This is a disturbing state of affairs for any criminal offense. This essay will firstly demarcate the roles in which judges currently play in deciding upon the nature of crime. Secondly, with the use of previous rulings on obscenity by the Supreme Court of Canada, the evolution of Canadian obscenity law will be analyzed. Thirdly, the involvement of the community standard of tolerance within the current obscenity definition will be flagged as prejudiced against non-mainstream minority representations of sex and sexuality. Fourthly, the Butler decision will be analyzed within the gay and lesbian context. Finally, the three inherent flaws of the current Butler definition of obscenity will be discussed; the vague definition of harm, the problematic categorization of â€Å"degrading and dehumanizing sex† and the overemphasis placed on heterosexual norms. The current roles in which judges play in deciding upon the nature of crime. Frey v. Fedoruk (1950), a decision made by the Supreme Court of Canada, is iewed as a very successful step in the courts’ quest for objectivity. This supposed milestone case marked the end of the courts’ ability to invent new crimes at common law and essentially appointed ultimate power of the Criminal Code to the federal government. Frey was accused of peeping into the window of a changing woman. The courts recognized that peeping was clearly morally objectionable, but the Court also noted that peeping was â€Å"not otherwise criminal and not falling within any category of offences defined by the Criminal Law. It went on further to say that â€Å"if any course of conduct is now to be declared criminal, which has not up to the present time been so regarded, such declaration should be made by Parliament and not by the Courts. â€Å"[i] This case essentially set the precedent that no person could be charged with an offence that was not previously stipulated in the Criminal Code. This case illustrates an evident shift in regards to the role judges play in the justice system; however, it is questionable if this shift is as substantial as originally perceived. Something that is often forgotten by those who stress the sovereign aspect of the criminal law is that Parliament does not have direct control over the enforcement of their own texts. Judges cannot directly contradict or invent new laws, but they can endlessly reinterpret them. Furthermore, in interpreting the criminal law, judges do not have control over the way in which fellow criminal justice personnel will reinterpret their interpretations. For example, due to the vagaries involved in Justice Sopinka’s ruling in R. v. Butler, criminal justice personnel have been given discretionary power that has resulted in the differential and unlawful targeting of gay and lesbian pornographic material. In arguing for judicial objectivity, one could argue that judges are only allowed to interpret law in accordance the intention of Parliament when the section was enacted or amended. Judges cannot adopt the shift in purpose doctrine, which was explicitly rejected in R. v. Big M Drug Mart Ltd. [ii]† However, in order to avoid running a foul of the shifting purpose argument, judges can use vague and indeterminate language that will only require the need for reinterpretation in the future and further the use of judicial subjectivity. When interpretations are required it opens the doors to the, subconscious or conscious, implementation of subjective standards of morality by judges or riminal justice personnel. Essentially different judges will interpret the law in different ways, which stresses the importance for clarification and specification within the Criminal Code. It has also been argued that the decision in Frey v. Fedoruk allows for citizens to know in advance if they are committing a crime. As seen in the Butler case, many laws in the Criminal Code continue to be vague and indeterminate, requiring the need for judicial interpretations. The vagaries of the obscenity law allow judges, police and customs officers, to interpret the law in a way that may encompass material or actions that were not specifically stipulated under the law itself. The evolution of Canadian obscenity law: Upon examination of the progression of Canadian obscenity law it is clear that the modernized obscenity law remains riddled with some of the same problems inherent to its predecessors. The law of obscenity in Canada has its roots in English law. The 1868 decision of the House of Lords in R. v. Hicklin was the leading case and set out a test for obscenity. In upholding an order for the destruction of a publication, Chief Justice Cockburn declared, â€Å"I think the test of obscenity is this, whether the tendency of the matter charged as obscenity is to deprave and corrupt those whose minds are open to such immoral influences, and into whose hands a publication of this sort may fall. â€Å"[1] This definition had been criticized for its disregard of serious purpose or artistic merit in the impugned material and for its excessive dependence on subjective speculations made on the part of the trier of fact. This was the test used in Canada until the Criminal Code