My Favorite Case We Went Over In Constitutional Law This

My favorite case we went over in constitutional law this year is Lochner v. New York because of the display of power by the justices joined in the majority and the fervent dissent countering their reasoning. I have described Lochner above in the context of the Commerce clause above but my focus for this question is the case in context of the Substantive due process section of the class. The substantive due process clause deals with the law itself and not the process, substantive rights are protected under the Due Process Clause. This clause has come to encompass more and more rights, such as abortion, the right to die, and many other. â€Å"No state shall deprive any person of life, liberty or property, without due process of law† (U.S. Const.†¦show more content†¦The general right to make a contract in relation to business is protected by the 14th amendment because it was read into â€Å"liberty† of the due process clause. Justice Peckham established that â₠¬Å"The right to purchase or to sell labor is part of the liberty protected by this amendment, unless there are circumstances which exclude the right† (Lochner 809). The court found that the right to contract was a fundamental liberty, expanding the mean of that word to something more than just bodily freedom. A reason I think this is one of my favorite case is because this is one of the earlier cases of Judicial Activism. I tend to agree with Holmes’ dissent more because he argues that the constitution should not be used to limit governmental regulation under the guise of the 14th amendment to promote a Laissez-fair form of economics. â€Å"But a constitution is not intended to embody a particular economic theory, whether or paternalism and the organic relation of the citizen to the state or laissez-fair† (Lochner 813). He states that â€Å"Every opinion tends to become a law. I think that the word liberty in the Fourteenth Amendment is perverted when it is held to prevent the natural outcome of a dominant opinion†¦.† (Lochner 813). He disagreed with the majority Justice’s conclusion that creates law from the bench. It is the job of the legislature to create lawsShow MoreRelatedThe Importance Of Human Rights1390 Words   |  6 PagesThese are some of the issues that were discussed in Articles written by Michael Pollen in an â€Å"Animal’s Place†. An article on, rather animals, should have constitutional rights. Molly Ivins article â€Å"Get a Knife, Get a Dog, but Get Rid of Guns†. Is an Article on rather or not our right to bear arms should still be relevant? The third article â€Å"The Case of Torture†. Is an article on rather or not Terrorist should the same legal rights as a non-terrorist? 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A Dirty Job Chapter 18 Free Essays

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None Provided Argumentative Essay Example For Students

