Understanding Fatigue and the Implications for Worker Safety

Understanding Fatigue and the Implications for Worker Safety Introduction Workplace safety requires a systematic approach that includes an understanding of risk factors and identification of hazards. Worker fatigue has been identified as a risk factor for both acute and cumulative injuries. Fatigue and incomplete recovery can lead to decreased capacity that can result in an increased risk of injury and a decline in work efficiency (Kumar 2001, de Looze, Bosch, and van Dieà «n 2009, Visser and van Dieà «n 2006). In addition, fatigue contributes to accidents, injuries and death (Williamson et al. 2011). Over $300 million in lost productivity time in US workplaces can be tied to fatigue. Significantly reducing the incidence of fatigue-induced workplace injuries and lost productivity depends on the accurate and timely detection of fatigue to allow for appropriate intervention. Although the term fatigue is commonly used, it has come to refer to many concepts in occupational safety and health. In order to manage and mitigate fatigue and the associated risks, it is essential to understand the different types and components. Fatigue is generally accepted as resulting in the impairment of capacity or performance as a result of work. However, fatigue is multidimensional, either acute or chronic, whole body or muscle level, physical or mental, central or peripheral. In addition, it includes a decline in objective performance, as well as perceptions of fatigue. Of added importance are the roles of sleep and circadian function. Each of these aspects of fatigue do not occur in isolation, but interact to modify worker capacity and injury risk. Both mental and physical fatigue can result in poor decision making, which may result in an acute injury (Williamson et al. 2011). The risk of injury is dependent on both the injury mechanism and the characteristics of the work being performed. Parameters of importance in the development of fatigue, and subsequent risk, include the length of time-on-task between breaks, work pace, and the timing of rest breaks (Williamson et al. 2011). Researchers have postulated that through delineation of the quantitative details of relevant variables, appropriate interventions and injury control can be developed (Kumar 2001). How to best quantify workplace conditions, particularly physical exposures experienced by the worker, remains an open research question (Kim and Nussbaum 2012). Current approaches to fatigue monitoring and detection often rely either on fitness-for-duty tests to determine whether the worker has sufficient capacity prior to start work, monitoring of sleep habits, or intrusive monitoring of brain activation (using electroencephalography (EEG)) (Balkin et al. 2011) or changes in local muscle fatigue (using electromyography (EMG)) (Dong, Ugaldey, and El Saddik 2014). While there is no single standard measurement of fatigue, there are numerous subjective measurement scales and objective measurement techniques that can be adapted for workplace use. Recent advances in wearable technologies also present an opportun ity for real-time and in-the-field assessment of fatigue development. Why should we care about fatigue? Fatigue in the workplace is often described as a multidimensional process, which results in a diminishing of worker performance. It results from prolonged activity, and is associated with psychological, socioeconomic and environmental factors (Barker and Nussbaum 2011, Yung 2016). From an occupational health and safety perspective, fatigue must be managed and controlled since it has significant short-term and long-term implications. In the short-term, fatigue can result in discomfort, diminished motor control, and reduced strength capacity (Bjà ¶rklund et al. 2000, Cà ´tà © et al. 2005, Huysmans et al. 2010). These effects might lead to reduced performance, lowered productivity, deficits in work quality, and increased incidence of accidents and human errors (Yung 2016). Fatigue can also result in longer term adverse health outcomes, including, e.g., chronic fatigue syndrome (Yung 2016) and reduced immune function (Kajimoto 2008). It can be seen as a precursor to work-related muscu loskeletal disorders (WMSDs) (Iridiastadi and Nussbaum 2006). These outcomes have been associated with future morbidity and mortality, work disability, occupational accidents, increased absenteeism, increased presenteeism, unemployment, reduced quality of life, and disruptive effects on social relationships and activities (Yung 2016). The safety impacts of fatigue are best evidenced in the transportation domain. In the U.S., an estimated 32,675 people died in motor vehicle crashes in 2014 (2015a). In 2013 there were 342,000 reported truck crashes that resulted in 3,964 fatalities and ~95,000 injuries (2015b). While these crashes often result from several factors, it is estimated that driver-related factors are the leading cause for 75-90% of fatal/injury-inducing crashes (Craye et al. 2015, Stanton and Salmon 2009, Medina et al. 2004, Lal and Craig 2001). The National Highway Traffic Safety Administration (NHTSA) estimates that about 20% of all crashes are fatigue-related (Strohl et al. 1998) and 60% of fatal truck crashes can be attributed to the driver falling asleep while driving (Craye et al. 2015). Drowsy driving increases crash risk by 600% over normal driving (Klauer et al. 2006). For many years, a succinct definition of fatigue has been sought after (Aaronson et al. 1999). In our estimation, there is no simple and standard definition for fatigue. For example, our statement above: Fatigue in the workplace is often described as a multidimensional process, which results in a diminishing of worker performance, while true, is not sufficient to describe fatigue, since there are many other conditions that may result in a diminished workers performance (e.g., motivation). Perhaps, more importantly, there are several other factors that impact our ability to determine one standard definition: Workplace fatigue development mechanisms differ significantly according to the occupation