was amended in 1959 to include a definition of obscenity as â€Å"the undue exploitation of sex, or of sex and any one or more of crime, horror, cruelty and violence. † Canadian courts then shifted their focus from the proper application of the Hicklin test to the understanding of how the â€Å"undue exploitation of sex† is to be recognized. Brodie was the first obscenity appeal to come before the Supreme Court of Canada following the amendment. Judson J. , during his explication of this ection, was conscious of the criticism that had been leveled against the Hicklin test and was subsequently trying to avoid its downfalls. Judson J. expressed the view, in light of the amendment, † that all the jurisprudence under the Hicklin definition is rendered obsolete† and that the new definition gave the Court â€Å"an opportunity to apply tests which have some certainty of meaning and are capable of objective a pplication, which do not so much depend as before upon the idiosyncrasies and sensitivities of the tribunal of fact, whether judge or jury†[2] . Two tests were purposed throughout the trial that were thought capable of objectively recognizing the â€Å"undue† exploitations of sex. The first test focused on the â€Å"internal necessities† of the work in question. The second test was â€Å" the community standard test. † He recognizes that community standards may vary from time to time, but held that there is a general instinctive standard of decency, which prevails in any given community. What is obscene is material that offend that standard. The development of the jurisprudence post-Brodie had elaborated upon this notion of â€Å" community standard. â€Å"It has been said to be: a general average of community thinking and feeling; a national standard; one where judges are entitled to judge for themselves, without expert evidence, when this standard has been exceeded. † However, a substantial development in the test for obscenity occurred in the Supreme Court of Canada’s decision in Towne C inema Theatres Ltd. v. The Queen. [3] In this decision, the court stated that the â€Å"community standard of tolerance† is only one way in which the exploitation of sex can be determined â€Å"undue. The Court recognized the imperfections of society and the subsequent possibility that the community could tolerate publications that cause harm to members of society. The court went on to say that â€Å" even if, at certain times, there is a coincidence between what is not tolerated and what is harmful to society, there is no necessary connection between these two concepts. † [4] Thus, the legal definition of â€Å" undue† was made to encompass publications that were harmful to members of society and consequently society as a whole. Material was deemed harmful if it portrayed persons in a â€Å"degrading or dehumanizing† way. Obscenity also continued to be assessed against â€Å" community standards. † This test was concerned, not with what Canadians would tolerate being exposed to themselves, but what they would tolerate other Canadians being exposed to. It was a test concerned itself with tolerance and not taste. R. v. Butler- the current definition of obscenity. The Supreme Court of Canada made its definitive decision in R. v. Butler. The case of R. v. Butler concerned the constitutionality of the obscenity provisions (now s. 63) of the Criminal Code of Canada. The provisions were under consideration on the grounds that they infringed upon a guaranteed right to freedom of expression under s. 2(b) of the Canadian Charter of Rights and Freedoms. The case is monumental in determining whether, and to what extent, Parliament can justifiably criminalize obscenity. On appeal to the Supreme Court of Canada, the following constitutional questions were raised: 1. Does s. 163 of the Criminal Code violate s. 2(b) of the Charter? 2. If s. 163 of the Criminal Code violates s. 2(b) of the Charter . Can s. 163 of the Criminal be demonstrably justified under s. 1 of the Charter as a reasonable limit prescribed by law? Before answering the main constitutional questions, Justice Sopinka, writing for the majority, firstly attempted to clarify and interpret what the impugned legislation was intended to signify. In deciding what constitutes the â€Å"undue† exploitation of sex, the court examined the three workable tests used in past cases of obscenity: the â€Å" community standard test†; the degrading or dehumanizing† test; and the â€Å" internal necessities test. The review of this jurisprudence showed that the relationship between each of the three tests failed to be clear or specific. Sopinka divided pornography into three categorie s: 1) explicit sex with violence; 2) explicit sex without violence but which subjects people to treatment that is degrading or dehumanizing; 3) explicit sex that is without violence and is neither degrading or dehumanizing. Sopinka used these three categories as the guidelines in determining what constitutes the undue exploitation of sex. Sopinka essentially merged the community standard of tolerance test together with the harm principle. The courts now need to figure out what the community would tolerate others being exposed