Tuesday, August 6, 2019
Grant Proposal Essay Example for Free
Grant Proposal Essay There are many steps to writing a grant proposal and itââ¬â¢s has to be written very well with all the grammar and spelling done correctly. You have to have a Request for Proposal this is a notice to the public will be generally be distributed and applicant agencies usually have 6 to 8 weeks to respond to the request for proposal. Then you have the Abstract which is the summary and its 45 single space lines. Table of Content which is the road map for the reader to understand the structure of the applicant proposal. Specific Aims/background and significance this is the present the rational and basis for the development. Needs and Problem Statement this is where they show the urgency of the problem. Target Population is where they are target the population that needs the most help. Approaches and Method is kind of like the elder lady would say whereââ¬â¢s the beef. Long- and short-term goals can be anything form the vision to mission, goals, objectives, and the activities is term that proposal writers program. Process, outcome, and impact objectives this is where they will show the objectives and the outcome of the proposal. Activities plans and scheduling which is the same as the timeline for everything taking place. Evaluation plan. This is where they assesses the achievement of a specific program. Agency Capacity and Project Management this is the creditability of the agency which is the same as with us in trying to get a credit card. Budget and budget Justifications this is where they are going to try to get the funding besides the grants. The purpose of a grant proposal is so that the human service can get the grant needed to help the community. The grant proposal and program plan help each other and as close to being the same.
Monday, August 5, 2019
Person Centred Mental Health Care for Schizophrenia
Person Centred Mental Health Care for Schizophrenia Person Centred Mental Health Care Disha Gupta References Essay: Ben is a 22 year old male who has been admitted to the acute in patient unit as a compulsory client under the Victorian Mental health Act (2014) who has a diagnosis of schizophrenia. Question When using recent research evidence please addresses the following; Identify the rationale and discuss strategies the mental health nurse will use to actively involve Ben and his carers when using the shared decision making process. (While in the acute mental health setting) AND Discuss strategies the mental health nurse, Ben and his carers can utilise to reduce his incidence of relapse in schizophrenia. Ben is a young adult suffering from schizophrenia that has been brought into an acute as an in-patient unit due to his psychotic behaviour. According to recent change in Victorian Mental Health Act a shared decision making process model which is being utilized within the practice in order for better outcomes. Shared decision making process is where two experts or a team of experts come together in making complex decisions for a patient (Chong WW, 2013). A set of health care providers come together and expand their knowledge and bring expertise in understanding the medical problem in order to provide a diagnosis. As well as the possible interventions and the possible risks of alternatives and potential benefits those are involved with the presented client. (REF). In this case we have Ben who has been ââ¬Å"compulsoryâ⬠admitted into an acute setting, which means this client is in need of serious treatment, which is why the shared decision making process has been put in place in order to achieve the right and hopefully an accurate treatment that works as it engages experts to be involved throughout the process. Not only a team of experts are involved in this process but, the individual is given the chance to put their values, understandings and preferences forward as well along with the support of family and other support network members (REF). This allows them to feel less inclined to thinking towards that they are being forced into something without their consent. As this gives them an opportunity to explore their wants and needs and together the individual and health care providers can come sometimes to a mutually agreed plan that is right for client. In order to plan and look after twenty two year Ben who is currently suffering from mental disorder we must first understand the problem followed by the treatment or action plan. Schizophrenia is an extremely complex disorder, it is occurred due to the imbalances of biochemical present in the brain which causes a person to believe in extraordinary and distorted thoughts, perceptions, emotions, movements and behaviour (REF). The symptoms of schizophrenia are categorized into two major categories, the positive or hard symptoms which include delusion, hallucinations, and grossly disorganized thinking, speech, and behaviour, and negative or soft symptoms as flat affect, lack of volition, and social withdrawal or discomfort (REF). This way it is easier for the health care providers to take further steps for a clients treatment as they have categories which clients fit into. In order for treatment or a plan to commence the nurse should start the process with a Two way exchange of information which allows the nurse (Clinician) to discuss the suitable treatment options and also any potential risks and benefits which may arise from these options and at the same time it will provide an opportunity to Ben to discuss his values and preferences regarding the treatment plan (REF). The two way communication will help to create a bond between the nurse and Ben which will help the nurse to know more about what Ben wants and this can help the nurse to reassure Ben in times of uncertainty, anxiety or vulnerability (REF). There is a strong need to develop an action plan for the treatment option to be executed and measured. An action plan is a document which is will be designed together by Ben and the mental health nurse and this plan should cover the issues being faced by Ben, the interventions which will be put in place and a review system to check the success of the action plan (REF).The plan should provide information about the Bens history, routines or symptoms that may assist in the treatment. Along documentations and communication there are other treatments also available such as medication. Antipsychotic medication treatment, Medication is one of the core foundations of treatment. Once the acute stage of a psychotic episode has passed, most people with schizophrenia will need to take medicine until further notice or until improved conditions where patients are not relied upon these mediations (REF). Antipsychotic medication is used to control the acute symptoms being experienced by the patient. These falls into two groups: typical and atypical antipsychotics (REF). Typical antipsychotics target the more obvious symptoms such as hallucinations and delusions. They work by reducing the disturbing quality of the symptoms and accompanying disruptive behaviour occurred due to imbalances in the brain (REF). In this plan a nurse needs to understand which antipsychotic medications need to be given and what their actions and adverse side effects are. The nurse should never forget to follow the eight rights of drug administration (REF). This step is vital for a mental health nurse because the way each medication is administered will differ between patients. Antipsychotic drugs, like almost all medications, have unwanted effects along with their advantageous effects. During the early phases of drug treatment, patients may be troubled by side effects such as drowsiness, restlessness, not able to keep the body still, muscle spasms, tremor, shaking, dry mouth, or blurring of vision (REF). Most of these can be corrected by lowering the dosage or can be controlled by other medications. Different patients have different treatment responses and side effects to various antipsychotic drugs. As mentioned before a patient may do better with one drug than another. Since Ben is in an acute phase of a schizophrenic episode first and foremost role of a nurse is to perform a mental health assessment or examination. A mental health nurse needs to perform and present symptoms and the level of risk that may cause to the patient and other people around (REF). In order to understand a personââ¬â¢s mental health situation, there are guidelines an clinician or a mental health care provider needs to follow. One of many assessment tools includes ââ¬Å"PAMSGOTJIMIâ⬠, abbreviation of: Perception, Affect, Mood, Speech, General Behaviour, Orientation, Thought, Judgment, Insight, Memory, and Intelligence. Or even ââ¬Å"ABCTâ⬠, abbreviated for Appearance, Behaviour, Cognition and Thought process (REF). Are great for mental health assessment of a client which needs to undergo a treatment plan, by following these guidelines a nurse can understand and develop a better understanding of a clientââ¬â¢s current situation in order to create the right p lan. A compliant cycle of antipsychotic medications plays an important part in the treatment of schizophrenia and at the same time non-compliance with the medications can result in relapse. This is why along side of Antipsychotic medications is the need for social interventions, including education and support for patients and carers, so that cares and individuals are on the same pages of understanding one another better. Social skills training and the care provided by day hospitals and centres such as community based voluntary and involuntary services etc (REF). Cognitive behavioural therapy (CBT) can help patients gain a degree of control over their symptoms as this helps them by understanding the links between their thought processes and subsequent behaviour. Which then helps them to move on and look at ways of changing and managing their thoughts and behaviours (REF). Family interventions largely help in reducing levels of stress and in the management of contributing factors to patient relapse (REF). As we know our families are the closest people we have got in our lives, which in return gives the individuals a sense of security and makes them feel secure by having family help them through tough time gives them the hope and strength to improve their wellbeing. Giving carers information about schizophrenia is helpful in its management. Support and information needs to be ongoing, both in everyday situations and also at times of crisis (REF). As mentioned before, carers and families have always played an important role in the management of people with very serious mental disorders. With the increasing focus on maintaining patients in the community as well as in acute settings, these roles are assuming to achieve high importance. This means that Benââ¬â¢s carersââ¬â¢ needs and concerns require are most likely to be on a higher level of attention. In order to achieve and target the correct procedure, there are a few simple actions that can be taken for instance, a need for further and ongoing education on schizophrenia for Ben and its management and interventions as a carer or family needs to be informed about in order to look out for in various situations (REF). Regular contact with clinical teams that offers both support and advice about the patient and is responsive to carers concerns (REF). Also a faculty or services of support for carers, as they can possibly go through their own feelings such as emotional burden because they feel that its an extra responsibility to look after a mentally challenged person. Guilt and frustration is also another where the carer or family feels that nothing is working and may feel like giving up. Such services can be provided through support groups or individually. Also there is a need for a service that works in partnership with the carers and patients both, and through this way, it will be optimising the patients care and allowing patients to continue living in the community (REF). Anyone undergoing an illness is not one of the greatest feelings to be going through, which is why it is very important to understand the cause, and the reasoning behind the problem. Followed by an thorough assessment by the right health care providers. As well as having solid treatment plan with goals those need to be achieved by the end of it all. Ben is young and by having support around him, from family and friends and services provided by hospitals or community facilities is the right way to improve his mental wellbeing. With the right techniques and action plans clients like Ben can rapidly improve their mental and physical wellbeing, and as a nurse, itââ¬â¢s very important to understand the basic needs and requirements of each client and the correct form of assessment is highly necessary in order to keep a record of each patients history of improvements and development.