type. For example, in manufacturing, the focus is typically on physical/muscle fatigue or related to the shift schedule, and in transportation drowsiness and sleepiness are often the root-causes for driver fatigue. Given the complexity of the human body, a single mechanism unlikely explains fatigue under all conditions, even for a single task and fatigue type (i.e. muscle fatigue) (Weir et al. 2006). No one definition can explain the complex interactions between biological processes, behavior, and psychological phenomena (Aaronson et al. 1999). It is unlikely that a single theory can be used to explain all observations of performance deterioration (Weir et al. 2006). Thus, we cannot provide a single definition of fatigue in this paper. Instead we refer the reader to Yung (2016, p.14) for a summary of multiple example fatigue definitions from various domains. Measuring and Quantifying Fatigue In this section, we divide how fatigue is measured according to cognitive and physical functions respectively. Talk about PVT and reaction time as the main standards for sleep-related fatigue There are several important cognitive characteristics that are typically assed in the context of fatigue. These include: a) arousal, b) alertness/ attention, c) cognitive control, d) motivation, and e) stress. Arousal is commonly measured in transportation safety studies since it aims at assessing sleep deprivation, an important root-cause for trucking crashes (especially at night) (Philip et al. 2005, Strohl et al. 1998). Measures of arousal include heart rate, electrodermal response (EDR), pupil dilation and self-report questionnaires (Yung 2016). Alertness and attention are important in translating sensory and work-related inputs into actionable items. They can be measured using gaze direction, EEG, validated scales, and questionnaires. The third characteristic, cognitive control, has to do with the time taken to process information, and thus, reaction time is perhaps the most commonly used measure for evaluating it. The fourth characteristic is perhaps the hardest to measure sinc e motivation cannot be assessed except through questionnaires and validated scales. Stress can be assessed through a number of measures which include heart rate variability, blood pressure and body postures (Yung 2016). The reader should note that the measures for quantifying mental fatigue include intrusive monitoring systems (e.g. EEG and blood pressure monitoring systems), non-intrusive measures (camera systems to detect gaze direction), and somewhat subjective measures (questionnaires and scales). Table 1 provides a summary of physiological and physical indicators of fatigue. Table 1: Typical Physiological and Physical Indicators of Fatigue Development Measurement Direction of Change with Fatigue Heart rate Increases with physical fatigue Heart rate variability Decreases with mental fatigue (for root-mean square of the successive differences (RMSSD)) Increased Low Frequency / High Frequency (LF/HF) power ratio Electromyography Decrease in mean power frequency Increase in root mean square amplitude Strength Decrease in maximum exertion Tremor Increase in physiological and postural tremor Pupil dilation Increases with mental fatigue and drowsiness Blink rate Increased percentage eyelid closure over the pupil, over time (PERCLOS) Reaction time Increased reaction time and lapses (using psychomotor vigilance task (PVT)) Performance Increase in errors and task completion time Force variability Increase in variability with physical fatigue Subjective assessment Increase in ratings of discomfort and fatigue On the physical side, electromyography is one of the most commonly used evaluation tools for muscle fatigue in a laboratory setting. The gold standard is to detect cellular and metabolic changes through blood sampling techniques (Garde, Hansen, and Jensen 2003). Since these approaches are intrusive, some researchers attempt to detect symptoms of physical fatigue. These symptoms include an impairment in postural control (Davidson, Madigan, and Nussbaum 2004), increased sway (Davidson, Madigan, and Nussbaum 2004), and joint angle variability (Madigan, Davidson, and Nussbaum 2006). Additional symptoms include an increase in exerted force variability (Svendson et al. 2010) and increased tremor (Lippold 1981). Note that these symptoms can be observed through the use of check sheets, visual inspection (manual and/or through cameras), and self-reported questionnaires among other tools. In our estimation, most methods described above are of limited use in practice since they are either invasive (and will be resisted by individuals/unions) or rely on visual inspection performed by an observer. Perhaps, more importantly, each observational and measurement technique also focuses primarily on one main risk factor, such as posture or force, or a combined set of factors but for a repetitive task, such as the NIOSH work practices guide (Waters et al. 1993). This fails to capture the interactive nature of many fatigue precursors as well as the variability of the work performed. In addition, these methods do not take into account the characteristics of the individual, beyond general anthropometric and demographic attributes, such as height and age. One important consideration is that the application of these methods in field studies and practice have also been limited by the question: can we detect if fatigue (or its symptoms) has occurred? Note that this question is binary with a yes/no answer. However, it is well understood that fatigue is a process that occurs as a function of loading, time and exertion and is not an end point. From a safety perspective, a more interesting question is: Can we predict when fatigue will occur for a given worker based on their schedule, environment and job tasks? If this can be done, then fatigue management will progress from a reactive state (equivalent of the personal protective equipment state in traditional hazard control theory) to higher/safer levels of engineering controls, substitution and/or perhaps elimination through modeling and scheduling. The increasing availability