to on the basis of the degree of â€Å"harm† that may flow from such exposure. Harm, in this context, signifies material that would predispose viewers to antisocial conduct. The first category of pornography was found to always constitute the undue exploitation of sex, the second category of pornography was found to sometimes constitute the undue exploitation of sex and the third category generally did not qualify to be the undue exploitation of sex. [5] Problems with the Community Standard of Tolerance test: It has been suggested that the modern obscenity test, the merger of the community standard of tolerance test and the harm principle, is liberal relative to its predecessor (the Hicklin test). On the surface it seems to draw on the more liberal attitudes of contemporary society about sexual representation and has the flexibility to evolve with the changing norms of communities through time. However, it cannot be forgotten that the community standard test of harm is delineated on the standards held by the majority, enforcing only the majority’s view of what is harmful and obscene. The imposition of majority views on other members of society is seen as the most serious threat to liberty in a democratic state, and seems to contradict the multicultural dogma that is representative of Canadian society. Subsuming a majority analysis into the definition of obscenity, unavoidably creates prejudice against non-mainstream minority representations of sex and sexuality. Usually, the tolerance level of a community is difficult to measure, requiring the courts to essentially guess as to how much â€Å"harm† a community as a whole would tolerate. It was held that evidence of community standards is desirable, but not essential. The lack of proof for a community standard furthers the vulnerability of minority groups. Fundamentally, judges can provide the court with a fictional interpretation of a community’s standard of tolerance. No matter how honest such an interpretation could be, it runs the risk of being false without the judge having to formally justify his/her findings. The community standard of tolerance of any given community, Professor Richard Moon says in regards to the Butler ruling, is â€Å"judicial subjectivity (value judgment) simply dressed up in the objective garb of ommunity standards†. [6] Furthermore, community standards only make sense in relations to a prevailing, and generally accepted understanding of sexual morality, in which some sex is good and some is not. Not withstanding the court’s best efforts to cast the objective of the law as the prevention of harm, particularly of harm towards women, the underlying sexual morality and the exclusive focus on heterosexu al relationships shapes the way in which the s. 163 is applied throughout the criminal justice system. It is within the context of gay and lesbian materials that the distinction between morality and harm is most difficult to sustain†, and that we can most clearly see the extent to which obscenity laws are still predicated on the legal regulation of sexual morality. Butler decision in the gay and lesbian context: The Littler Sisters Case: Throughout his judgment, Sopinka J. provides an implicit message for the need to protect females against male violence. A common thread woven throughout out many heterosexual relations is the idea of an aggressive and powerful male and a passive and subordinate female. Therefore, Sopinka J. ’s understanding of harm is set in a heterosexual framework. Gay and lesbian sexual representations are not produced within the heterosexual framework of the more mainstream pornography to which the Butler decision addressed itself. Realistically speaking, how would men watching pictures of men having sex with men, contribute to the type of harm to women identified in Butler? However, these gay and lesbian sexual representations of sexuality have been targeted, charged and found guilty pursuant to the â€Å"modernized† Butler test for obscenity. The gay and lesbian community have argued, â€Å"that gay or lesbian sexual representations have absolutely nothing to do with the harm towards women associated with heterosexual pornography. â€Å" (quote red book . pg 128 ) Interestingly, Carl Stychin, has contended, that the sexually explicit images of gay male pornography do not reinforce patriarchal male sexuality, but rather directly challenge dominant constructs of masculinity by displacing the heterosexual norm. (quote) It would seem warranted to suggest that since gay and lesbian sexual epresentations do not operate within a heterosexual framework, that these images cannot and should not be measured against a heterosexual norm. The constitutionality of provisions located under the Canadian Customs Act, who operate in accordance to Butler’s definition of obscenity, was questioned, in the context of gay and lesbian culture, in the Supreme Court of Canada’s decision in Little Sisters Book and Art Emporium v. Can ada. This case was the culmination of several instances where customs officials had unlawfully targeted gay and lesbian sexually explicit materials. Little Sisters Book and Art Emporium carried a