Evaluation of Public Health Agenda in Community: Obesity
Evaluation of Public Health Agenda in Community: Obesity Module Title: Promoting the Public Health of Populations in Specialist Community Public Health Nursing Module Code: SHN3048 Critical evaluation of the current public health agenda in relation to a health need identified within a community profile. The purpose of this assignment is to critically analyse the current public health agenda in relation to a health need identified through use of community profiling. This paper will aim to provide recommendations as to how a Specialist Community Public Health Nurse (SCPHN) can proactively address high levels of obesity identified within the Cwmbwrla ward (Appendix 1). For the benefit of the reader Cwmbwrla is a suburban area of Swansea, with good transport links to the city centre. In considering the level of deprivation Cwmbwrla is ranked 181 0f 1,909 (LSOA) in Wales (Welsh Government, 2014a). Public health in the 21st century is defined by Riegelman (2010 p4) as the totality of all evidence-based public and private efforts that preserve and prolong health and prevent disease, disability and death thus, recognising public health as a varied approach which should be viewed holistically. Health visitors are a group of specialist community public health nurses (SCPHN), skilled in delivering a proactive Public health service which relies on evidence base research to enhance health and reduce inequalities for all families with children 0-5 (Royal College of Nursing, 2011; The National Institute for Health and Care Excellence (NICE) 2014). The current Public Health strategy in Wales aims to achieve a healthier, happier and fairer Wales, through improving health, reducing inequalities and supporting a good start in life (Public Health Wales (PHW), 2015; Welsh Assembly Government (WAG), 2010; WAG, 2011a; Welsh Government (WG), 2016). There is consistent evidence which suggests investment in the early years significantly improves the health of the child and has a positive impact on long term outcomes (Acheson,1998; Black,1980; Marmot, 2010). As a result of the reaffirmation of the public health role of the SCPHN in recent policy, it is believed that the health visitor is st rategically placed to empower individuals and positively influence the health outcomes of young children and their families (Department of Health (DoH), 2011; WG, 2012a). The four domains of SCPHN practice begin with Search for health needs (Cowley Frost, 2006), thus requiring health visitors to undertake an assessment of the populations health and well-being. A key part of this process is health needs assessment (HNA) (Nursing and midwifery Council, 2010).Ãâà In defining HNA, Stewart et al, (2009) suggests the purpose is to identify the health assets and need of a population in order to inform decisions regarding service delivery to improve health and reduce inequalities. Through use of HNA policies are developed and needs are prioritized across services, with the aim of targeting those in greatest need (Williams, 2013). Statistics from the profiled area of the Cwmbwrla ward (Appendix 1), identify high levels of obesity in adulthood as being a significant problem. Despite there being no local data to highlight the levels of childhood obesity specifically within the ward, research suggests a strong link between childhood obesity and obesity in later life (NHS, 2015). Findings from the child measurement program 2014-2015, recorded that 11.8% of 4-5 year olds in Swansea were obese (Public Health Wales Observatory, 2016), a trend mirrored throughout Wales, with findings from the Welsh health Survey (2011) identifying that 35% of children living in Wales were classed as overweight or obese. Obesity has fast become a global epidemic (World Health Organisation (WHO), 2003; 2016), with research suggesting that obesity is the worlds most common nutritional disorder (NICE, 2014). The 2007 Foresight report emphasized the need to tackle the problem of obesity in the United Kingdom, particularly in childhood. The prevalence of obesity in infants, children and adolescents is increasing rapidly both nationally, and internationally, which has a significant impact on both short and long term health (Hall et al, 2009; WHO, 2016 ). Exploration of the literature suggests that there are many risk factors associated with becoming overweight, with the key principles leading to obesity being laid down in childhood (WAG, 2010). Wanless (2004) and Jones et al (2005) identified that during the period of 1986-2002 weight gain in children translated to a doubling in the proportion of those classified obese.Ãâà Childhood obesity is becoming evident in younger ages, with studies documentin g a sizable increase in the percentage of overweight children between the ages of two and three years (Hall et al, 2009; Nelson, 2004). Studies linking overweight to psychological consequences show that obese children tend to have low self-esteem, increased rates of sadness, loneliness and are often bullied and socially excluded outside the home (Strauss,2000). Promoting healthy weight and preventing and managing obesity have become pressing public health priorities over recent years (Phillips et al 2011). The effects of addressing obesity in early childhood are not solely limited to its health benefits; improvements in the rates of obesity could potentially save the NHS millions. In Wales alone it is estimated that between 1.65 million a week is spent treating conditions linked to Obesity (PHW, 2016). Despite obesity being at the forefront of the Public health agenda within the UK, progress in tackling childhood obesity has been slow and inconsistent, with a clear lack of provision identified as a problem within Wales (WAG, 2010; WHO, 2016). It has long been recognized that socioeconomic class has a significant impact on health inequalities, with those living in the most deprived areas more at risk of becoming overweight or obese (Acheson, 1998; Black, 1980). This is of particular relevance to the Cwmbwrla ward (APPENDIX 1), which falls within the 20% most deprived areas within Wales (WG, 2014). NICE (2014) supports this, with statistics indicating that 29% of children living in the most deprived areas of Wales being overweight or obese compared to 21% in the least deprived areas. More recent findings have suggested that, despite improvements in the overall health of the general population, there continues to be significant gaps between the social classes (Dahlgren and Whitehead, 1991; Marmot, 2010). These differences have been tackled within Welsh Government policy, which aimed to target the most deprived areas of Wales, through the delivery of the Flying Start program, which promotes health and delivers intensive servi ces in areas of greatest need (WAG, 2005, 2011a; WG, 2016). While such services must be applauded for their proactive approach, it must also be considered that as a consequence of this, the availability services relies heavily on postcode (WG, 2013), resulting in many families in need being unable to access necessary support. However, more recent WG policy has identified the need to tackle inequality, and improve health outcomes for all children, delivering support in key areas to all families with children under 7, underpinned by the principle of progressive universalism (HCWP, 2016). As previously identified, the determinants of obesity are complex and varied, it is important to recognise than no single intervention is likely to prevent or improve childhood obesity alone (WHO, 2012). Availability of data is important in planning services at a local level. Collaboration, leadership and quality improvement play a leading role within WG policy (PHW, 2013; WG, 2011, 2016). These policies emphasize the importance of adopting a muti-agency approach in addressing health needs, thus, identifying the need for SCPHN to support existing programs when planning health interventions to address obesity, with the aim of strengthening current initiatives and reducing the need for later more expensive treatments (NICE, 2013). The all wales obesity pathway supports this, and sets out a multi-agency approach in targeting obesity, allowing the identification of gaps in provision and the determination of where to best focus efforts (WAG, 2010). Over recent years, the WG have invested millions on strategies targeting obesity; for example, Free swimming programme (2003), Health Challenge Wales (2005), Creating an active Wales (2009), Mend (2009), and Our healthy future (2009), despite this the number of overweight children and adults continues to rise (Mc Pherson Marsh, 2007). Research suggests it Is highly likely that obese children will have obese parents, thus indicating the possible detrimental effects of learnt behaviours in childhood such as poor eating habits (NICE,2015). The literature emphasises the need for family involvement in interventions to ensure improvements in outcomes (Public Health England, 