of pervasive sensing technologies, including wearable devices, combined with the digitization of health information has the potential to provide the necessary monitoring, recording, and communication of individuals physical and environmental exposures to address this question (Kim and Nussbaum 2012, Vignais et al. 2013). In the following section, we describe some of the research and commercially available products that are used for predicting/monitoring fatigue development. Predicting Fatigue Development Models for fatigue development are not new, but the existing models are often incomplete. Models for predicting/understanding how humans fatigue have received significant attention over the past few decades in the fields of aviation, driving, mining, and professional athletics. In the transportation areas (i.e. aviation and driving), the models originated from efforts to model the underlying relationships between sleep regulation and circadian dynamics (Dinges 2004). Dinges (2004) present a survey of the biomathematical models used in this area. There are also some surveys on driver fatigue detection models, see e.g. Wang et al. (2006). However, based on our interactions with one of the larger trucking companies in the U.S., these models do not offer answers to the following question: Given the massive data collected on each truck that include indirect indicators of fatigue, e.g. lane departures and hard brakes, and individual characteristics of each driver, can we predict how each driver will fatigue for a given assignment, traffic condition and weather profile? With the advent of big data, this is the direction that is needed for fatigue development in the trucking industry. One can make parallels for aviation and military applications. In mining, there are commercially available products that claim to predict fatigue among mine workers. The authors did not have the chance to test these products and thus, we cannot verify/validate these claims. However, if true, this system will be a significant contribution to mining safety. Based on the above discussion, there are several important observations to be made. First, there has not been much independent research verifying the claims made for any commercial products. Thus, practitioners should use them with caution and in tandem with their current safety methods. Second, there have been only limited attempts to perform inter-disciplinary research in fatigue development. Thus, the current approaches are domain-dependent and are often incomplete since they consider only a few precursors. There needs to be a systematic move towards utilizing big data analytics as a mechanism to harness the massive amounts of data that is being captured on our equipment, workers, etc. The research challenge is to ensure that we are asking the right questions prior to considering what the technology can (or cannot) provide. Third, it is somewhat inexplicable that the manufacturing safety community is significantly behind other safety domains. We believe that there is a significant opportunity for both researchers and practitioners in examining how other disciplines are managing fatigue. General Strategies for Fatigue Management and Mitigation There are several somewhat recent publications that detail how to manage physical and/or mental fatigue indicators (Hartley and Commission 2000, Caldwell, Caldwell, and Schmidt 2008, Williamson et al. 2011, Williamson and Friswell 2013). These studies have presented the typical hazard control recommendations, which include administrative and engineering controls that can reduce/mitigate the development of fatigue. Practitioners should also consult the documentation from Transport Canada on Developing and Implementing a Fatigue Risk Management System (https://www.tc.gc.ca/media/documents/ca-standards/14575e.pdf). Typical interventions include: rest (for physical fatigue), sleep (for alertness), modified work-rest schedules, and limits on the cumulative hours worked in a week (or shift changes). While these strategies are effective for population averages/overall, they do not address the weakest link in the workforce (i.e. those most likely to fatigue and/or get injured). We see much w ork needed in this area. Concluding Remarks In this paper, we have provided an overview of some of the current issues in fatigue detection/ management research and practice. Based on our review of the literature, we offer the following advice to safety professionals: Transportation Safety Professionals: There is a significant body of research that highlights the impact of lack of sleep (e.g. from sleep apnea and/or scheduling), night driving, weather (e.g. cloudy or rainy), and work-rest schedules on fatigue development. In general, less sleep, night driving, bad weather and frequent changes in the work-rest schedule are more detrimental to transportation safety. To mitigate these risks, the routing/scheduling can be modified to alleviate some of these precursors. In addition, wearable sensors and on-vehicle systems (e.g. lane departure and hard brake detection sensors) can provide real-time indicators of fatigue development in driving. The data from these sensors can be used through simple dashboards that provide the dispatcher with information on which drivers are at risk. The dispatcher can then force these drivers to rest if fatigued (and sleep in-cabin at a truck stop if necessary) since a short break/nap can help mitigate these effects. Manufacturing Safety Professionals: Fatigue has been shown to be a precursor to risky behaviors and long-term injuries. It is also associated with a diminished performance and, therefore, can result in significant quality problems. Based on our discussion with several safety managers from large automotive companies, we have learned that it is often easier to sell safety projects to upper management when it is combined with quality improvement initiatives. The rationale is simple to management since they can see a return on investment (ROI) on these projects when compared to a softer objective (reducing/eliminating the probability of a safety problem that has not