None Provided Argumentative Essay Quality and Six Sigma Quality InitiativeSigma ? is most common known as a Greek letter which is used in statistics as a measure of variation, or change. Most of the people, however, dont know that ? is not only a symbol but it is also a method of quality. 6? Quality (Six Sigma Quality) is a management philosophy which has to lead to better employee performance and therefore completely satisfy the customer. Six Sigma Quality, or in the abbreviation 6SQ was first introduced in 1986, when Dr. Mikel J.Harry tried the first project in the Motorola Company. However, the idea if it is not new. The same, or a very similar concepts are known under different names such as Total Quality Management (TQM) or Zero-Mistake-Production. Nowadays, many companies adopted the Six Sigma Quality Philosophy, among them are General Electric (GE), BMW car producers in Germany, Navistar or Thermoking. Six Sigma involves all the employees, from the basic ones, to the top management. 6SQ requires not only training, but also the cooperation from the employees. If a company achieves ? 1, it will have a yield of 31% that means the business operations will be error free in 31%. Sigma on the stage two means error freeness in 69.2%, number 3 93.32%. All this seems to be a big improvement, but as we will see later on, it is not enough to work on the level 3, or 4, even though both of them have a very high percentage of error-freeness. Sigma step number 4 in the real numbers means 99.37% error free operations. Most of the companies, which are working under 6SQ are operating somewhere between Sigma 3 and Sigma 4. Sigma 5 means almost perfect result. 99.97% error freeness, and this seems to be a dream for most of the companies. The highest Sigma level, Sigma 6 has the yield of 99.99966%. We can summarize it in a following table. As we may see, the improvement between each of the Sigma steps is incredible, the step ? 6 is 2000 times better than the ? 4. What do this numbers mean in the real life? If there is a ? 4 which means 99.37 error free operations, it would mean for example that 2 planes at the Chicago Airport would be landing unsafely every day. 500 people per week would be suffering because there would be victims of the incorrect surgical operations. Or 22,000 checks would be deducted from the wrong bank accounts every hour. Therefore, it is very important that the companies approve their quality, so they can achieve at least ? 5. What is quality and how the we achieve it?Quality can be defined as anything that enhances the customers satisfaction. Of course, the company has to satisfy not only customers, but their employees as well. Employees can be satisfied, if their needs are satisfied. If we apply Maslows Hierarchy of Needs, we can see that peoples needs can be divided in five groups: where the basic needs are satisfied, needs such as food, sleep etc. -where the needs of safety are have to be satisfied. -each person has to be accepted by the others-this is the drive toward self-fulfillment How can be these needs applied to Quality? If the customers are satisfied, it is predictable that their job results will be better.Therefore, the CEOs of the Company have to be aware that they have to provide people with a good environment, and then they can except better results from their employees. For the easier understanding of the situation we can make a model Company which is called Monique Ltd. This company is producing perfumes and it has 1,000 employees. The CEO and the Work council have decided, after they saw their results from the last accounting period, that the quality as well the profit is not satisfactory. Therefore they decided to make a survey within the company how are the employees satisfied with their work conditions. Most of them said, that their salaries, as well as the social conditions are not satisfactory. Others were worried that the working place is not safe enough. A very small group replied that they dont have the chance to get promoted. The work council became worried, and the CEO was worried as well, because both of them saw,that they underestimated the situation. The needs of the individuals were not satisfied.Some improvements were introduced. The employees are not going to get paid according to a flat rate, but they will have as the benefit shares from the profit of the company, if the profit in the next year will be more than $1,000,000. There will be groups introduced and each group will have only one control point, not every group several. This however will require the cooperation of all employees. How to do that? Since the CEO heard about the Six Sigma Initiative and he decided to try it in his company. .u3a44b132efbffb1cfb55e94a6a1162f3 , .u3a44b132efbffb1cfb55e94a6a1162f3 .postImageUrl , .u3a44b132efbffb1cfb55e94a6a1162f3 .centered-text-area { min-height: 80px; position: relative; } .u3a44b132efbffb1cfb55e94a6a1162f3 , .u3a44b132efbffb1cfb55e94a6a1162f3:hover , .u3a44b132efbffb1cfb55e94a6a1162f3:visited , .u3a44b132efbffb1cfb55e94a6a1162f3:active { border:0!important; } .u3a44b132efbffb1cfb55e94a6a1162f3 .clearfix:after { content: ""; display: table; clear: both; } .u3a44b132efbffb1cfb55e94a6a1162f3 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .u3a44b132efbffb1cfb55e94a6a1162f3:active , .u3a44b132efbffb1cfb55e94a6a1162f3:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .u3a44b132efbffb1cfb55e94a6a1162f3 .centered-text-area { width: 100%; position: relative ; } .u3a44b132efbffb1cfb55e94a6a1162f3 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .u3a44b132efbffb1cfb55e94a6a1162f3 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .u3a44b132efbffb1cfb55e94a6a1162f3 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .u3a44b132efbffb1cfb55e94a6a1162f3:hover .ctaButton { background-color: #34495E!important; } .u3a44b132efbffb1cfb55e94a6a1162f3 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .u3a44b132efbffb1cfb55e94a6a1162f3 .u3a44b132efbffb1cfb55e94a6a1162f3-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .u3a44b132efbffb1cfb55e94a6a1162f3:after { content: ""; display: block; clear: both; } READ: Del monte VPN architecture suggestion for assignment purpose EssayAs the survey showed, Monique Ltd operates error free between 70 and 75%, in 6 Sigma terms between ? 2 and 3. The CEO wanted to improve the number to ? 3-4, which means 93.3 and 99.7% error free operations. Since the new salary system was introduced, people started to be more satisfied. Still, there was some uncertainty. CEO believed that some training is needed. Six Sigma Quality has a training which is supposed to teach the people how to work efficiently and error freely. Six Sigma Quality has a training which is divided into 5 parts. 1. Awareness part which should be for all of the employees2. Improvement part which is for the team members3. Black/Green Belt Training this is is the actual training for the team leaders. It has two parts. Part one is the Green Belt Training which deals with the basic quality and improvement issues, and Black Belt, which comes after Green Belt, which is also dealing with the quality and improvement, however it much more detailed. 4. Master Black Belts is the training for the team consultants5. Champions last, but not least the training for the management. All of these seemed to be a good idea, and therefore 3 days for each training was dedicated. The employees were asked to cooperate and sign up for this training. Most of the employees agreed and signed up. 850 from 1,000 completed the 3rd stage Green/Black Belt training, and 10 became Master with the Black Belt. The training was not the only improvement in the Monique Ltd Company. People were involved in problem solving, and the power of the Work Council was stronger. Work Council proposed the flexible working time, which in reality meant that people could choose when it is convenient for them to come to work. The fixed times, however, could not be changed to flexible times, because it is important that someone is there in the major times, when customers could call. This times were between 9.30 and 14.30. Whenever a person arrived to work, there was a little card, which was there to be signed by the machine. In case, that the person is working longer hours that it is prescribed (8.5 hours daily) it was also noted at the card. These hours could be added and a free day could be taken, however, the further acceptance of the manager was needed. At the end of the year the final results came. CEO founded out, that the profit increased rapidly. Of course he was very happy about that. Increase in employees satisfaction, as we could see in our example, can lead to major improvements in the company. However there are some problems with that. In Slovakia, for example it would be very difficult to introduce low control organizations. I believe that people wouldnt work effectively, because they would know that there is no one who is going to control over their work. Six Sigma Quality is also trying to eliminate rework, preparatory work, as well as the external and internal transfer of materials. This would not be possible, or at least now not possible to introduce in Slovakia. Most of the people who are employed in the governmental organizations, are filling their working day with reworking, inspecting and transferring. If 6SQ would be introduced in Slovakia some people would loose their place, because no re-working, or a very small amount would be needed. There is also a problem with the flexible working time. If people could come to work, whenever they want to, sign the card and sign it again whenever they leave, I believe that they would let the card sign from the other colleagues, or they will sign it a day earlier. Still, Six Sigma Quality doesnt have only positive elements. It is trying to involve all employees in the process of quality, there are seminars, where people are taught how to work effectively.They are taught about effective working, which, in most of the cases is the common sense. Alone the General Electrics Company (GE) is going to invest $550 M only in the year 1999 for the Six Sigma Program. (Manager Magazine, October 1999). Since GE had 293.000 employees in the year 1998, the cost for each employee comes up to $ 1.706. Since we have to consider that not all the employees are willing to take part on the seminar. Some of the people view that the Six Sigma Quality is forcing people to do lots of seminars on what is the common sense saying. Simply it is sometimes viewed as a pure waste of time, because the participation on these seminars takes a lot of time. The other disadvantages include another stress for the employees who are running the quality program and also for the employees who have to be in the program. Very often the idea is not bad at all, but the employees simply do not have time to complete the tasks. Bibliography:

Light Of Sight Essays - Electromagnetic Spectrum,

Light Of Sight In this universe there are many thing that we cannot explain. Among these many things is light. Light, as far as we know, come in different wavelengths and the size of the wavelength determine what type of light it is. The middle wavelength lights are what gives us the seven basic colors of red, orange, yellow, green, blue, indigo and violet. Beside these visible lights there are the lights that cannot be seen by the human eye. These invisible lights can be grouped into two other groups the long waves and short waves. The first group of waves is the longer wavelength of light including infrared and radio waves. Radio waves, the longest wavelengths, alternate and can be volatile. Arthur C. Clarke said in the essay "The Light of Common Day" that since radio waves fluctuate so much no animal has ever been able to sense them. He goes on to say that if you had an eye big enough to see radio waves your eyes would be millions of times larger than a normal eye. The next longest wave is the infrared light waves. Infrared light is used nowadays to see in the night. Special goggles are designed to pick up infrared light making it possible to see at night. The next group of light waves are the shorter waves of ultraviolet and x-rays. Ultraviolet light, sometimes referred to as UV, is right next to violet and is just beyond sight. UV light is what causes sunburns and can be very painful. In Arthur C. Clarks essay it states that even though UV light is not visible the retina of the human eye reacts powerfully to it. He compare the human eye to a camera and says that a good camera need may types of lenses made out of different types of glass to take a good picture. The human eye has only one lens and cannot possible see UV light. The last type of light is the x-ray. The x-ray is the smallest wave and is used in the medical field greatly to take pictures through flesh of bones. Even though x-rays are very useful they can be very dangerous. They have been know to disrupt radio waves and can poison a human body to the point of death. In summary, the invisible lights can be broken down into large wavelength and short wavelength groups. The large wavelength group consists of radio waves and infrared light. Radio waves are sometimes volatile and infrared light is use to see at night among other things. The other set of invisible light, the short wavelength, include ultraviolet light and x-rays. Ultraviolet light is not visible but affects the retina in the human eye. X-rays are helpful in hospitals but are lethal in large quantities.

Information About the Nut-Producing Allegheny Chinkapin

Information About the Nut-Producing Allegheny Chinkapin Chinkapin or chinquapin is a small tree found throughout the southeastern United States. It has one nut in a burr that opens into two halves which gives the tree a distinctive chestnut look. Botanists have now condensed the trees grouping of taxa to a single tree, Castanea pumila var. pumila and now consider that the chinkapin is one species comprising two botanical varieties: vars. ozarkensis and pumila. This tree should not be confused with chinquapin oak. The Allegheny chinkapin, also called common chinkapin, may well be the most ignored and undervalued native North American nut tree. It has been widely hailed as a sweet and edible nut and has been of value to its cousin, the American chestnuts breeding programs. It is, however, a small nut encased in a tough bur which makes for difficulties in harvesting the nut. Chinkapin Specifics Scientific name: Castanea pumilaPronunciation: cast-ah-neigha pum-ill-ahCommon name(s): Allegheny chinkapin, common chinquapin, American chinkapinFamily: FagaceaeUSDA hardiness zones: USDA hardiness zones: USDA hardiness zones: 5b through 9AOrigin: native to North America The Special Little Chinkapin Nut The chinkapins fruit is an interesting small, bur covered nut. The bur has sharp spines, 3/4 to 1 1/2 inches in diameter. Often the burs form in clusters on stems but each bur contains a single, shiny brown chestnut-like nut. Nuts are edible and quite sweet when mature in the fall. A horticulturist once remarked, the Allegheny chinkapin makes your mouth water but to see it makes your eyes water, obviously liking both the trees beauty and bounty. Other experts suggest that the tree is well worthy of cultivation as an ornamental shade tree, even if we leave out of the account its rapid growth, productiveness, and delicious little nuts, which will be very acceptable for home use. There are several online sources where you can purchase the tree. General Chinkapin Description Castanea pumila var. pumila can be characterized as a large, spreading, smooth-barked multistemmed shrub, 10 to 15 feet tall, or as a small tree occasionally single stemmed and 30 to 50 feet tall. Large trees are sometimes found in the landscape, especially where they have been groomed and encouraged to grow and where there are few competing trees. Chinkapin Leaf Characteristics Leaf arrangement: alternateLeaf type: simpleLeaf margin: toothedLeaf shape: elliptical; oblongLeaf venation: parallel side veinsLeaf type and persistence: deciduousLeaf blade length: 3 to 6 inchesLeaf color: greenFall color: yellow Chinkapin Nut Harvest The Allegheny chinkapin is normally ready for harvesting in early September in the upper tree hardiness zones and later in the lower portion of the trees natural range. These nuts need to be harvested as soon as they mature. Prompt nut collection is a must as a large wildlife population can remove the entire crop in days. Again, one single brown nut is contained in each spiny green bur. When these burs start to separate and begin changing into a fall yellow color, its time for seed collection. The burs of chinkapin are normally no more than 1.4 to 4.6 cm in diameter and will split into two sections at nut maturity. Pests and Diseases of Chinkapin Chinkapins are fairly susceptible to the Phytophthora cinnamomi root rotting fungus as are many tree species. The tree can also suffer from the blight of the American chestnut. The Allegheny chinkapin seems to be somewhat resistant to the American chestnut blight which is a fungal disease caused by Cryphonectria parasitica. Only a few heavily cankered trees have been found in Georgia and Louisiana. Chinkapins that do blight will continue to sucker and send up shoots from the root collar despite the cankering and will produce fruit. Folklore Legend has it that Captain John Smith recorded the first European record of the chinquapin in 1612. Cpt. Smith writes, The indians have a small fruit growing on little trees, husked like a chestnut, but the fruit most like a very small acorne. This they call Checkinquamins, which they esteem a great daintie. Bottom Line Allegheny chinkapins are prolific producers of sweet, nutty flavored, small chestnuts. They have attractive foliage and flowers, although the odor at blossoming time is considered unpleasant. Horticulturist Michael Dirr says Allegheny chinkapin, has entered my plant life since moving south and makes, as I have seen it, a small shrub that could be used for naturalizing and providing food for wildlife. The great drawback of Allegheny chinkapin is its small nut size and the added disadvantage that many nuts stick fast in the bur at harvest and have to be removed by force. Because these nuts are small, are difficult to harvest and can germinate before harvest time, they have limited potential as a commercial crop. Good news is that the trees small size, precocity, and heavy production may be useful characteristics to breed into the commercial chestnut species. The chinkapin is adapted to a wide range of soils and site conditions and should be considered for its wildlife value. The nuts are eaten by a number of small mammals such as squirrels, rabbits, deermice, and chipmunks. By cutting the stem at the ground surface, dense thickets can be established within a few years to provide food and cover for wildlife, especially grouse, bobwhite, and wild turkey.