2014). There is emerging evidence that programmes that aim to enhance parenting skills can have a positive impact on childhood obesity (Berge Everts, 2011). Therefore, within the Cwmbwrla area, a recommendation would be to build community capacity for healthy eating by setting up a 4 week weaning programme. The programme would be available to families between the 16 week clinic contact and 24 week health review as per the HCWP (2016), and will deliver education and advice within a group setting. The programme will cover topics such as, delayed weaning, healthy eating in childhood, controlling portion size and how to quickly create cheap but nutritio us meals, with the aim of encouraging behaviour change using an educational approach (Naidoo Wills, 2016). The programme would aim to build upon existing initiatives such as Change 4 Life, which has previously been judged for not fulfilling its full potential (WAG, 2014). However,Ãâà it is important to consider that in the past, group programmes have been criticised for failing to involve individuals and communities who are hard to reach resulting in poor engagement (PHW, 2013). A further recommendation for the Cwmbwrla ward would be the provision of Increased/intensive home visits to specific families identified during the antenatal or birth visit as being at risk of overweight or obesity. Research has indicated a correlation between parenting lifestyle and that of their children in terms of diet and physical activity (Rhee, 2008). Arguably, the most effective strategy we can employ in tackling obesity in childhood is to work with parents (Golan, Kaufman Shahar, 2006).The aim is to focus on parents and support them to making positive choices that facilitate a healthy start in life. The additional visits will enable SCPHN to facilitate behaviour change by addressing key influences such as; positive parenting, feeding behaviour and food and activities accessible within the home, while also allowing the SCPHN the flexibility toÃâà tailor the program specifically to the needs of the individual family. It is imperative that SCPHN are mindful that there is no one correct parenting style, it is therefore important when delivering the program not to stereotype, but to encourage a generally more authoritative approach. Delivering the program within the home will aim to address the possible barriers families experience in accessing services (PHW, 2013). To conclude, this paper has evaluated the current public health agenda in relation to high levels of obesity identified within the Cwmbwla ward, a trend mirrored throughout the UK. Findings suggest that effort needs to be invested in preventing obesity, particularly in children; targeting early intervention and encouraging and educating families to adopt a healthy varied diet and active lifestyle (NICE, 2006, 2014). Through raising awareness, and by influencing local and national policies, SCPHN can facilitate ways to combat the problem of childhood obesity and seek to change the patterns which lead to obesity and poor health in later life (Cowley Frost, 2006; WG, 2014). As a result, recommendations for practice were identified for implementation within the profiled area of Cwmbwrla. The overall aim is for SCPHN to identify, address and facilitating families to overcome the current obesity epidemic, which could potentially result in a huge gain in terms of both cost to the NHS and more importantly the health of children and the adults they become (WG, 2015). Congestive Heart Failure: Causes, Types and Symptons Congestive Heart Failure: Causes, Types and Symptons Heart failure is caused by the heart not pumping as much blood as it should and the body does not get as much blood and oxygen that it needs. The malfunctioning of the heart chambers are due to damage caused by narrowed or blocked arteries leading to the muscle of your heart. This Heart failure can also be described based on which area of the heart isnt operating properly.2 types of heart failure. 1) Diastolic dysfunction: The contraction function is normal but theres impaired relaxation of the heart, impairing its ability to fill with blood causing the blood returning to the heart to accumulate in the lungs or veins. 2) Systolic dysfunction: The relaxing function is normal but theres impaired contraction of the heart causing the heart to pump pump out as much blood that is returned to it as normally does. As a result of more blood remaining in lower chambers of the heart Causes Any disorder that directly affects the heart can lead to heart failure, as can some disorders that indirectly affect the heart. Some disorders cause heart failure quickly; others do so only after many years. Some disorders cause systolic dysfunction, others cause diastolic dysfunction, and some disorders, such as high blood pressure and some heart valve disorders, can cause both types of dysfunction. Systolic Dysfunction: In many cases, a combination of factors results in heart failure. Coronary artery disease is a common cause of systolic dysfunction. It can impair large areas of heart muscle because it reduces the flow of oxygenirich blood to the heart muscle, which needs oxygen for normal contraction. Blockage of a coronary artery can cause a heart attack, which destroys an area of heart muscle. As a result, that area can no longer contract normally. Myocarditis (inflammation of heart muscle) caused by a bacterial, viral, or other infection can damage all or part of the heart muscle, impairing its pumping ability. Some drugs used to treat cancer and some toxins (such as alcohol) may also damage heart muscle. Some drugs, such as nonsteroidal antiiinflammatory drugs, may cause the body to retain fluid, which increases the workload of the heart and may precipitate heart failure. Heart valve disordersinarrowing (stenosis) of a valve, which hinders blood flow through the heart, or leakage of blood backward (regurgitation) through a valveican cause heart failure. Both stenosis and regurgitation of a valve can severely stress the heart, so that over time, the heart enlarges and cannot pump adequately. An abnormal connection (septal defectsi(see Birth Defects: Atrial and Ventricular Septal Defects and Patent Ductus Arteriosus: Failure to CloseFigures) between the heart chambers can allow blood to recirculate within the heart, increasing the workload of the heart, and thus can cause heart failure. Disorders that affect the hearts electrical conduction system and produce prolonged changes in heart rhythms (especially if these are fast or irregular) can cause heart failure. When the heart beats abnormally, it cannot pump blood efficiently. Some lung disorders, such as pulmonary hypertension (see Pulmonary Hypertension), may alter or damage blood vessels in the lungs (pulmonary arteries). As a result, the right side of the heart has to work harder to pump blood into the lungs. The person may then develop cor pulmonale (see Cor Pulmonale: A Disorder Stemming From Pulmonary HypertensionSidebar), in which the right ventricle is enlarged and there is rightisided heart failure. Sudden, usually complete blockage of a pulmonary artery by several small blood clots or one very large clot (pulmonary embolism) also makes pumping blood into the pulmonary arteries difficult. A very large clot can be immediately life threatening. The increased effort required to pump blood into the blocked pulmonary arteries can cause the right side of the heart to enlarge and may cause the walls of the right ventricle to thicken, resulting in right sided heart failure. Disorders that indirectly affect the hearts pumping ability include a severe deficiency of red blood cells or hemoglobin (anemia), an overactive thyroid gland (hyperthyroidism), an underactive thyroid gland (hypothyroidism), and kidney failure. Red blood cells contain hemoglobin, which enables them to carry oxygen from the lungs and deliver it to body tissues. Anemia reduces the amount of oxygen the blood carries, so that the heart must work harder to provide the same amount of oxygen to tissues. (Anemia has many causes, including chronic bleeding due to a stomach ulcer.) An overactive thyroid gland overstimulates the heart, so that it pumps too rapidly and does not empty normally during each heartbeat. When the thyroid gland is underactive, levels of thyroid hormones are low. As a result, all muscles, including the heart, become weak because muscles depend on thyroid hormones to function normally. Kidney failure strains the heart because the kidneys cannot remove excess fluid from t he bloodstream, so the heart has a larger volume of blood to pump. Eventually, the heart cannot keep up, and heart failure develops Diastolic Dysfunction: Inadequately treated high blood pressure is the most common cause of diastolic dysfunction. High blood pressure stresses the heart because the heart must pump blood more forcefully than normal to eject blood into the arteries against the higher pressure. Eventually, the hearts walls thicken (hypertrophy), then