occurred before). In addition, we challenge practitioners to categorize their at-risk populations (e.g. unexperienced workers, obese and/or elder workers, etc.). These workers cannot be modeled by existing ergonomics and safety models that consider an average worker. Thus, a dashboard and sensors that monitor their absenteeis m, quality of their work and/or complaints can be used to trigger appropriate interventions. Mining Safety Researchers: The technology with fatigue monitoring (and more general safety) in mining has evolved significantly over the past decade. There are several commercial products that allow for active monitoring, scheduling, and equipment safety checks. To our knowledge, at least one major equipment manufacturer has released a safety systems suite that incorporates all these data sources to present a clear picture of a workers fatigue and distraction risk. We did not test the validity of these claims and therefore, we ask safety practitioners to ask for system demos and ensure that this particular system meets their needs. A word of caution: fatigue detection systems do not mitigate and/or eliminate fatigue. In addition, we urge safety professionals to embrace the role of technology and its potential to redefine safety from a one system fits all to an individualized approach. For researchers and educators, we believe that there is a sufficient body of literature that suggests that our community is headed to individualized safety models. To develop these models, there needs to be an emphasis on managing large amounts of data, revisiting our old models and ensuring that we can offer data-driven interventions for safety/ergonomics problems. In essence, our field is moving towards individualized models and evidence-based interventions. Acknowledgments This research was partially supported by the American Society for Safety Engineers (ASSE) Foundation grant titled ASSIST: Advancing Safety Surveillance using Individualized Sensor Technology. Bibliography 2015a. Crash Stats: Early Estimate of Motor Vehicle Traffic Fatalities in 2014. edited by U.S. Department of Transportation National Highway Traffic Safety Adminstration. Washington, DC: NHTSAs National Center for Statistics and Analysis. 2015b. Large Trucks: 2013 Data (Traffic Safety Facts. DOT HS 812 150). National Center for Statistics and Analysis, accessed 06/01. http://www-nrd.nhtsa.dot.gov/Pubs/812150.pdf. Aaronson, Lauren S, Cynthia S Teel, Virginia Cassmeyer, Geri B Neuberger, Leonie Pallikkathayil, Janet Pierce, Allan N Press, Phoebe D Williams, and Anita Wingate. 1999. Defining and measuring fatigue. Image: the journal of nursing scholarship 31 (1):45-50. Balkin, Thomas J., William J. Horrey, R. Curtis Graeber, Charles A. Czeisler, and David F. Dinges. 2011. The challenges and opportunities of technological approaches to fatigue management. Accident Analysis Prevention 43 (2):565-572. doi: http://dx.doi.org/10.1016/j.aap.2009.12.006. Barker, L. M., and M. A. Nussbaum. 2011. The effects of fatigue on performance in simulated nursing work. Ergonomics 54 (9):815-29. doi: 10.1080/00140139.2011.597878. Bjà ¶rklund, Martin, Albert G Crenshaw, Mats Djupsjà ¶backa, and Hà ¥kan Johansson. 2000. Position sense acuity is diminished following repetitive low-intensity work to fatigue in a simulated occupational setting. European journal of applied physiology 81 (5):361-367. Caldwell, John A, J Lynn Caldwell, and Regina M Schmidt. 2008. Alertness management strategies for operational contexts. Sleep medicine reviews 12 (4):257-273. Cà ´tà ©, Julie N, Denis Raymond, Pierre A Mathieu, Anatol G Feldman, and Mindy F Levin. 2005. Differences in multi-joint kinematic patterns of repetitive hammering in healthy, fatigued and shoulder-injured individuals. Clinical Biomechanics 20 (6):581-590. Craye, Cà ©line, Abdullah Rashwan, Mohamed S. Kamel, and Fakhri Karray. 2015. A Multi-Modal Driver Fatigue and Distraction Assessment System. International Journal of Intelligent Transportation Systems Research:1-22. doi: 10.1007/s13177-015-0112-9. Davidson, Bradley S, Michael L Madigan, and Maury A Nussbaum. 2004. Effects of lumbar extensor fatigue and fatigue rate on postural sway. European Journal of Applied Physiology 93 (1-2):183-189. de Looze, Michiel, Tim Bosch, and Jaap van Dieà «n. 2009. Manifestations of shoulder fatigue in prolonged activities involving low-force contractions. Ergonomics 52 (4):428-437. doi: 10.1080/00140130802707709. Dinges, David F. 2004. Critical Research Issues in Development of Biomathematical Models of Fatigue and Performance. Aviation, Space, and Environmental Medicine 75 (3):A181-A191. Dong, Haiwei, Izaskun Ugaldey, and Abdulmotaleb El Saddik. 2014. Development of a fatigue-tracking system for monitoring human body movement. Instrumentation and Measurement Technology Conference (I2MTC) Proceedings, 2014 IEEE International, 12-15 May 2014. Garde, A Helene, Ã…se M Hansen, and Bente R Jensen. 2003. Physiological responses to four hours of low-level repetitive work. Scandinavian journal of work, environment health:452-460. Hartley, Laurence, and National Road Transport Commission. 2000. Review of fatigue detection and prediction technologies: National Road Transport Commission Melbourne. Huysmans, Maaike A, Marco JM Hoozemans, Allard J van der Beek, Michiel P de Looze, and Jaap H van Dieà «n. 2010. Position sense acuity of the upper extremity and tracking performance in subjects with non-specific neck and upper extremity pain and healthy controls. Journal of rehabilitation medicine 42 (9):876-883. Iridiastadi, H, and MA Nussbaum. 2006. Muscle fatigue and endurance during repetitive intermittent static efforts: development of prediction models. Ergonomics 49 (4):344-360. Kajimoto, Osami. 2008. Development of a method of evaluation of fatigue and its economic impacts. In Fatigue Science for Human Health, 33-46. Springer. Kim, Sunwook, and Maury A. Nussbaum. 2012. Performance evaluation of a wearable inertial motion capture system for capturing physical exposures during manual material handling tasks. Ergonomics 56 (2):314-326. doi: 10.1080/00140139.2012.742932. Klauer, Sheila G, Thomas A Dingus, Vicki L Neale, Jeremy D Sudweeks, and David J Ramsey. 