Using PHP to Display Random Quotes

Using PHP to Display Random Quotes One way to add a random quote to your website is to use the PHP switch () statement. The switch statement compares one variable with many values and executes one piece of code depending on the value it equals. This allows you to prepare a list of quotations and then use the rand () function to select a number randomly that corresponds to one of the quotations.   Using Switch to Display Random Quotes This example code demonstrates how to use switch () to display a random quote on your website. Each of the sample quotes is set to run when  its number is chosen. By using rand () to choose a random number, one of the quotes is displayed at random. This example accommodates only six quotations, hence the rand (1,6) entry.   } ? To add more quotes, you change the rand () function to allow for higher numbers and then add in their corresponding cases in the code. If you want to include a random quote on your PHP web page, use include () to pull the quote from this file, like this: INCLUDE yoursite.com/path/to/quote_file.php

Ass4 Coursework Example | Topics and Well Written Essays - 250 words

Ass4 - Coursework Example This mountain later came to be known as â€Å"Mount Kailash†. To some people, the similarity between Mount Meru and Mount Kailash has a spiritual aspect. Shiva Samhita says that their lies a Mount Meru in one’s body and only a true yogi can identify it. Certain religious pilgrims, who visit Mount Kailash, view it as a spiritual, and not a cosmological centre. A ‘kora’ is a religious practice in Tibetan. In this practice, one has to go around Mount Kailash to wash your sins and to gain enlightenment. Hence, the word pilgrimage, ‘nekorwa’, in Tibetan, means ‘making circles about holy places’. Various different ways of doing a ‘kora’ are adopted. Some people sponsor a ‘kora’ for the person who actually travels around Kailash and the blessings of this act are shared by both. Some people may complete the ‘kora’ in a day. But to gain enlightenment, you must be, spiritually, in contact with God. Answer- Hindus believe that the act of completely immersing oneself in Lake Manasarovar leads to one’s incarnation as God. Tibetans, on other hand, do not bathe in Lake Manasarovar because they do not like to dirty the holy water. Dolma La is the highest point in Kailash kora. Along the path to Dolma La, stones are stacked by pilgrims. These stones represent Mount Kailash. ‘Dolma’ is said to be the one who guided the first person to reach Dolma La. A boulder is worshipped at the place where she

W5Security Essay Example | Topics and Well Written Essays - 1250 words

W5Security - Essay Example Modern technology poses a threat in terms of ease of access to data and information which is exchanged over the Internet, which can compromise the privacy of both individuals as well as confidential information pertaining to business activities (Laudon & Laudon, 1999). Privacy is the freedom individuals have to be left alone both at home and at work, free from observation or intrusion by other individuals or the State, or in the case of organizations, from the State and unauthorized sources. Information technology and systems threaten individual rights to privacy by making the intrusion into privacy inexpensive, cost-effective, and efficient (Laudon & Laudon, 1999). Organizational information security strategies, measures, and standards are entirely significant reflections. An organization must take care to devise and put into practice a successful information safety plan, that can cover every phase of available information. Each category of such information safety serves a diverse function. The W5-Data Security Policy incorporates the following main points regarding the organizational data (W5-data security Policy, 2009) Security risk: Consumer based applications such as Internet sales and call center programs pose a security risk to data at its collection point, because they can be tapped by unauthorized sources.(www.protegrity.com). The data and information security risk can be illustrated as the intensity of its effect on organization activities (including operational jobs, illustrations, or status), organization assets, or on individual and/or financial information collected during the process of entering into business information arrangements. The security of data may also be compromised during the process of its use, such as for example through actual theft or hacking into data as well as insider theft, all of which pose a hazard (Rebecca, 2007). The above section has presented the possible hazards in a business situation. Such