specialized inventory catering to the gay and lesbian community. The store imported 80 to 90 percent of its erotica from the United States. Consequently, the vast majority of their erotica was susceptible to Customs censorship powers. Code 9956(a) of Schedule VII of the Customs Tariff prohibits the importation of â€Å"books, printed paper, drawings, paintings, prints, photographs or representations of any kind that . . . re deemed to be obscene under subsection 163(8) of the Criminal Code†. (quote little sister) The Supreme Court of Canada did acknowledge the fact that Customs officials had subjected the appellant to differential treatment when compared to importers of heterosexually explicit material. The treatment was dismissive of the â€Å" appellants’ charter rights under s. 15 (1) of the Charter as they were not given the equal â€Å"benefit of a fair and open customs procedure. † However, the source of the s. 5(1) Charter violation was not identified as the customs legislation itself, since there is nothing on the face of the Customs legislation or in its necessary effects, which contemplates or encourages differential treatment based on sexual orientation. The unlawful differential treatment had been made at the administrative level in the implementation of the legislation. The court held that â€Å"Parliament is entitled to proceed on the basis that its enactments will be applied constitutionally by the public service. As stated by the Court, â€Å"The fact that a regulatory power lies unexercised provides no basis in attacking the validity of the statute that conferred it. † The Court held that the Customs legislation infringes s. 2(b) of the Charter, with exception of the reverse onus provision in s. 152(3) of the Customs Act. However, the legislation constituted a reasonable limit prescribed by law, justified under s. 1 of the Charter. The court trusted Customs to identify and implement the needed changes, and the burden of monitoring compliance was left to future litigations. quote Osgood hall law journal) Thus, the majority absolved Parliament of any constitutional obligation to ameliorate this obviously flawed legislative regime of border censorship. By upholding the legislation, and simultaneously affirming the differential treatment unfairly imposed on Little Sisters Book and Art Emporium by Customs, the Court has projected itself as the defender of sexual pluralism and has not done enough to reduce the likely risk that over-censorship will reoccur. Vague conception of Harm It has been shown, most specifically in the case of Frey v. Fedoruck, that the Supreme Court of Canada has been trying to limit the power of appointed judges and consequently reserve the power over the Criminal Code for Parliament. In the Little Sisters case the Court admittedly held that â€Å"A large measure of discretion is granted in the administration of the Act, from the level of the Customs official up to the Minister, but it is well established that such discretion must be exercised in accordance with the Charter†. Ideally, all criminal justice personnel should exercise discretionary power in accordance to the Charter, but whether done mistakenly or purposely this is not always the case, which has historically given reason to the clarification or amendments of the law. Since criminal justice personnel are only human, and prone to error, the use of safeguards within the criminal code, in the form of clear and definite laws, is necessary to protect against judicial subjectivity. The majority opinion in the Butler case, includes validation of Littler Sister’s struggles and denunciates Custom’s discriminatory and excessive censorship practices. Although the ruling did include positive sentiments, it ignored the possibility that the law had something to do with Custom’s failures. The Court disproportionately blames the acts of individual custom officers, or those functioning at the administrative level in the implementation of the legislation, for the over-censorship of gay and lesbian material. However, the faulty administration of the discretionary powers conferred on officials by the Act can be a symptom of the underlying root problem: the vague community standard of harm test for obscenity. The Court defended their inaction on â€Å"the fact that the face of the Customs legislation or in its necessary effects, does not contemplates or encourages differential treatment based on sexual orientation†. Regardless of how promising a law looks on paper if it lacks consistency and objectivity in its application and demonstrates significant procedural deficiencies it should be brought into question. On a supposed quest for objectivity, Sopinka held that there should be a shift in focus from morality to harm when testing for obscenity. Harm, in this case, was defined as the risk of â€Å"anti social behavior,† (ie the mistreatment of women). â€Å"Anti-social conduct for this purpose is conduct which society formally recognizes as incompatible with its proper functioning. †[iii] Although the Supreme Court has provided us a fair amount of guidance on how the issue of obscenity is to be dealt with, it has provided a rather