2006. The impact of driver inattention on near-crash/crash risk: An analysis using the 100-car naturalistic driving study data. Washington, DC. Kumar, Shrawan. 2001. Theories of musculoskeletal injury causation. Ergonomics 44 (1):17-47. doi: 10.1080/00140130120716. Lal, Saroj K. L., and Ashley Craig. 2001. A critical review of the psychophysiology of driver fatigue. Biological Psychology 55 (3):173-194. doi: http://dx.doi.org/10.1016/S0301-0511(00)00085-5. Lippold, OCJ. 1981. The tremor in fatigue. In Human muscle fatigue: Physiological mechanisms, 234-248. Pitman Medical London (CIBA Foundation symposium 82). Madigan, Michael L, Bradley S Davidson, and Maury A Nussbaum. 2006. Postural sway and joint kinematics during quiet standing are affected by lumbar extensor fatigue. Human movement science 25 (6):788-799. Medina, Alejandra L., Suzanne E. Lee, Walter W. Wierwille, and Richard J. Hanowski. 2004. Relationship between Infrastructure, Driver Error, and Critical Incidents. Proceedings of the Human Factors and Ergonomics Society Annual Meeting 48 (16):2075-2079. doi: 10.1177/154193120404801661. Philip, Pierre, Patricia Sagaspe, Nicholas Moore, Jacques Taillard, Andrà © Charles, Christian Guilleminault, and Bernard Bioulac. 2005. Fatigue, sleep restriction and driving performance. Accident Analysis Prevention 37 (3):473-478. doi: http://dx.doi.org/10.1016/j.aap.2004.07.007. Stanton, Neville A., and Paul M. Salmon. 2009. Human error taxonomies applied to driving: A generic driver error taxonomy and its implications for intelligent transport systems. Safety Science 47 (2):227-237. doi: http://dx.doi.org/10.1016/j.ssci.2008.03.006. Strohl, KP, SL Merritt, J Blatt, AI Pack, F Council, and S Rogus. 1998. Drowsy driving and automobile crashes. nccdr/nhtsa expert panel on driver fatigue and sleepiness. National Highway Traffic Safety Administration, accessed 01/25. http://www.nhtsa.gov/people/injury/drowsy_driving1/Drowsy.html. Vignais, Nicolas, Markus Miezal, Gabriele Bleser, Katharina Mura, Dominic Gorecky, and Frà ©dà ©ric Marin. 2013. Innovative system for real-time ergonomic feedback in industrial manufacturing. Applied Ergonomics 44 (4):566-574. doi: http://dx.doi.org/10.1016/j.apergo.2012.11.008. Visser, Bart, and Jaap H. van Dieà «n. 2006. Pathophysiology of upper extremity muscle disorders. Journal of Electromyography and Kinesiology 16 (1):1-16. doi: DOI: 10.1016/j.jelekin.2005.06.005. Wang, Qiong, Jingyu Yang, Mingwu Ren, and Yujie Zheng. 2006. Driver fatigue detection: a survey. WCICA 2006: The Sixth World Congress on Intelligent Control and Automation, Dalian, China. Waters, Thomas R., Vern Putz-Anderson, Arun Garg, and Lawrence J. Fine. 1993. Revised NIOSH equation for the design and evaluation of manual lifting tasks. Ergonomics 36 (7):749 776. Weir, JP, TW Beck, JT Cramer, and TJ Housh. 2006. Is fatigue all in your head? A critical review of the central governor model. British journal of sports medicine 40 (7):573-586. Williamson, Ann, and Rena Friswell. 2013. Fatigue in the workplace: causes and countermeasures. Fatigue: Biomedicine, Health Behavior 1 (1-2):81-98. doi: 10.1080/21641846.2012.744581. Williamson, Ann, David A. Lombardi, Simon Folkard, Jane Stutts, Theodore K. Courtney, and Jennie L. Connor. 2011. The link between fatigue and safety. Accident Analysis Prevention 43 (2):498-515. doi: http://dx.doi.org/10.1016/j.aap.2009.11.011. Yung, Marcus. 2016. Fatigue at the Workplace: Measurement and Temporal Development. PhD, Department of Kinesiology, University of Waterloo.

Free Yellow Wallpaper Essays: An Essay :: Yellow Wallpaper essays

For the women in the twentieth century today, who have more freedom than before and have not experienced the depressive life that Gilman lived from 1860 to 1935, it is difficult to understand Gilman's situation and understand the significance of "The Yellow Wallpaper". Gilman's original purpose of writing the story was to gain personal satisfaction if Dr. S. Weir Mitchell might change his treatment after reading the story. However, as Ann L. Jane suggests, "The Yellow Wallpaper" is "the best crafted of her fiction: a genuine literary piece...the most directly, obviously, self-consciously autobiographical of all her stories" (Introduction xvi). And more importantly, Gilman says in her article in The Forerunner, "It was not intended to drive people crazy, but to save people from being driven crazy, and it worked" (20). Therefore, "The Yellow Wallpaper" is a revelation of Charlotte Perkins Gilman's own emotions. When the story first came out in 1892 the critics considered "The Yellow Wa llpaper" as a portrayal of female insanity rather than a story that reveals an aspect of society. In The Transcript, a physician from Boston wrote, "Such a story ought not to be written...it was enough to drive anyone mad to read it" (Gilman 19). This statement implies that any woman that would write something to show opposition to the dominant social values must have been insane. In Gilman's time setting "The ideal woman was not only assigned a social role that locked her into her home, but she was also expected to like it, to be cheerful and gay, smiling and good humored" (Lane, To Herland 109). Those women who rejected this role and pursued intellectual enlightenment and freedom would be scoffed, alienated, and even punished. This is exactly what Gilman experienced when she tried to express her desire for independence. Gilman expressed her emotional and psychological feelings of rejection from society for thinking freely in "The Yellow Wallpaper", which is a reaction to the fact that it was against the grain of society for women to pursue intellectual freedom or a career in the late 1800's. Her taking Dr. S. Weir Mitchell's "rest cure" was the result of the pressures of these prevalent social values. Charlotte Gilman was born on July 3, 1860, in Hartford, Connecticut in a family boasting a list of revolutionary thinkers, writers. And intermarriages among them were, as Carol Berkin put it, "in discrete confirmation of their pride in association" (18).