Women, Health, and the Environment Essay Example for Free

Women, Health, and the Environment Essay -These three words together speak to a web of issues and concerns that challenges us to think outside the proverbial box and silos that keep us narrowly focused and divided. We must think and act from a holistic perspective if we are ever to reverse the environmental degradation and social inequalities on the planet and create environmentally sustainable, economically viable, and socially equitable gender-sensitive societies. A discussion of women’s health and the environment must also include issues of poverty, hunger, food, security, racism, water, sanitation, agriculture, trade, energy, species extinction, biodiversity and climate change. Our agenda for women’s health and environment must also address access and right to live with dignity, sustainable livelihoods, shelter, education for girls, political power and decision making, sexuality, and freedom from violence, conflict and war. Today many feminists believe we are in a third wave of feminism, one that challenges the idea if dualism itself while recognizing diversity, particularity, and embodiment. By theorizing from the notion of embodiment, recent iterations of feminism are beginning to reweave the specific duality between culture and nature, an especially important endeavor in these environmentally disturbing times. These feminisms, rather than working from established and usually abstract foundational theories, begin from the situated perspectives of different women. Beyond this general congruence, however, there are several different foci in the feminisms seen as third wave today. One of the most intractable problems facing environmentalists is how to address global environmental issues given the very different, often conflicting, ways that nature is valued within and across cultures. In many parts of the world, nature is valued as an exploitable resource that when used efficiently can raise standards of living, improve the quality of life, or increase the wealth of a select few. In other places, people believe that economic development efforts must be sustainable; promoting natural balance and improving living standards are values that can be achieved simultaneously. For many people, the value of global justice suggests that rich nations must do more to protect the global environment in order to allow for the legitimate improvement of the quality of life of the poor. To make things more complicated, there are additional values beyond the value of nature, and the value of justice. Ecofeminism, in the United States, originated during the second wave of feminism as women in the peace movement began to perceive the interrelationships of militarism, sexism, racism, classism and environmental damage. The theorizing of how this environmental damage was related to women’s oppression and the oppression of other people, together with theorizing form the perspectives of the women involved, including women in the so-called developing world, became evident during the time period seen as the emergence of third-wave feminism. Consider basic issue-women’s everyday living environments and women’s access to water and sanitation. Millions of poor women in urban and rural areas around the world do not have access to safe and affordable water or toilets. Unsafe water causes health problems such as diarrhea, schistosomiasis, trachoma, hepatitis, malaria and poisoning. The care of sick family members is usually the responsibility of women and takes time away from their income generating initiatives. To ill health, add the loss and suffering from the death of an estimated three million children a year from contaminated water-related diseases. In the rural area of Garla Mare, Romania, the majority of the water sources-the wells are contaminated with nitrates, chemicals, heavy metals and bacteria. Amongst other things, high nitrate levels in drinking water are linked to â€Å"blue baby disease† or acute infantile methaemoglobinaemia. Women in Romania along with Women in Europe for a Common Future (WECF) are working together to document sources of contaminated water, develop strategies to â€Å"clean† water with local authorities and run educational campaigns demonstrating the links between polluted water and ill-health (Merchant, 1980. Due to deforestration, the loss of vegetation, and the lack of toilets, rural women have to rise earlier and walk further to attend to their daily needs. In urban areas, slums often lack hygienic and secure toilets for women. Women and girls in many countries have been sexually and physically assaulted in the night when attempting to use the â€Å"outside,† or toilets that are too far from their homes. Women in the US are also organizing to question poor water quality as water supplies in many US cities and towns are contaminated with industrial and agricultural chemicals. Access to safe and affordable sanitation services is critical for women’s and girl’s dignity, health, and safety. Human-made chemicals and metals that are persistent, biomagnifying and endocrine disrupting such as atrazine, 2, 4-D, and lindane, have been used extensively in agriculture, industry, and the home and garden. Some of these chemicals are also called POPs (Persistent Organic Pollutants). They are the subjected of the United Nations Stockholm Convention for the protection of human health and the environment. These same chemicals are readily found in household sprays and cleaners, pesticides, herbicides, fungicides, insecticides, and in our food. Chemicals enter into natural systems and are having devastating impacts on wildlife. For example, there is evidence that some alligators, Western gulls, and Rainbow trout are developing rudimentary sexual organs, Western and Herring gulls are exhibiting mating behavior of both genders, frogs are being born with missing limbs and eyes, and Beluga whales are dying from immune suppression and cancer. Human beings are at the top of the food chain and health impacts similar to those on wildlife are being documented around the world. Widely documented are the health impacts on agricultural and horticultural workers, many of whom are poor women and children with limited options for other livelihoods. Lead, dioxins, DDT and PCB’s are found in women’s breast milk, from indigenous women in the Aral Sea region of Central Asia. Human exposure to these chemicals is linked to endocrine disruption, learning impairment and hyperactivity in children, as well as cleft lip and palate, spina bifida and limb anomalies. Environmental contamination has resulted in women in the North and in greater numbers in the South facing increased risks of fertility problems, spontaneous abortion and miscarriage, reproductive system abnormalities, immune system disorders and cancer. Breast cancer has become major women’s disease, transcending class, race, ethnicity, culture, sexual orientation and geographical location. The complexity of women’s sexual and reproductive health issues and illnesses underlines the need for women’s right to decision making and control of their sexuality, sexual and reproductive health, and their right to relevant services through the public health care system. While women are often dismissed from discussions on energy, it is a central issue concerning women’s quality of life. Poor women who use wood fuel and charcoal to cook indoors are exposed to poor air quality and an increased risk of severe respiratory problems. While nuclear proponents advertise nuclear energy as â€Å"clean† energy, they deliberately ignore the impacts of radiation and nuclear waste and the work of many women who have researched and critiqued the dangers of nuclear energy and weapons. Seventeen years after the Chernobyl nuclear disaster of 1986, medical research shows that 70% of pregnant women in the Ukraine have extra-genital and obstetrics disorders including anemia, late toxicosis, cardiovascular disorders and urogenital diseases (Merchant, 1980). Increases in the frequency and severity of floods and drought have been linked to changing global climate regimes. A recent study on the impact of