stiffen. The stiff heart does not fill quickly or adequately, so that with each contraction, the heart pumps less blood than it normally does. Diabetes causes other changes that stiffen the walls of the ventricle. As people age, the hearts walls also tend to stiffen. The combination of high blood pressure and diabetes, which are common among older people, and ageirelated stiffening makes heart failure particularly common among older people. Heart failure may result from other disorders that cause the hearts walls to stiffen, such as infiltrations and infections. For example, in amyloidosis, amyloid, an unusual protein not normally present in the body, infiltrates many tissues in the body. If amyloid infiltrates the hearts walls, they stiffen, and heart failure results. In tropical countries, infiltration by certain parasites into heart muscle can cause heart failure, even in young people. Some heart valve disorders, such as aortic valve stenosis, hinder blood flow out of the heart. As a result, the heart muscle thickens and has to work harder, and diastolic dysfunction develops. Eventually, systolic dysfunction also develops. In constrictive pericarditis, the sac that envelops the heart (pericardium) stiffens, preventing even a healthy heart from pumping and filling normally. Types of Heart diseases affect the heart chambers include These are the heart diseases which leads to heart failures A) Pulmonary heart diseases B) Heart Disease affecting heart muscles C) Heart disease affecting heart valves D) Heart disease affecting coronary arteries and coronary veins E) Heart disease affecting heart lining F) Heart disease affecting electrical system G) Congenital heart disease A) Pulmonary heart disease Pulmonary heart disease is caused by an enlarged right ventricle. It is known as heart disease resulting from a lung disorder where the blood flowing into the lungs is slowed or blocked causing increased lung pressure. The right side of the heart has to pump harder to push against the increased pressure and this can lead to enlargement of the right ventricle In the case of heart diseases affecting heart muscles, the heart muscles are stiff, increasing the amount of pressure required to expand for blood to flow into the heart or the narrowing of the passage as a result of obstructing blood flow out of the heart. B) Heart diseases affecting heart muscles Cardiomyopathy Heart muscle becomes inflamed and doesnt work as well as it should. There may be multiple causes such as high blood pressure, heart valve disease, artery diseases or congenital heart defects. a) Dilated cardiomyopathy The heart cavity is enlarged and stretched. Blood flows more slowly through an enlarged heart, causing formation of blood clots as a result of clots sticking to the inner lining of the heart, breaking off the right ventricle into the pulmonary circulation in the lung or being dislodged and carried into the bodys circulation to form emboli . b) Hypertrophic cardiomyopathy The wall between two ventricles becomes enlarged, obstructing blood flow from the left ventricle. Sometimes the thickened wall distorts one leaflet of the mitral valve, causing it to leak. The symptoms of hypertrophic cardiomyopathy include shortness of breath, dizziness, fainting and angina pectoris. c) Restrictive cardiomyopathy The ventricles become excessively rigid, harder to fill with blood between heartbeats. The symptoms of restrictive cardiomyopathy include shortness of breath, swollen hands and feet. Myocarditis Myocarditis is an inflammation of heart muscles or weakens of heart muscles. The symptoms of myocarditis include fever, chest pains, and congestive heart failure, palpitation. C) Heart disease affecting heart valves Heart diseases affecting heart valves occur when the mitral valve in the heart narrows, causing the heart to work harder to pump blood from the left atrium into left ventricle. Here are some types of heart disease affecting heart valves: a. Mitral Stenosis Mitral Stenosis is a heart valve disorder that involves a narrowing or blockage of the opening of mitral valve causing the volume and pressure of blood in left atrium increases. b. Mitral valves regurgitation Mitral regurgitation is the heart disease in which your hearts mitral valve doesnt close tightly causing the blood to be unable to move through the heart efficiently. Symptoms of mitral valve regurgitation are fatigue and shortness of breath. c. Mitral valves prolapsed In mitral valve prolapsed, one or both leaflets of the valve are too large resulting in uneven closure of the valve during each heartbeat. Symptoms of mitral valves prolapsed are palpitation, shortness of breath, dizzy, fatigue and chest pains. d. Aortic Stenosis With aging, protein collagen of valve leaflets are destroyed and calcium is deposited on the leaflets causing scarring, thickening, and stenosis is the valve therefore increasing the wear and tear on the valve leaflets resulting in the symptoms and heart problems of aortic stenosis. e. Aortic regurgitation Aortic regurgitation is the leaking of aortic valve of the heart that causes blood to flow in the reverse direction during ventricular diastole, from the aorta into the left ventricle. Symptoms of aortic regurgitation include fatigue or weakness, shortness of breath, chest pain, palpitation and irregular heartbeats. F. Tricuspid stenosis Tricuspid stenosis is the narrowing of the orifice of the tricuspid valve of the heart causing increased resistance to blood flow through the valve. Symptoms of tricuspid stenosis include fatigue, enlarged liver, abdominal swelling, neck discomfort, leg and ankle swelling. g. Tricuspid regurgitation. Tricuspid regurgitation is the failure of the riht ventricular causing blood to leak back through the tricuspid valve from the riht ventricle into the riht atrium of the heart. Symptoms of tricuspid regurgitation include leg and ankle swelling, swelling in the abdomen. D. Heart disease affecting coronary arteries and coronary veins Heart disease affecting coronary arteries and coronary veins: The malfunctioning of the heart may be due to damage caused by narrowed or blocked arteries leading to the muscle of your heart as well as blood backing up in the veins. Types of heart disease that affect the coronary arteries and veins include Angina pectoris Angina pectoris occurs when the heart muscle doesnt get as much blood oxygen as it needs. Here are 3 types of angina pectoris: a) Stable angina Stable angina is chest pain or discomfort that typically occurs with activity or stress due to oxygen deficiency in the blood muscles usually follows a predictable pattern. Symptom of stable angina include chest pain, tightness, pressure, indigestion feeling and pain in the upper neck and arm. b) Unstable angina Unstable angina is caused by blockage of the blood flow to the heart. Without blood and the oxygen, part of the heart starts to die. Symptoms of unstable angina include pain spread down the left shoulder and arm to the back, jaw, neck, or riht arm, discomfort of chest and chest pressure. c) Variant angina aiso known as coronary artery spasm Caused by the narrowing of the coronary arteries. This is caused by the contraction of the smooth muscle tissue in the vessel walls. Symptoms of variant angina include increasing of heart rate, pressure and chest pain. Heart attacks known as myocardial infarction or MI Heart attacks caused by plaque rupture with thrombus formation in a coronary vessel, resulting in an acute reduction of blood supply to a portion of the myocardium. Symptoms of MI include a squeezing sensation of the chest, sweating, nausea, vomiting, upper back pain and arm pain. Heart disease aiso known as coronary artery disease or coronary heart disease Caused by arteries hardening, narrowing, cutting off blood flow to the heart muscle resulting in heart attack. Symptoms of heart disease include shortness of breath, chest pains on exertion, palpitation, dizziness and fainting. Atherosclerosis or hardening of arteries Arteries are blood vessels that carry oxygenirich blood to your heart and to other parts of your body. Atherosclerosis is caused by plaques that rupture in result of blood clots that block blood flow or break off and travel to another part of the body. Atherosclerosis has no symptom or warning sign. Silent ischemia. Ischemia is a condition in which the blood flow is restricted to a part of the body caused by narrowing of heart arteries. Siient ischemia means people have ischemia without pain. There is aiso no warning sign before heart attack. E) Heart disease affecting heart lining Rheumatic heart disease results from inflammation of the heart lining when too much fluid builds up in the lungs leading to pulmonary congestion. It is due to failure of the heart to remove fluid from the lung circulation resulting in shortness of breath, coughing up blood, pale skin and excessive sweating. Heart disease resulting from inflammation of either the endocardium or pericardium is called heart disease affecting