ambiguous concept of harm that continues to give appointed judges, and in this case Customs officers, a fair amount of discretionary power and opens the doors to subjective standards of morality. The ambiguous conception of harm has already posed problems in regards to enforcement. For example, obscenity laws have adversely affected those importing gay or lesbian erotica in comparison to other individuals importing comparable publications of heterosexual nature. [iv] Being a piece of legislation that admittedly violates our right to freedom of expression, one would think that s. 163 would be held to a higher standard of clarity. Since the definition of harm is relatively vague it can unfairly persecute the gay community, holding gay pornography to a lower standard of tolerance than heterosexual pornography. During Sopinka’s Charter analysis, he goes on to say that there is no need for proof of harm or evidence of a causative link between the obscene material and the feared social harm. This is because social harm is so difficult to prove or measure. On the one hand such a finding could be welcomed since the court has developed a test that is sympathetic to the inequality and oppression of women. However, on the other hand this loose standard of evidentiary burden, which the government must satisfy in order to justify its infringement of freedom of expression, together with a rather ambiguous definition of harm, raises the critical question as to what types of materials will be targeted. It is very important for the criminal code to be subject to a standard of heightened clarity and transparency (more so than the Charter), so that citizens can know in advance if they are committing a crime. Studies on the causal link between pornography and attitudinal harm: In the case of R. v. Butler, when deciding the second constitutional question (s. 1 analysis), Sopinka held that the prevention of harm likely to arise from the distribution of certain obscene materials constitute a sufficiently â€Å"pressing and substantial† objective to warrant some limitations on s. 2(b) of the Charter. Sopinka made clear that while parliament cannot impose subjective standards of sexual morality it can impose the morality of the majority when it coincides with the morality of the charter. This can be done to maintain values integral to a democratic society. In terms of proportionally, there are three aspects. Firstly, it was asked whether there was a rational connection between the impugned measures and the objective. The courts held that it is reasonable to assume a causal relationship between the exposure to obscene material and the risk of negative attitudinal changes (i. e. harm) in the absence of concrete proof. Secondly, Sopinka found that there was minimal impairment of the right to freedom of expression as the legislation aims only to restrict material that poses a risk of harm to society. Furthermore, material that has artistic merit will not be criminalized. Finally, the court found that there was a proper balance made between the effects of the limited measures and the legislative objective. It was found that the limits placed on the right to freedom of expression was not outweighed by the important legislative objective that was aimed at avoiding harm. Thus, the Court held that the prohibition against pornography contravenes the freedom of expression guarantee in section 2(b) of the Charter, but went on to hold that the section could be demonstrably justified under section 1 of the Charter as a reasonable limit prescribed by law. The section 1 issues raised in the Littler Sisters case related to the substance of the obscenity prohibition and the procedures by which it is enforced. The former had been fully articulated and defended by the Court in the Butler ruling, so it was not surprising that the challenge to the content of the obscenity standard itself failed. The degree to which Sopinka J defended the constitutionality of s. 163 and thus the s. 1 analysis raised by the regime f Customs censorship on the avoidance of attitudinal harm is disproportionate in comparison to the likelihood that such harm actually exists. It is very difficult to find any proof that pornography can be the cause of attitudinal harm amongst its viewers. There have been two attempts and potential sources of such proof: statistical evidence and experimental evidence. Statistical evidence attempts to show a correlation between the prevalence of pornography and the incidence of violent crime. Statistical evidence has been unable to establish a causal link between pornography and violence. Some research has purported to show that many rapists report having had little exposure to pornographic material. Furthermore as technology has become increasingly sophisticated in recent years, there has been a dramatic increase in the availability of pornography over the internet. Despite growing concerns, it has been proven extremely difficult to censor or detect the distribution of â€Å"obscene† pornographic material. Despite the probable increase in access to â€Å"obscene† material, the rate of sexual assault has not increased significantly