floods on women and girls in Cambodia highlights a number of issues. These include an increase in food insecurity and loss of crops; fear of losing children to the floods; risk of drowning because women and girls are not taught to swim; disaster-related debt and the corresponding increase in workloads of women as men migrate to cities; and the resulting stress and fear of HIV and sexually transmitted infections brought back from men engaging with other partners in the cities. While the study did not document an increase in wife assault during the disaster period or after, it did identify that the fear of assault is a constant factor enmeshed in women’s daily life and an ever present threat that colours women’s actions and involvement in decision making. The lack of political will and commitment from many national governments and major international bodies, like the International Monetary Fund (IMF), have degraded natural environments and subjected women citizens to increasing poverty by a loss of livelihoods and a reduction in accessibility to health, education, and other basic services. Extensive research and documentation has demonstrated the negative economic and social impacts of programs like the structural adjustment programmes o the IMF on African women. Another approach advocated by feminists such as Shulamith Firestone is the liberation of women through reproductive technology. This approach includes a spectrum of possibilities that would give women the right to choose when and if they wish to bear and raise children: male and female contraceptive devices, voluntary vasectomies and tubal ligations, amniocentesis and genetic counseling an, ultimately, test-tube reproduction and cloning. Science and technology are here viewed as potentially liberating and progressive, yet these approaches also raise a host of difficult ethical questions about the nature of control over life itself. For example, amniocentesis allows the woman to know the sex of her unborn child and thus to decide whether or not to abort the fetus. If through contraceptive and genetic technology families decide to have one or two children and to make the first child a male, then an increase in the proportion of males in society could result. If the psychological approach to the woman-nature question is valid, and if trust children tend to be more highly motivated, aggressive, and domineering than second children, then the outcome could be an increase in dominating males, with negative implications for women and nature. For many women who have become aware of environmental hazards and nuclear technologies through environmentalism and have become conscious of sexism through feminism, the appropriate technology movement presents an appealing alternative. Here the hands on skills necessary for personal survival and control over one’s own life are revered, and low-environmental-impact technologies are the movement’s hallmarks. Women involved in the appropriate technology movement, however, find great satisfaction in building bridges, solar collectors, greenhouses, and doing home repairs themselves, without resorting to high-cost contractors. Carpentry and plumbing skills taught to groups of women by other women rather than male â€Å"experts† are popular forms of education. The social economic analysis of the woman-nature question accepts many of the insights of the foregoing feminists but is critical of the idea of universal sex oppression and of the dichotomies â€Å"public-private† and â€Å"self-other† as explanatory categories. Rather than postulating a separate sex/gender system as the framework of analysis, this approach examines the historical context of male and female gender roles in different systems of economic production. The simultaneous emergence of the womens and environmental movements over the past two decades raises additional questions about the relationships between feminism and ecology. The structures and functions of the natural world and of human society interact through a language common to both. Ethics in the form of description, symbol, religion, and myth help to mediate between humans and their world. Choices are implied in the words used to describe nature: choices of ways in which to view the world and ethical choices that influence human behavior toward it. Ecology and feminism have interacting languages that imply certain common policy goals. These linkages might be described as follows: 1. All parts of a system have equal value. Ecology assigns equal importance to all organic and inorganic components in the structure of an ecosystem. Healthy air, water, and soil-the abiotic components of the system-are essential as the entire diverse range of biotic parts-plants, animals, and bacteria and fungi. Without each element in the structure, the system as a whole cannot function properly. Remove an element, reduce the number of individuals or species, and erratic oscillations may appear in the larger system. Similarly, feminism asserts the equality of men and women. Intellectual differences are human differences rather than gender-or race-specific. The lower position of women stems from culture rather than nature. Thus policy goals should be directed toward achieving educational, economic, and political equity for all. Ecologists and feminists alike will therefore assign value to all parts of the human-nature system and take care to examine the long and short range consequences of decisions affecting an individual, group, or species. In cases of ethical conflict, each case must be discussed from the perspective of the interconnectedness of all parts and the good of the whole. 2. The earth is a home. The Earth is a habitat for living organisms; houses are habitats for groups of humans. Each ecological niche is a position in a community, a hole in the energy continuum through which materials and energy enters and leaves. Ecology is the study of the Earths household. Human houses whether sod houses, igloos, or bungalows, are structures in an environment. Most are places wherein life is sustained-shelters where food is prepared, clothes are repaired, and human beings cared for. For ecologists and feminists the Earths house and the human house are habitats to be cherished. Energy flows in and out; molecules and atoms enter and leave. Some chemicals and forms of energy are life-sustaining; others are life-defeating. Those that lead to sickness on the planet or in the home cannot be tolerated. Radioactive wastes or potential radioactive hazards are present in some peoples environments. Hazardous chemicals permeate some backyards and basements. Microwaves, nitrite preservatives, and cleaning chemicals have invaded the kitchen. The home, where in fact women and children spend much of their time, is no longer a haven. The soil; over which the house is built or the rocks used in its construction may emit radon, potentially a source of lung cancer. The walls, furniture, floor coverings, and insulation may contain urea formaldehyde, a nasal, throat, and eye irritant. Leaky gas stoves and furnaces can produce nitrogen dioxide and carbon monoxide, resulting in nausea, headaches, and respiratory illnesses. An underground garage in an apartment building can be an additional source of indoor carbon monoxide. The homes faucets may be piping in carcinogenic drinking water, formed by the action of chlorine on organic compounds in reservoir supplies. Disinfectants sprayed where people eat or children play may contain phenols, aerosols, or ammonium chlorides that can produce toxic effects on the lungs, liver, and kidneys, or act as nervous system depressants. Over cleaners may contain caustic alkalis. The bathroom and bedroom any feature cosmetics and shampoos that can produce headaches, eye-make up contaminated by bacteria and fungi, deodorants laced with hexachlorophene and hair dyes containing aromatic amines that have been linked to cancer. The kitchen may have microwave oven and the living room a color television emitting low-level radiation when in use. The refrigerator may be stocked with food containing nitrite preservatives, food dyes, and saccharin-filled ‘low-cal’ drinks suspected as potential carcinogens. In the cupboards pewter pitchers or dishes containing lead glazes can slowly contribute to lead poisoning, especially when in contact with acidic foods. The indoor atmosphere may be filled with cigarette, cigar, or tobacco smoke, containing particles that remain in the air and accumulate even in the lungs of non-smokers. For ecologists and feminists alike, the goal must be the reversal of these life-defeating intrusions and the restoration of healthy indoor and outdoor environments. 