heart lining. Endocardium is the inner layer of the heart. It consists of epithelial tissue and connective tissue. Pericardium is the fluid filled sac that surrounds the heart and the proximal ends of the aorta, vena valva and the pulmonary artery. a. Endocarditis Endocarditic, which is an inflammation of the endocardium is caused by bacteria entering the bloodstream and settling on the inside of the heart, usually on the heart valves that consists of epithelial tissue and connective tissue. It is the most common heart disease in people who have a damaged, diseased, or artificial heart valve. Symptoms of endocarditis include fever, chilling, fatigue, aching joint muscles, night sweats, shortness of breath, change in temperature and a persistent cough. b. Pericardium Pericarditis is the inflammation of the pericardium. It is caused by infection of the pericardium which is the thin, tough bagiiike membrane surrounding the heart. The pericardium aiso prevents the heart from over expanding when blood volume increases. Symptoms of pericarditis include chest pain, mild fever, weakness, fatigue, coughing, hiccups, and muscle aches. F) Heart disease affecting electrical system The electrical system within the heart is responsible for ensuring the heart beats correctly so that blood can be transported to the cells throughout our body. Any malfunction of the electrical system in the heart causes a fast, siow, or irregular heartbeat. The electrical system within the heart is responsible for ensuring that the heart beats correctly so that blood can be transported throughout our the body. Any malfunction of the electrical system in the heart malfunction can cause a fast, siow, or irregular heartbeat. Types of heart disease that affect the electrical system are known as arrhythmias. They can cause the heart to beat too fast, too siow, or irregularly. These types of heart disease include: a. Sinus tachycardia Sinus tachycardia occurs when the sinus rhythm is faster than 100 beats per minute therefore it increases myocardial oxygen demand and reduces coronary blood flow, thus precipitating an ischemia heart or valvular disease. b. Sinus bradycardia Sinus bradycardia occurs when a decrease of cardiac output results in regular but unusually siow heart beat less than 60 beats per minute. Symptoms of sinus bradycardia includes a feeling of weightlessness of the head, dizziness, low blood pressure, vertigo, and syncope. c. Atrial fibrillation Atrial fibrillation is an irregular heart rhythm that starts in the upper parts (atria) of the heart causing irregular beating between the atria and the lower parts (ventricles) of the heart. The lower parts may beat fast and without a regular rhythm. Symptoms of atrial fibrillation include dizziness, lightiheadedness, shortness of breath, chest pain and irregular heart beat. d. Atrial flutter Atrial flutter is an abnormal heart rhythm that occurs in the atria of the heart causing abnormalities and diseases of the heart. Symptoms of atrial flutter includes shortness of breath, chest pains, anxiety and palpitation. e. Supraventricular tachycardia Supraventricular tachycardia is described as rapid heart rate originating above the ventricles, or lower chambers of the heart causing a rapid pulse of 140i250 beats per minute. Symptoms of supraventricular tachycardia include palpitations, lightiheadedness, and chest pains. f. Paroxysmal supraventricular tachycardia Paroxysmal supraventricular tachycardia is described as an occasional rapid heart rate. Symptoms can come on suddenly and may go away without treatment. They can last a few minutes or 1i2 days. g. Ventricular tachycardia Ventricular tachycardia is described as a fast heart rhythm that originates in one of the ventricles of the heart . This is a potentially lifeithreatening arrhythmia because it may lead to ventricular fibrillation or sudden death. Symptoms of ventricular tachycardia include light headedness, dizziness, fainting, shortness of breath and chest pains. h. Ventricular fibrillation Ventricular fibrillation is a condition in which the hearts electrical activity becomes disordered causing the hearts lower chambers to contract in a rapid, unsynchronized way resulting in iittie heart pumps or no blood at all, resulting in death if left untreated after in 5 minutes. There are many heart diseases affecting electrical system such as premature arterial contractions, wolf parkinson, etc. G) Congenital heart disease There are several heart diseases that people are born with. Congenital heart diseases are caused by a persistence in the fetal connection between arterial and venous circulation. Congenital heart diseases affect any part of the heart such as heart muscle, valves, and blood vessels. Congenital heart disease refers to a problem with the hearts structure and function due to abnormal heart development before birth.Every year over 30,000 babies are born with some type of congenital heart defect in US alone. Congenital heart disease is responsible for more deaths in the first year of life than any other birth defects. Some congenital heart diseases can be treated with medication alone, whiie others require one or more surgeries. The causes of congenital heart diseases of newborns at birth may be in result from poorly controlled blood sugar levels in women having diabetes during pregnancy, some hereditary factors that play a role in congenital heart disease, excessive intake of alcohol and side affects of some drugs during pregnancy. Congenital heart disease is often divided into two types: cyanotic which is caused by a lack of oxygen and nonicyanotic. A. Cyanotic Cyanosis is a blue coloration of the skin due to a lack of oxygen generated in blood vessels near the skin surface. It occurs when the oxygen level in the arterial blood falls below 85i90%. The below lists are the most common of cyanotic congenital heart diseases: a) Tetralogy of fallot Tetralogy of fallot is a condition of several congenital defects that occur when the heart does not develop normally. It is the most common cynaotic heart defect and a common cause of blue baby syndrome. b) Transportation of the great vessels Transportation of the great vessels is the most common cyanotic congenital heart disease. Transposition of the great vessels is a congenital heart defect in which the 2 major vessels that carry blood away from the aorta and the pulmonary artery of the heart are switched. Symptoms of transportation of the great vessels include blueness of the skin, shortness of breath and poor feeding. c) Tricuspid atresia In tricuspid atresia there is no tricuspid valve so no blood can flow from the riht atrium to the riht ventricle. Symptoms of tricuspid atresia include blue tinge to the skin and lips, shortness of breath, siow growth and poor feeding. d) Total anomalous pulmonary venous return Total anomalous pulmonary venous return (TAPVR) is a rare congenital heart defect that causes cyanosis or blueness. Symptoms of total anomalous pulmonary venous return include poor feeding, poor growth, respiratory infections and blue skin. e)Truncus arteriosus Truncus arteriosus is characterized by a large ventricular septal defect over which a large, single great vessel arises. Symptoms of truncus arteriosus include blue coloring of the skin, poor feeding, poor growth and shortness of breath. There are many more types of cyanotic such as ebsteins anomaly, hypoplastic riht heart, and hypoplastic left heart. If you need more information please consult with your doctor. B. Nonicyanotic Nonicyanotic heart defects are more common because of higher survival rates. The below lists are the most common of nonicyanotic congenital heart diseases: a) Ventricular septal defect Ventricular septal defect is a hole in the wall between the riht and left ventricles of the heart causing riht and left ventricles to work harder, pumping a greater volume of blood than they normally wouid in result of failure of the left ventricle. Symptoms of ventricular septal defect include very fast heartbeats, sweating, poor feeding, poor weight gain and pallor. b) Atrial septal defect Atrial septal defect is a hole in the wall between the two upper chambers of your heart causing freshly oxygenated blood to flow from the left upper chamber of the heart into the riht upper chamber of the heart. Symptoms of atrial septal defect include shortness of breath, fatigue and heart palpitations or skipped beats. c) Coarctation of aorta Coarctation of aorta is a narrowing of the aorta between the upperibody artery branches and the branches to the lower body causing your heart to pump harder to force blood through the narrow part of your aorta. Symptoms of coarctation of aorta include pale skin, shortness of breath and heavy sweating. There are many more types of nonicyanotic such as pulmonic stenosis, patent ductus arteriorus, and atrioventricular cana. These problems may occur alone or together. Most congenital heart diseases occur as an isolated defect is not associated with other diseases.