more than those of other forms of crime. Experimental studies have come the closest in claiming a causal link between violence and pornography. Some work has shown that, under laboratory conditions, there may be a measurable relationship between aggressive behavior and exposure to aggressive pornography. However, such experiments are inherently artificial, as the circumstances are essentially fabricated. Therefore the findings in these experiments cannot be directly transferable from the laboratory into the real world, where inhibitions and public scrutiny affect social behavior. Furthermore, not all studies focus on the negative effects of pornography on viewer’s social behavior. Some support the theory that pornography can serve as a safety mechanism, allowing its viewers to satisfy aggressive impulses in a non violent way. This theory, along with the theory that pornography induces aggression, has been discredited and remains improvable. Although discredited, such a theory remains equally as plausible as the theory endorsed throughout the Butler case: that pornography induces attitudinal harm. It is unclear as to why obscenity should be defined almost exclusively around the prevention of something that could be complete fiction. In the absence of conclusive scientific evidence, it could be argued that s. 163 represents and arbitrary infringement upon our freedom of expression. It is difficult to see how the court deemed the objective of the law to be â€Å"pressing and substantial† in the absence of demonstrable proof and in the presence of empty assumptions. In the absence of proof of harm, whether material is obscene becomes a matter of faith and not evidence. Such an ambiguous definition of harm can be understood as a disingenuous effort by the court to decide what the impugned legislation was intended to mean. It could be argued that Justice Sopinka was instead formulating his judgment in regards to what he thinks the legislation should mean now. â€Å"The appellant argued that to accept the objective of the provision as being related to the harm associated with obscenity would be to adopt the shift in purpose doctrine which was explicitly rejected in R. v. Big M Drug Mart Ltd. † [v]Sopinka argues that the original purpose remains as it was in 1959: â€Å"protection of harm caused by obscene material. However, when the legislation was first enacted, it was concerned primarily with the corruption of morals and not precisely the victimization of women. Such a vague definition of harm allows the courts to justify the infringement of a Charter right on the basis of a different argument of the time and not on the basis of why the law was created in the first place. Overemphasis placed on the protection of women The obscenity test in Butler, who adversely effected the Customs Act, seems to further reinforce women’s marginalized role as crime victims as well as men’s repugnant roles as crime perpetrators. Although this ruling is meant to essentially promote equality amongst men and women, it seems as though it has completely ignored the hardships existent in same sex relationships. Throughout this judgment Sopinka provides an implicit message for the need to protect females against male violence. After such an emphasis has been placed on the protection of women, and in the absence of conventional or homophobic morality displayed by custom officers, it is questionable as to whether s. 163 would allow pornographic material portraying explicit sex and violence against men to escape criminality. Although it is very important for the law to apply equally to all citizens, as stated in s. 15(2) of the Charter it is not unconstitutional to take affirmative action to help previously disadvantaged groups such a women. In reality women run the risk, more so then men, to be victimized because of pornography. Victims of sexually based offences are disproportionately female in comparison to male. However, the types of harm that can be aggravated by obscenity, discussed throughout the Butler case, can exist in all types of human relationships regardless of sexual orientation or the individuals involved. Gays and lesbian relationships are susceptible to the same physical, sexual and mental abuse in much the same ways that heterosexual relationships do. This in essence shows that the judgment was based primarily on heterosexual norms, running the risk of ignoring other possible victims of obscenity. It is this lack of recognition of homosexuals within the leading interpretation of the obscenity law that can either cause the over-censorship or under-censorship of homosexual material, both being equally problematic to the homosexual community. Problematic categorization: In an effort to further clarify the obscenity provisions in the Criminal Code Sopinka devised a three-tier categorization of pornographic material. Sopinka concluded that material that fell within the second category of; â€Å"explicit sex without violence but which subjects people to treatment that is degrading or dehumanizing† could be considered undue. The categorization of â€Å"degrading and dehumanizing† is elusive and vulnerable to subjective