3. Process is primary. The first law of thermodynamics, which also the first law of ecology, asserts the conservation of energy in an ecosystem as energy is changed and exchanged in its continual flow through the interconnected parts. The total amount of energy entering and leaving the Earth is the same. The science of ecology studies the energy flow through the system of living and non-living parts on the Earth. All components are parts of a steady-state process of growth and development, death, and decay. The world is active and dynamic; its natural processes are cyclical, balanced by cybernetic, stabilizing, feedback mechanisms. The stress on dynamic processes in nature has implications for change and process in human societies. The exchange and flow of information through the human community is the basis for decision making. Open discussion of all alternatives in which ecologists and technologists, lawyers and workers, women and men participate as equals is an appropriate goal for both environmentalists and feminists. Each individual has experience and knowledge that is of value to the human-nature community. 4. There is no free lunch. â€Å"No free lunch† is the essence of the laws of thermodynamics. To produce organized matter, energy in the form of work is needed. But each step up the ladder of organized life, each material object produced, each commodity manufactured increases entropy in its surroundings, and hence increases the reservoir of energy unavailable for work. Although underpaid environmentalists are said to accept free lunches, nature cannot continue to provide free goods and services for profit-hungry humans, because the ultimate costs are too great. Thus, whenever and wherever possible, that which is taken from nature must be given back through the recycling of goods and the sharing of services. For feminists, reciprocity and cooperation rather than free lunches and household services are a desirable goal. Housewives frequently spend much of their waking time struggling t undo the effects of the second law of thermodynamics. Continually trying to create order out of disorder is energy consumptive and spiritually costly. Thus the dualism of separate public and private spheres should be severed and male and female roles in both the household and the workplace merged. Cooperation between men and women in each specific context-childrearing, day-care centers, household work, productive work, sexual relations, etc. -rather than separate gender roles could create emotional rewards. Men and women would engage together in the production of commodities that are costly to nature. Technologies appropriate to the task, technologies having a low impact on the environment, would be chosen whenever possible. Resistance to a feminist-environmental coalition comes form both movements. Environmental coalition comes from both movements. Environmentalists react negatively to the intrusion of feminist’s issues that seem to them to muddy and complicate an already difficult struggle. At anti-nuclear rallies and solar technology conferences, the presence of lesbian feminists challenging male control of technology may seem particularly galling. Increasingly, in countries of the South and North, many governments are failing to defend and enhance women’s hard earned rights to live free of violence from either family members or the State, and to have right and access to health services, as well as specific programmes to address gender concerns as in the case of the HIV/AIDS pandemic. For poor rural women, government supported privatization of common property resources such as forests, wetlands, fallow fields, pasturelands, etc. make it nearly impossible to maintain precarious levels of substinence living; thus, further marginalizing those women who rely on common property resources for food, fodder and raw materials. Moreover, many of these groups establish ritual behaviors that maintain steady-state equilibrium between population and resources. Here nature and culture are not separated dichotomies in which nature is devalued and culture elevated. The nonhuman world is alive, sensitive, intelligent, and on a par with the human portion. In some cultures animals are members of separate societies governed by special spirits; particular rocks and trees are sacred; and the Earth is a living nurturing mother. Women and men perform different tasks and have different roles, but each is essential to the survival of the group as a whole and neither is devalued. The society is geared to the production of use values as the material basis for sustaining life. Like postcolonial and generational/youth cultures, feminism’s growing interest in ecofeminism has been evident in the last several years. Some ecofeminists, however, posit that, as a term, â€Å"ecofeminism† informally appeared, here and there, worldwide, in the 1970’s, usually as a response to so-called development activities. The Chipko Movement, the movement that began when village women of Himalayan India organized in the 1970’s to protect their forests, as described by their country woman, Vandana Shiva, and noted above, is most often specifically cited as the beginning of ecofeminism. In the West, an ecofeminist focus in activism emerged during the second wave of the women’s movement and was predicated on seeing the relations between militarism, sexism, racism, classism, and environmental damage. By the middle 190’s, many women, committed to direct action against militarism, started naming themselves ecofeminists to depict the interdependencies of their political concerns. As ecofeminism evolved, it took up additional issues such as toxic waste, deforestation, military and nuclear weapons policies, reproductive rights and technologies, animal liberation, and domestic and international agricultural development, in its efforts to reweave the nature/culture dualism. Ecofeminism is distinct, however, in its insistence that nonhuman nature is a feminist concern. Ecofeminist theory utilizes principles from both ecology and feminism to inform its political organizing and its efforts to create equitable and environmentally sound lifestyles. From ecology, it learns to value the interdependence and diversity of all life forms; from feminism, it against the insights of a social analysis of women’s oppression that intersects with other oppressions such s racism, colonialism, classism, and heterosexism. Ecofeminism, in its use of ecology as a model for human behavior, suggests that we act out of recognition of our interdependency with others, all others: human and nonhuman. Ecofeminist politics embrace heterogenous strategies and solutions. Ecofeminists do share a broad vision of a society beyond militarism, hierarchy, and the destruction of nature, but like feminism itself, they often have different analyses and strategies for achieving them. In many ways, an ecofeminist style of politics the notion of â€Å"local resistance† against power relations. Ecofeminists understand power as â€Å"multiplicity of force relations† that are not centered, but are diverse and are constantly being reproduced. While ecofeminsm emphasizes local activism, it also maintains the importance of a global perspective. In ecofeminism, where everything is seen as interconnected and/or interdependent, there is a serious regard for women whose cultures and geographic locations are being foisted croded as a result of so-called development projects that are being foisted on the third world. Ecofeminists challenge the relationship between economic growth and exploitation of the natural environment, and as noted above, ecofeminist anthologies