Sunday, August 4, 2019
Joseph Stalin Essay -- Biography Soviet Union European History
Joseph Stalin Joseph Stalin was one of the biggest mass murderers of the twentieth century. From the purges in the Red Army to forced relocations, Stalin had the blood of millions on his hands. This essay is not going to debate the fact that this was indeed a brutal and power hungry individual, because he was indeed just that. I will on the other hand show you that through his way of governing the Soviet Union, he actually saved mother Russia from the German invasion in World War Two through his cunning and ruthlessness. Joseph Stalin was a very industrious person and used every means possible to better prepare his country for the coming war that he believed was inevitable. Wether it was diplomatic plotting, economic maneuvering, or just plain brute force, Stalin used every tool in his vast arsenal. The following are some of the more important decisions and methods that Stalin employed. Stalin was forced to consolidate his power through harsh means to better rule the Soviet Union. He ordered the five year plans to industrialize the nation and ordered one of the largest military build up plans ever. Stalin attempted many times to reach a diplomatic solution and ways to delay war with the Axis powers while at the same time trying to guarantee security from the West. Stalin wanted nothing less than to rule the Soviet Union and make her the greatest country in the world and he would stop at nothing to reach those goals. In his quest for leadership Stalin wished to consolidate his power in only himself, t hus enabling him to better rule the Soviet Union. Stalin's roots in politics go all the way back to him being expelled from the theological seminary in Tiflis, Georgia in 1899. This was where Stalin got his first real taste for politics and from that point on his political ambitions grew greater and greater. Stalin soon joined up with the Social Democratic Party and after the party split over ideological differences in 1903, Stalin joined the Bolshevik party under Vladimir Lenin. From 1903 to 1912 Stalin was arrested, and managed to escape, several times. He was exiled to Siberia from 1913 to 1917, returning only after the fall of the Tsar. With the fall of the Tzar and the country in the hands of the revolutionaries Stalin believed it to be the perfect time to come back and renew his political ambitions. Stalin was appointed Commissar of Nationalities ... ... military industry at the beginning of the war and up-to-date equipment was starting to be delivered to the front. The movement of the war industry east contributed to the lack of material but proved to be the saving grace of the army in the end. At the end the Soviet war industries were producing some of the best equipment in the world. In the end I do believe that through Stalin's leadership the Soviet Union was saved. Had it been under the leadership of the intended Communist bureaucracy it would have surely fallen. As we have seen in our country even simple matters can take forever to go into effect or get started under a bureaucracy. In that highly volatile and dangerous time period only an iron fisted rule could bring about change fast enough to due any good. True in the short term peoples right were trampled upon and millions died from famine, purges, and the war itself but in the end hundred's of millions were saved. Bibliography Robert Conquest, The Great Terror, (Toronto: Macmillan and Co. Ltd, 1968), p.123. Alexander Werth, Russia at War, (London: Barrie and Rockcliff, 1964), p.19. Isaac Deutscher, Stalin, (New York: Oxford University Pres, Inc 1967.
Saturday, August 3, 2019
Skepticism Essay -- Skeptic philosophy philosophers
Skepticism Skepticism is the Western philosophical tradition that maintains that human beings can never arrive at any kind of certain knowledge. Originating in Greece in the middle of the fourth century BC, skepticism and its derivatives are based on the following principles: There is no such thing as certainty in human knowledge. All human knowledge is only probably true, that is, true most of the time, or not true. Several non-Western cultures have skeptical traditions, particularly Buddhist philosophy, but properly speaking, skepticism refers only to a Greek philosophical tradition and its Greek, Roman, and European derivatives. The school of Skeptic philosophers were called the "Skeptikoi" in Greece. The word is derived from the Greek verb, "skeptomai," which means "to look carefully, to reflect." The hallmark of the skeptikoi was caution; they refused to be caught in assertions that could be proven false. In fact, the entire system of skeptic philosophy was to present all knowledge as opinion only, that is, to assert nothing as true. In this, they were firmly planted in a tradition started a century earlier by Socrates. Socrates claimed that he knew one and only one thing: that he knew nothing. So he would never go about making any assertions or opinions whatsoever. Instead, he set about questioning people who claimed to have knowledge, ostensibly for the purpose of learning from them, using a judicial cross-examination, called elenchus . If someone made an assertion, such as, "Virtue means acting in accordance with public morality, " he would keep questioning the speaker until he had forced him into a contradiction. As in a court of law, this contradiction proved that the speaker was lying in som... ...at a certain piece of knowledge, that piece of knowledge then becomes the basis for clearing up other doubts. Descartes systematic doubt became the basis of the Enlightenment and modern scientific tradition. One begins with a proposition, or hypothesis, that is in doubt and then tests that proposition until one arrives, more or less, at a certain conclusion. That does not, however, end the story. When confronted by the conclusions of others, one's job is to doubt those conclusions and redo the tests. Once a hypothesis has been tested and retested, then one can conclude that one has arrived at a "scientific truth." That, of course, doesn't end it, for all scientific truths can be doubted sometime in the future. In other words, although scientists speak about certainty and truth all the time, the foundational epistemology is skeptical: doubt anything and everything.