Case Analysis: Ski-Right Essay

I. Background of the Case The case begins with Bob Guthrie, a retired physician and an avid skier, who realized that there was a need for a special ski helmet following the recent incidents that lead to serious head injuries for skiers. There were existing ski helmets in the market, but Bob believed that he had a chance to make helmets more appealing to the people, by adding new features. Bob took this idea as something that could not only be an outlet for his creativity, but as a way for him to make some money. He set out with the goal of making helmets that were attractive, safe and fun to wear. With this in mind, Bob came up with several ideas for his new helmet, which he named ‘Ski Right’. Bob wanted his helmets to be attractive, so they had to come in several colors and feature the latest fashion trends and designs. But aside from this, they also had to be fun and useful. To achieve this, Bob thought of putting a built in AM/FM radio and cellphone to the helmets, with controls in a pad on the skier’s leg or arm. Before proceeding to build the helmet, Bob thought of the possibilities of success and failure in his venture. He figured that there was a 20 percent chance that there will be an excellent market for his product, a 40 percent chance that the market will be good, a 30 percent chance that the market will just be average and a 10 percent chance that the market will be poor. With this in mind, he continued his plans. Bob found several companies that could help him build his helmets. Progressive Products agreed to be a partner in developing Ski Right and would share in the profits and losses. Bob also discovered Leadville Barts, who specializes in bike helmets. They could be of great help in the production of the helmets itself. Bob was also talking to Talrad TR, a radio company in Florida, who had experience in making military radios. They could assist in putting the AM/FM radios in the Ski Right. Finally, Bob was meeting up with Celestial Cellular, who could develop the cellphones. Bob Guthrie now has to take into consideration all this information in making the decision of how to make and launch his new product, with the intention of making the most money he can as possible and avoiding failure. II. Problem Statement Bob’s problem now is deciding which combination of partners would result in the best profits for his new product, Ski Right. His first option is to partner up with Progressive Products in developing the helmets. He also has the option to ask Leadville Barts to make the helmets, which will then be taken by Progressive Products for finishing. His third option is to contract Talrad TR to make the radios for the helmets, which will then be brought to Leadville Barts and Progressive Products. Bob’s fourth choice is to work with Celestial Cellular to make the cellphones which will be passed to Progressive Products for the rest of production and distribution. His final option is to forget about Progressive Products completely, contract the three other companies and hire some friends to assemble and market Ski Right. Other than choosing which of the options would be the best recommendation for Bob, the case also calls for us to compute the expected opportunity loss that Bob would have if he chose one option over another. The group also has to determine what the value of perfect information is, which represents the maximum that Bob should pay in order to get perfect information. The group will also identify if Bob was logical in his approach to setting up his business and making decisions. III. Model Development The objective of this study is to identify what would be the most profitable course of action for Mr. Bob Guthrie. Another objective is to identify the opportunity loss in this situation as well as the value of perfect information. In all of the options available to him, Mr. Guthrie calculated the possible profits or losses he would have for every possible state of the market. He also determined the probabilities of each of the states of market given. The information is shown in the table below. In order to meet the given objectives, the group will apply the method of Decision Making Under Risk due to Mr. Guthrie being aware of the probabilities of all outcomes. There is also a need to identify the possible amount of losses Mr. Guthrie may incur which means that gaining a perfect or accurate forecast would be beneficial to better clarify what is the best decision to take. V. Conclusion After applying the method of Decision Making Under Risk, based on the decision table used to sort out and categorize the information given, the group was able to analyze and interpret the results, and found out he best decision Mr. Guthrie could choose for the new product he’s about to make. After determining the EMV for each alternative, option 2 which EMV for $2,600, came out as the highest among the other EMVs. Next, the group was able to identify the possible amount of losses Mr. Guthrie may incur. After getting all the opportunity loss for each alternative, the one with the lowest value of EOL which is $14,300 is determine. The result is once again, option 2. This was made sure by getting the EVwPI and subtracting it to the maximum EMV, thus giving us the EVPI of $14,300 which is equal to the EOL we determined earlier. According to the option 2 which is getting Leadville Barts to make the helmets, and Progressive Products to finish them, LB had extensive experience in making bicycle helmets which gives Mr. Guthrie a higher chance of assurance in getting the job done right, especially that he considers the quality of the helmets to be produced. On the other hand, he’s facing a greater risk since he’s handing out to job to two different companies.

Swath vs. Swatch

Swath vs. Swatch Swath vs. Swatch Swath vs. Swatch By Maeve Maddox A reader sent me this extract, asking if it might provide material for a post topic: Charles Darwin did a fine job of showing why his theory of evolution explained the living world better than any creationist ideas could, and evidence has piled up ever since, but a swatch of the American public remain unconvinced. The reader was referring to the use of swatch where the context calls for swath. The example appeared in Forbes Magazine. The editors there have since corrected swatch to swath and even include the following addendum: â€Å"An earlier version of this story contained a typo in the word swath.† Unfortunately, about 172 other sites, which copied part or all of the original Forbes article, continue to display the error. I have found the same error- perhaps they are also typos- on news sites. Here are two: During the visit to the site where construction has started and a smoothened dirt road cuts through a wide swatch of the land where olive trees used to stand, border police arrived.- Catholic News. Stanley denounced the demand that American Jews â€Å"unequivocally support Israel against criticism† when â€Å"Israeli policies of the moment can and do betray values held by a large swatch of American Jewry.†- Progressive.