contain work by and about women resisting ill-conceived development projects in the third world, in addition to those in the West. The relation of ecofeminism theory to political activism is ideally informative and generative, not perspective. The activism that is undertaken is a result of the individuals who are involved reflecting on an actual problematic situation or issue. Because of ecofeminism recognizes that sexism, racism, classism, heterosexism, speciesism, and naturalism are mutually reinforcing systems of oppression, the work o end any oppression is valuable. Using ecology as a model for understanding these interdependencies and the value of diversity enables ecofeminists to include many kinds of political action. Ecofeminist theory, in turn is expanded by focusing on the actual activities, as articulated by the embodied voices of the participants. Social justice cannot be achieved apart from the well-being of the Earth. Human life is dependent on the Earth; our fates are intertwined. Ecofemism is spiritual, too, emphasizing that the Earth is sacred unto itself. And a strong recognition of the necessity of sustainability-a need to learn the many ways we can walk the fine line between using the Earth as resource while respecting the Earth’s need. One of the main endeavors of ecofeminism, in its efforts to reweave the nature/culture duality, is to understand the ideology that perpetuates the domination of women, other humans, and nonhuman nature. There are many approaches taken by ecofeminists who are engaged in analyzing how the subjugation of women, other suppressed people and nature are interconnected. Karen Warren (2000), writing 10 years after the Diamond and Orenstein anthology, in her work Ecofeminist Philosophy: A Western Perspective on What It Is and Why It Matters, discerns 10 directions ecofeminists take to theorize these interconnected subjugations. Warren terms these various approaches: historical and causal, conceptual, empirical, socioeconomic, linguistic, symbolic and literary, spiritual and religious, epistemological, ethical, and political. Feminist who take the historical and causal approach to explain the interconnected subjugations of women, other suppressed people, and nature, suggests that the ubiquitous ness of androcentrism with its accompanying phenomenon, the patriarchal domination of women and nature, is the source of environmental degradation. Riane Eisler and Carolyn Merchant are examples of feminists who present varying accounts of this approach. They explain how and approximately when societies that previously had been living essentially in concord with nature and with each other became subjugated by patriarchal domination. Societies, in these accounts, then become disharmonious in their relationships. A second approach some ecofeminists take to understand the ideology that perpetuates domination is an analysis of conceptual frameworks that have functioned historically to perpetuate and justify the dominations of interconnected subjugations. Conceptual frameworks function as socially constructed lenses through which one perceives reality. These conceptual works can be oppressive because of the part plated by rationalism in the domination of women and nonhuman nature illustrates. Rationalism explains how structures of domination are based â€Å"in hierarchically organized value dualism and an exaggerated focus on reason and rationality divorced form the realm of the body, nature, and the physical† (Warren 2004, p. 24). Warren, she, makes similar conceptual connections. She locates these connections in an oppressive patriarchal conceptual connection. She locates these connections in an oppressive patriarchal conceptual framework, mediated by what she calls â€Å"a logic domination. † This â€Å"logic† provides the moral premise for domination/subordination relationships based on socially constructed dualistic notions of superiority/inferiority. Empirical interconnections are made by ecofeminists who use verifiable evidence to document the tie-in among dominations. Using this kind of data, they are able to illustrate, for example, that subordinate groups suffer disproportionately form industrial environmental pollutants. Coinciding with postcolonial feminism, some ecofeminists using the empirical interconnections approach, furnish data to show how women’s inability to provide adequate sustenance for themselves and their families is caused by first-world development policies such as those destroying subsistence agriculture and/or the productivity of the land. Nature like women’s bodies and labor is colonized by the inter-workings of capitalism and patriarchy in first-world development. Some ecofeminists, who follow the concept formation that is strongly influenced by language, make linguistic interconnections to explain subjugation. They maintain that language is pivotal in maintaining mutually reinforcing sexist, racist, and naturist views of women, people of color, and nonhuman nature. They call our attention to the considerable extent that Euro-American language contains illustrations of sexist-naturist language depicting women, animals, and nonhuman nature as having less value than men. Related to this approach is the ecofeminist animal welfare â€Å"analysis that the oppression of nonhuman animals, is based on a variety of women-animal connections: for example, sexist-naturalist language, images of women and animals as consumable objects, pornographic representations of women as meat, male perpetuated violence against women and nonhuman animals,† (Warren 2000, p. 126). Another method-that of making symbolic and literary interconnections-is seen in a new genre of literary analysis: ecofeminist literary criticism. This genre has emerged as a way to appraise literature according to criteria of ecological and feminist values. Ecofeminists using this approach, maintain that the literary canon needs to be reconsidered to include a de-homocentric approach. Ecofeminist theologians work to make spiritual and religious interconnections to explain subjugation. They discern most ancient religious myths basic to Judeo-Christian and Western traditions as ones justifying a social structure that exalts ruling-class men while denigrating others, including nonhuman nature. What many of these ecofeminist theologians subsequently have to consider is whether these religions can be reformed or if new religions, myths, and spiritual practices are needed. Some Ecofeminist working with spiritual and religious interconnections, see women’s spirituality as political. They believe â€Å"the preservation of the Earth will require profound shift in consciousness, a recovery of a more ancient and traditional view that reveres the profound connection of all beings in the web of life and a rethinking of the relation of both humanity and divinity in nature (Warren 2000, p. 32). The notion of â€Å"the Goddess† is also invoked by many spiritual ecofeminists to express the veneration both nonhuman nature and the human body merit. Warren further notes that knowledge and knowledge creation is studied by ecofeminists who work to make epistemological interconnections. Like postcolonial feminism, they challenge the Western view that knowledge is objective. Warren is also discusses the ethical interconnection approach made by ecofeminist philosophers who hold that a feminist ethical analysis and response is needed to show how subjugation of women, other â€Å"others† and nonhuman nature is interlinked. â€Å"Minimally, the goal of ecofeminist environmental ethics is to develop theories and practices concerning humans and the natural environment that are not male-biased and that provide a guide to action in the prefiminist present,† (Warren 20007, p. 37). Making political interconnections is integral to ecofeminism, which has always been a grassroots political movement, motivated by pressing pragmatic concerns (Warren 2000, p. 35). In addition to women’s activism to sustain their families and communities, the relationship of environmental and women’s health to science and development projects, animal rights, and peace activism are examples of issues that