Friday, August 2, 2019
Business Statistics
QMT2033 BUSINESS STATISTICS Assignment for mid -term break 1. Most of the information technology developers claim that wireless connection would give speed of at least 11 Mbps compared to wired connection. A sample of 105 computers using wireless connection shows it gives a mean of 11. 7 Mbps and a standard deviation of 2. 3 Mbps. a) Do you think that the wireless usage should be implemented? Test at 7% significance level). b) Repeat the test by using p-value approach. 2. A jack is usually used for raising the axle of a motor so that a wheel may be changed.It is known that the weight of the vehicle that be raised by a jack is more than 100kg. a random sample of 125 jacks with a mean of 102. 2kg and standard deviation of 15. 17kg is taken. a) Do you agree that a jack can raise more than a 100 kg vehicle? (use ? = 0. 03) b) Repeat the test by using p-value approach. 3. In a normal situation, on average, a song needs a duration of at most 3. 5 minutes to be played. The duration of a ran dom sample of 11 songs is taken, and the data are as follows: 5. 32 6. 53 4. 52 3. 20 3. 39 4. 00 4. 10 3. 15 3. 47 4. 01 2. 3 a) By using the data, do you agree with the statement that a song needs a duration of at most 3. 5 minutes to be played? (use ? = 0. 05) b) Repeat the test by using p-value approach. 4. A researcher needs on average, 1. 2 years to complete his short-term research. A random sample of 12 researcher are taken, and the duration (in years) to complete their research are recorded as below: 4. 3 1. 0 1. 5 1. 6 1. 2 0. 8 2. 1 2. 4 0. 7 1. 3 0. 4 a) Do these data support the stamen that a researcher needs exactly 1. 2 years to complete his research? (use ? =0. 05) b) Repeat the test by using p-value approach. 5.Newly purchased automobile tyres of a certain type are supposed to be filled with a pressure of at most 34 psi. A random sample of 36 such tyres was selected and it gives a sample mean of 34. 66 psi and a standard deviation of 2. 14 psi. a) Does this sample pr ove that such tyres fill with a pressure of at most 34 psi? (Use 7% significance level). b) Repeat the test by using p-value approach. QMT2033 BUSINESS STATISTICS 6. In a labour-management discussion it was brought up that workers at a certain large plant, take on average at least 32. 6 minutes to get to work. If a random sample of 60 workers took on the average of 33. minutes with a standard deviation of 6. 1 minutes, what can you conclude based on the sample taken? (Use 0. 017 level of significance). Repeat the test by using p-value approach. 7. A manufacturer has developed a new fishing line, which he claims has a mean breaking strength of 15 kilograms with a standard deviation of 0. 5 kilogram. To test the eligibility of the claim, a random sample of 50 lines has been tested and it gave a mean of 14. 9 kilograms. Can you help the manufacturer to test his claim? (Use a significance level of 0. 08). Repeat the test by using p-value approach.
Thursday, August 1, 2019
Aspect of Contract & Negligence in Business Essay
The aim of this brief article is to set out some key aspects of contract and the tort of negligence using the following headings: â⬠¢The relationship between the parties â⬠¢The nature of the obligation â⬠¢Causation and remoteness of damage â⬠¢The measure of damages. Using the same headings should remind you of the key aspects of each of the two areas in such a way that you are less likely to confuse them. (The words ââ¬Ëcontractââ¬â¢ and ââ¬Ënegligenceââ¬â¢ are deliberately repeated in each heading so that you get into the habit of distinguishing between the rules for each area, rather than having a general set of notes on, say, remoteness of damage, which confuses material from both areas.) KEY ASPECTS OF THE LAW OF CONTRACT Contract ââ¬â the relationship between the parties A contract is a legally binding agreement formed by the mutual consent of the parties. The parties may be known to each other, as with a client and an accountant, or they may be strangers, as with a software company and a person who downloads and installs the software. In either case, there is a clear relationship between the parties and this relationship is both formed and governed by the contract. (The rules governing the formation and content of contracts are set out in syllabus areas B1 and B2 of Paper F4 (ENG) syllabus.) Contract ââ¬â the nature of the obligation In a contractual relationship, the nature of the obligation is determined by the terms of the contract. By entering into the contract, the parties agree to accept the resulting obligations. That is not to say that there is complete freedom of contract, since certain contractual terms may be restricted by statute ââ¬â for example, under the Unfair Contract Terms Act 1977. Nevertheless, in order for a contract to be binding, the parties must intend to create legal relations and their contractual obligations are based on mutual consent. Contract ââ¬â causation and remoteness of damage This issue concerns the extent of the defendantââ¬â¢s liability for the chain of events set in motion by the breach of contract. The leading case is Hadley v Baxendale (1854) in which the defendant was contracted to transport a broken mill shaft from the claimantââ¬â¢s mill to the repairers. The defendant was late in delivering the shaft and the mill was idle for a longer period as a result. The claimant sought damages for loss of profits during the delay. The court found for the defendant, setting out a two-stage test for remoteness of damage. In order to be recoverable, the loss must be: â⬠¢either a normal result of the breach, or â⬠¢one which, at the time of the contract, both parties would have contemplated as a probable result. Here, given how important a drive shaft was to a mill, neither test was satisfied, since it was reasonable to expect that the mill would have a spare shaft. Another useful case here is Victoria Laundry v Newham Industries (1949). Here, the defendantââ¬â¢s delay caused the defendant loss of profit, including the loss of an unusually lucrative contract. The defendant was liable for normal loss of profit under the first limb of the Hadley test, but not for the loss from that particular contract. He would only have been liable for that had he known about it when the contract was formed. Contract ââ¬â the measure of damages The remedies available for breach of contract include the common law remedies of damages, action for the price and quantum meruit, as well as the equitable remedies of injunction and specific performance. Remember that a breach of contract is a breach of a legal obligation, so the aim of the remedies is to put the claimant in the position that they would have been had the defendant fulfilled the obligation. This means putting the claimant in the position that they would have been in had the contract been performed. In relation to damages, this may be divided into expectation lossà (benefits that might have been gained from the performance of the contract) and reliance loss (expenses incurred by the claimant in his side of the contract). The conduct of the claimant may also affect the amount of damages payable, since the claimant is under an obligation to take reasonable measures to mitigate the loss, as in Payzu v Saunders (1919). For example, if the buyer refuses to accept or pay for the goods, the seller must recover what they can by selling the goods to a third party. The damages will be the difference between the contract price and the amount that the seller receives. If the seller receives the contract price or higher from a third party, only nominal damages will be claimable. A claimant who does not attempt to mitigate their loss may have their damages reduced by the amount by which they could have done so. It is for the defendant to prove that the claimant failed to mitigate the loss. We will now use the same headings in relation to the tort of negligence. KEY ASPECTS OF THE TORT OF NEGLIGENCE Negligence ââ¬â the relationship between the parties Negligence cases are based on a non-contractual relationship between the parties. The parties may be known to each other, as with a surgeon and a patient, or they may be strangers, as with two drivers involved in a road traffic accident. Due to the lack of any agreed relationship between the parties, the first question that arises in the case of negligence is that of whether any relationship exists between them at all. If one party is to be held liable to another in negligence, the relationship that must first be established is that of a duty of care. Exam answers often state as a learned fact that liability in negligence is non-contractual, but it is worth spending a little longer thinking about what it actually means. As a future accountant, you may find it helpful to relate this point to professional negligence cases since these illustrate the extent to which an accountant may be held liable in relationships where there may be no contractual obligation. A useful case in this respect is Caparo Industries plc v Dickman (1990). Here, the claimants were shareholders in a company and the defendants were the companyââ¬â¢s auditors. The claimants relied on the audited accounts and purchased more shares with a view to making a takeover bid. Having taken over the company, the claimants discovered that the company had in fact made a à £400,000 loss rather than the à £1.2m profit shown by the financial statements. The House of Lords held that the requirements for