Future of an Illusion Essays

Future of an Illusion Essays Future of an Illusion Essay Future of an Illusion Essay Essay Topic: Rebuttal Self Reliance The Future of an Illusion Sigmund Freuds The Future of An Illusion proposes an idealistic form of human culture, one in which human relations are reorganized so that coercion and suppression of instincts are abandoned. The pivotal factor in this reorganization, he believes, is the universal abdication of religion. For the first portion of this response, the text itself will be broken down into chapter-by-chapter summaries. These summaries are written from the Freudian perspective and are not indicitive of the authors standpoint on these matters; this standpoint will be explored in the latter art of this response. Chapter-by-chapter Analysis Freud begins by philosophically examining the origin of culture, for he suggests that the less one knows of the past, the less reliable will ones Judgement of the future prove. Human culture is defined to consist of two things. Firstly, all of the knowledge and power that men have attained to master the forces of nature (Freud, 1928, p. 3) and secondly, the regulation of the relations between citizens so that the distribution of resources is attained. Culture is a human creation that Freud believes protects humanity from its own hostile nature. He then goes on to discuss an optimistic indulgence: his idealistic golden age, in which human instincts would not be suppressed. He concludes the opening chapter by introducing a concept that reappears later on; namely, that it is not in mans nature to be fond of work and as such, culture breeds internal rebellion. The second chapter describes the transition in reasoning from a material basis of culture to that of a psychological origin. : If the attainment of resources by means of labor is strongly opposed instinctually, then culture cannot be the creation of an instinctual process. For if this were the case, culture would be irreparably threatened by rebellion and would cease to exist. Therefore, Freud suggests that culture is the design of psychological motives. The process by which culture is a derivative of psychology follows three stages. To breifly summarize, any instinct that cannot be satisfied leads to frustration, which is the result of a prohibition; the condition produced by a prohibition being a privation. A prohibition primarily suppresses instinctual wishes; the class of men that express this frustration by asocial behavior are known as neurotics. Lastly, the chapter concludes that Freuds contemporary society cannot survive. The suppressed classes will develop a hatred towards culture, for which they provide the majority of labor while only sharing a small portion of its resources. A culture that leaves an entire class dissatisfied and motivated to rebel cannot be expected to survive. Freud has established that the principal task of culture is to protect humanity from the forces of nature. Religion, for Freud, is a creation of culture. It attempts to resolve the damaged self-esteem of man, and its strong urge for consolation. It demands an answer for the inevitability of death and the elplessness that permeates its existence. The answer is found in religion. According to Freud, Gods must exorcise the terrors of nature, they reconcile the cruelty of fate and make amends for the suffering imposed upon man through the communal life of culture. All good will ultlmately De rewaraea, In tnls IITe or tne next, ana all evll will be punished, which relieves the terror and fear that plagues mans consciousness. Gods remain, however, a device, a creation of culture to console the trembling, fearful mind. He then goes on to note that, despite the various differences between religions, t is a device that is held especially valuable. He argues that it is held more valuable than all of our devices for survival, or attaining resources, or preventing disease. Faith in the existence of a God discredits these fears and strips them of their power. With faith being the highest priority, once again, Freud concludes that the reason for culture must be psychological. Thus far Freud has allowed himself to theorize freely, without objection. The fourth chapter is dedicated to some potential rebuttals and is essentially a dialogue between Freud and an imagined opponent who follows my (Freuds) arguments with mistrust (Freud, 1928, p. 33). The first interjection regards the Freuds assumption that it is indeed culture that creates religious ideas and regulates the distribution of products of labor. Freud responds by mentioning that he has already attempted to show that religious ideas have formed in reaction to the same need as all other achievements of culture: from the necessity to defend itself against the crushing supremecy of nature. (Freud, 1928, p. 34). Furthermore, he explains that there is another motive for religion: the strong desire to correct the painfully felt imperfections of culture. The second argument regards what Freud escribed as mans technique of personifying nature. If the forces of nature, such as death, are similar in emotion to man then they are capable of being bribed, exorcised or appeased in order to rob them of their power over us. Frueds opposing voice suggests that man personfies nature due to his own natural disposition, which is likely to serve him well and in fact be correct. This personification of nature is what Freud describes as an infantile prototype. He uses the example of an infant and its parents. The infant learns that the best way to influence something that is supreme to oneself is to form a relationship with it. It is natural to man to personify everything he wishes to comprehend, in order to later control it. (p. 36). Here Freud begins to assess and pick apart the heavy reliance that human culture places upon religious doctrines. religion consists of certain dogmas, assertations about facts and conditions of external (or internal) reality, which tell one something that one has not oneself discovered and which claim that one should give them creedence. (Freud, 1928, p. 41). Yet these claims are not substantiated. Here, Freud uses the example of a common dogma that was sung in school: Konstanz is on the Bodensee if you dont believe it go and see. (Freud, 1928, p. 42). On visiting Konstanz, and noting that it is indeed on the Bodensee, Freud explains that this dogma was substantiated and as such he follows it. Dogmas exact belief in their contents, but not without substantiating their claim to this. If one wishes to substantiate a dogma for themselves, they should be able to do so; as Freud did by visiting Konstanz. Religion does not, as Freud would say, provide such an opportunity: it cannot be substantiated. According to Freud, there are three claims that are ade in order to exact belief in religious doctrines: firstly, because our ancestors have believed it; secondly, because we posses proofs that have been handed down from the period of antiquity; and thirdly, because it is forbidden to raise the question of their authenticity at all. This last claim arouses suspicion and can only be motlvatea Dy socletys awareness 0T tne uncertalnty 0T tnls Deller. Yurtnermore, to disregard this last claim has been met, in the past particularly, with serious penalties: often death. If society did trust the authenticity of these doctrines, then it would not feel threatened by those that question. Finally, this chapter suggests that evidence for the authenticity of religious doctrines should be easily found in the present. This point that Freud puts forth is evaded by the claim that religious doctrines, as Freud puts it, stand above reason. (Freud, 1928, p. 48). Freud concludes that the inherent strength of religious doctrines lies in psychology and are certainly independent of the acknowledgement of reason. Freud claims that religious ideas are not the residue of experience and as such he describes them as the titular illusion. He describes them as fulfillments of mans strongest wishes and it s indeed the strength of these wishes that give religion its strength in culture, not its authenticity or dependence on reason. An illusion is not defined as an error. It is, however, necessarily derived from a mans wish, and it is achieved when that man believes his wish to be fulfilled; the actual realization of this wish is not important. Here, Freud assigns religious doctrines to the