or even discriminatory evaluations. The flexibility provided in the second category can be translated into inconsistencies within the legal process. Providing a category that â€Å"could† be viewed as obscene seems to dilute what was meant to be an objective guideline to be followed when testing for obscenity. The selling of material that falls within the second category is essentially equivalent to gambling since there is no certainty as to whether the selling of such material would or would not constitute a criminal offence. One could argue that the sellers of the questionable material could themselves determine the standard of tolerance of a community in determining whether the material that they are selling is obscene. However, one person’s interpretation of what the community would tolerate might be radically different from that of the courts’. â€Å" The potential subjectivity is suppose to be reined in by reference to â€Å" community standards of tolerance†. (ossgood) Since judges determine this standard on their own, in the absence of proof of such a standard, it is hard to see how they will act as a legitimate constrain of judicial subjectivity. What the current obscenity definition has trouble demarcating in obscenity as a narrow category of sexually explicit material. To remedy this situation it would have been beneficial to introduce additional categories of pornography that were more specific and detailed than the ones currently offered. Additional categories would force the court to specify what material in the second category would and would not pose a substantial risk of harm. This would have further objectified the test for obscenity because the discretion of individual trial judges would be reduced when it came to dealing with pornographic material falling within the second category. Judges and other criminal justice personnel would be required to sort material in the devised categories instead of deciding independently what they feel the community would tolerate on the basis of harm. This would also seem to provide the general population with a better understanding of lawful vs. unlawful pornographic material. Implicit to Sopinka’s categorization of pornographic material is the idea that there is a distinct difference between soft porn and hard porn when it omes to what will cause social harm. Sopinka holds throughout his judgment that the objective of s. 163 is to provide protection against what could cause the â€Å" abject and servile victimization† of women. He is assuming that the dissemination of soft porn will not pose the same risk of social harm to women as the categories of explicit sex with violence or explicit sex that is degrading or dehumanizing. However, any pornographic representation of women can be considered to be a systematic ob jectification. As Justice Gonthier wrote for the dissent of the Butler case, â€Å"even if the content is not as such objectionable†¦. the manner in which the material is presented may turn it from innocuous to socially harmful. †[vi] Both soft porn and hard porn (all three categories) could thus contribute to women’s subordination and inequality in society. It is clear that Sopinka’s test for obscenity does not necessarily lock up with its purpose of protecting women from antisocial behavior and inequalities and could serve as evidence of an appeal to conventional standards of sexual morality. Modest and restrained depictions of sexual activity were permitted in accordance to an implicit hierarchy of conventional moral values and not on the basis of harm. (does that make sense? ) The â€Å"internal necessities test† can also be questioned in terms of Sopinka’s harm based obscenity test. Pornographic representation found in art and literature can be just as harmful as what is found in, what is now understood to be, pornography. Therefore, it seems as though material that could be dehumanizing and degrading and thus cause significant social harm could pass the test for obscenity devised by the court. By not leaving behind the view that representations of sex are bad if not redeemed by art or some other higher social purpose, the definition of obscenity remains vague and open ended. The Customs administration of the obscenity prohibition at the border and the general over-censorship of homosexual pornographic material, confirm that the Butler definition of obscenity is open to multiple interpretations and makes room for the affirmations of old prejudices. In the Littler Sisters ruling, the Court denied that these problems existed, and instead relied upon an idealized portrait of the community standard test that will llegedly force criminal justice personnel towards judicial objectivity. It has been proven that the community standard test is based primarily on the views of the majority and does not necessarily constitute a â€Å"guarantee of tolerance for minority expression†. In actuality society, while becoming more liberal, is still deeply entrenched with prejudices again st minorities especially throughout the criminal justice system, stressing the need for clear and definitive language used within the Criminal Code and court process.