a duty of care to exist were as follows: â⬠¢the harm must be reasonably foreseeable â⬠¢there must be proximity between the claimant and the defendant â⬠¢it must be just, fair and reasonable to impose a duty of care on the defendant. Note that foreseeability at this stage in the context of negligence is used to establish whether there is any relationship between the parties; this is not necessary at this stage in contract since the contract itself establishes that there is a relationship. (We will consider foreseeability again in relation to remoteness of damage, which is discussed below.) In Caparo, the contract was between the company and the auditors. The individual shareholders did not have a contract with the auditors. The question was whether the auditors owed a duty of care to the shareholders. The House of Lords held that the auditors owed a duty to the shareholders as a body, but that they did not owe a duty to potential investors or to existing shareholders who planned to increase their shareholding. The defendants were therefore not liable. Caparo is one of a number of cases considering professional negligence. (This is covered by syllabus area B5 of Paper F4 (ENG).) A key theme running through these cases is the existence of the so-called ââ¬Ëspecial relationshipââ¬â¢. This was first established in Hedley Byrne & Co Ltd v Heller and Partners (1963). Bear in mind that the question of a special relationship is likely to be relevant where the claimant does not have a contractual relationship with the professional providing the advice. In Hedley Byrne itself, the claimant provided services on credit to a client. It did so on the basis of a credit reference given by the defendant, the clientââ¬â¢s bank. Note that there was a contract between the claimant and the client and a contract between the client and the bank, but no contract between the claimant and the bank. The defendant was able to avoid liability by relying on an exclusion clause contained in the credit reference. However, had the clause not been present, the defendant would have been liable because it had used its special skill to provide a statement to the claimant in the knowledge that the claimant would rely on this. Other cases that you may find helpful to consider in this context are as follows: â⬠¢JEB Fasteners Ltd v Marks, Bloom & Co (1982) â⬠¢Morgan Crucible v Hill Samuel Bank Ltd (1991) â⬠¢James McNaghten Paper Group Ltd v Hicks Anderson & Co (1991) â⬠¢ADT v BDO Binder Hamlyn (1995) â⬠¢NRG v Bacon & Woodrow and Ernst & Young (1996) In each case, identify any contractual relationships between the various parties involved and the nature of the relationship between the claimant and the defendant. Negligence ââ¬â the nature of the obligation In relation to negligence, the nature of the obligation is not agreed between the parties but rather is imposed by operation of law. For example, a road user will owe a duty of care to other road users and a manufacturer will owe a duty of care to the final consumers of its products. Once a duty of care has been held to exist, the defendantââ¬â¢s actions are judged by the standard of the reasonable man in the defendantââ¬â¢s position:Blyth v Birmingham Water Works (1856). The standard of care for professionals is of the reasonable professional having or holding himself out as having the skill or ability in question. Learners and the inexperienced will also be judged against the standards of the fully-qualified. Negligence ââ¬â causation and remoteness of damage In relation to negligence, issues of causation and remoteness tend to beà considered separately. The key test for causation is known as the ââ¬Ëbut forââ¬â¢ test, which basically asks whether the loss would have been sustained ââ¬Ëbut forââ¬â¢ the defendantââ¬â¢s negligence. The leading case here is Barnett v Chelsea and Kensington HMC (1969). The claimant arrived at the hospital emergency department complaining of stomach pains. He was sent home without being examined and subsequently died. Even though the doctor owed the patient a duty of care and had breached the duty, the breach of duty had not caused the patientââ¬â¢s death, since the poisoning was so advanced by the time the patient arrived at the hospital that he could not have been saved even with prompt treatment. The defendant was therefore not liable. The key test for remoteness in negligence is one of foreseeability. In The Wagon Mound (1961), the defendants negligently allowed oil to spill into Sydney Harbour. The claimants were welding, but ceased doing so on seeing the oil. Having been advised that the sparks would not ignite oil lying on the surface of the water, they resumed work. Sparks ignited debris lying on the surface of the oil, which in turn ignited and damaged the claimantsââ¬â¢ wharf. It was held that the defendants were not liable since the only foreseeable damage was pollution rather than fire. By contrast, in Jolley v London Borough of Sutton (2000), a local authority failed to remove an abandoned boat for two years. A 14 year-old was seriously injured when he tried to jack up the boat in order to repair it. The authority was found liable since it knew that children regularly played on the boat, so it was foreseeable that a child would be injured. It did not matter that the precise nature of the injury could n ot be foreseen. The cases may appear to conflict, since The Wagon Mound focuses on foreseeability of the type of damage whereas Jolley v Sutton focuses on foreseeability of some harm. There are a number of cases in this area and they are not always easy to reconcile. For the purposes of Paper F4, the key point to remember is that the test for remoteness in the tort of negligence is based on foreseeability of harm. You should be prepared to illustrate this point with examples. Note that the law of negligence considers foreseeability twice: once in relation to duty of care and again in relation to remoteness. Remember that, if there is no duty of care, the question of remoteness does not arise. Caparo v Dickman is a useful illustration of this: it might be foreseeable that existing shareholders would rely on an audit report in deciding whether to increase their shareholding. Nevertheless, the auditor did not owe a duty of care to potential investors. This was based on other aspects of the duty test: proximity and the question of whether it was fair, just and reasonable to impose a duty. Negligence ââ¬â the measure of damages As with contract, once liability in negligence has been established, the next point to consider is that of remedies and the aim of the remedies is to put the claimant in the position that he would have been in had the breach of obligations not taken place. For negligence, the aim is therefore to put the claimant in the position that they would have been had the tort not been committed. Again, as with contract, the damages payable may also be reduced because of the claimantââ¬â¢s conduct. In negligence, this may be due to the partial defence of contributory negligence. This happens in cases where, even though the defendant was at fault, the claimant contributed to their own loss. Where this happens, the claimantââ¬â¢s damages are reduced by the percentage to which the claimant is held to be at fault. The leading case here is Sayers v Harlow UDC (1958) where the claimant was trapped in a public toilet due to a defective lock. She was injured when trying to climb out and it was held that she had contributed to her own injuries. It is for the defendant to prove that the claimant was contributorily negligent. CONCLUSION Contract and the tort of negligence arise in separate questions on Paper F4, so you will not be asked to compare and contrast them. The aim of this article is to identify some key similarities and differences so that you are less likely to confuse these two areas. Your aim for the exam should be to be able to explain these key aspects of contract and negligence without confusing them. You may find that the following table acts as a useful revision aid: Contractual LiabilityLiability in negligence Relationship between the partiesThe relationship is created and governed by the contract. The parties enter the relationship by mutual consent.The relationship is non-contractual and is imposed by law. The defendant must owe the claimant a duty of care. Nature of obligationThe parties must comply with the terms of the contract.The defendant must act according to the standard of care expected of the reasonable man or the reasonable professional. Causation and remotenessIf the loss is a normal result of the breach, the defendant will be liable; if the loss is not a normal result of the breach, the defendant will only be liable if they knew of the unusual circumstances.The defendantââ¬â¢s negligence must cause the claimantââ¬â¢s loss and the loss must have been a foreseeable consequence of the breach of duty. Measure of damagesThe aim is to compensate the claimant by putting them in the position that they would have been had the contract been performed.The aim is to compensate the claimant by putting them in the position that they would have been had the negligence not taken place. Possible reduction of damagesDamages may be reduced by the amount that could have been mitigated if the claimant fails to take reasonable action to mitigate the loss.Damages may be reduced by the relevant percentage if the claimantââ¬â¢s conduct contributed to the loss.
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