category of illusion as they cannot be submitted to proof. Perhaps one of Freuds most crucial assertions is represented as such: Critics persist in calling deeply religious a person who confesses to a sense of ans insignificance and impotence in the face of the universe, although it is not this feeling that consitutes the essence of religious emotion, but rather the next step, the reaction to it, which seeks a remedy against this feeling. He who goes no further, he who humbly acquisces in the insignificant part man plays in the universe, is, on the contrary, irreligious in the truest sense of the word. (Freud, 1928, p. 6) This concept of seeking an answer to ones insignificance is the foundation of religion, according to Freud, and the method of finding this answer, faith in a higher power, is what he objects to. Once again, the text is opened up to the religious rebuttal. The seventh chapter explores the arguement that culture is built upon the foundation of religion and without it there would be chaos as man would revert back to their asoc ial instinctual behaviors. Furthemore, it is a purposeless cruelty to disprove religious doctrines as it would take away the solace that many find in their belief. In response to this, Freud begins by assuring the reader that a devout believer could not be convinced to abandon their faith simply by reading this text. Nor does he pretend that he is the first to put forth these arguments or ideas he has merely put orth a certain psychological foundation to the critique of my great predecessors. (Freud, 1928, p. 60). He goes on to admit that religion has contributed much to restraining asocial behaviors, however, he believes that it has dominated human society for thousands of years and it has been given the chance to show what it can achieve. It has failed. If the greater mass of mankind had found happiness, then there would be no need to strive for social change. As the authenticity of religious doctrines are nibbled at by critics and scientific advancements, religions influence on culture is slipping. In this eighth chapter, the reader is exposed to Freudian theory in its most demanding form. He proposes that religion is the universal obsessional neurosis of humanity. As with a child that goes through a stage of neuroses, so too does humanity. The child grows out of his neuroses and enters adulthood, in the same way, Freud believes that humanity will grow out of religion ana Tina a new cultural Tounaatlon tnat Is more Dennclal. Rellglous ooctrlnes are tne neurotic survivals of our ancestors and he suggests that through psycho-analytic therapy, they can be removed as any other neuroses can. As this text is coming to its conclusion, the Freudian contender steps in once again. He reminds Freud that the experiment of a society without religion has already been entertained, during the French Revolution: it failed. Furthermore, it was being explored at the time in Communist Russia. The contender questions whether Freud really believes that humanity can survive without religion. By this stage, it may come as no surprise that he does. He begins by conceding that A man who has for decades taken a sleeping draught is naturally unable to sleep if he is deprived of it (Freud, 1928, p. 86). Specifically, a man that has been indoctrinated by religious ideas may not be able to live without religion. However, the uninfluenced child does not need the consolation of religion to comfort its thoughts. The final chapter begins with a final interjection: Given that personality is formed within the first few years of childhood, religious teachings are the best way to instill a sense of morality into ones personality. Even if religion is an illusion your (Freuds) endeavour reduces itself to the attempt to replace a proved and affectively, valuable illusion by one that is unproved and without affective value. (Freud, 1928, p. 3). To this Freud admits that his idealistic hope for the future of culture may also be an illusion. Yet he makes an important distinction between his illusion and the religious counterpart. His illusion is not incapable of correction or improvement: You must defend the religious illusion with all your might; if it were discredited then your world would collapse, there would be nothing left for you but to despair of everything, of culture and of the future of mankind. (Freud, 1928, p. 94). The foundation of Freuds belief, however, is that it is possible for scientific work to discover something about the world that will e beneficial to mankind. Science has shown through many trials and successes that science is no illusion. But it would be an illusion to suppose that we could get anywhere else what it cannot give us. The final words of this text reveal Frueds underlying contention: the future of the illusion of religion is empty, and it must be abandoned if culture is to continue to develop. Interpretation The text is essentially a Journey from the origins of culture to the necessary denial of religion. If one is to blindly accept the validity of each step on this path, then the denial of religion would certainly follow. It is difficult to challenge the chain of logic that is presented in this text. Yet there are many aspects of it that are certainly susceptible to criticism. For if even one step in this process is flawed, then the chain itself is flawed. The following analysis of Freuds The Future of an Illusion expresses this authors personal reaction to and examination of the text. The incorporation of external resources such as similar analytical essays of the text by other authors are intentionally omitted so that this authors viewpoint is not influenced by anyone other than Freud himself. Freuds initial enquiry into culture is brief, yet it is greeable. The conclusion that culture is a device that serves to protect humanity from the supremecy of nature (Freud, 1928, p. 25) appeals to the common sense of the reader. Considering the lack of physical weapons and defences with which the human body is equipped, strength is found in numbers. The contradiction in Freuds theory lies in his concept of instinctual suppression. One should not contest the concept entlrely, Tor culture certalnly does, to some extent, suppress many aeslres that an individual may have. However, the importance that Freud attributes to this suppression is disproportionate. To suggest that every man is an enemy of culture (Freud, 1928, p. 9) as a result of this suppression is a serious inference. Furthermore, his idealistic vision of a culture without instinctual suppression is based upon the assumption that humanity will act upon rational thought. Herein lies the contradiction, for the issue of instinctual suppression is in fact a product of rational thought. Why does one suppress an instinctual desire? It is the result of a process of rational thought that prohibits acting upon it. This inconsistency is the first issue that one can find within Freuds illusion. The first problem with Freuds dialogue of religion is that it is, in actuality, a monologue. Though he must be commended for his attempt to allow for the imaginary interjections of a fictional opponent, they are still derived from his own viewpoint. To a large extent, Freud uses these interjections as a means of introducing a new point or to strengthen his own argument by discrediting the opposing view. The second issue lies in the nature of religious discussion in general. To publish a text that strongly advocates the denial of religion will be read in one of two ways: firstly, the atheist reader will strongly agree ith the logical chain that leads to the denouncement of religion; secondly, the religious reader will strongly object to the argument and may even stop reading. Neither instance describes any serious influence on behalf of the text. Freud does, however, address this. He himself regards this work as harmless and incapable of actually leading to the denial of religion that he advocates. Then, it must be asked, for what purpose did he write this? Perhaps he sought after a younger audience, one that had not already been indoctrinated by religion. Or perhaps this is simply a prediction, one which he hoped would one day be fulfilled. Irrespective of his motivation, it must be admitted that despite the strong will Freud expresses for social change within this text, it can ironically never inspire such change since the very indoctrination he refers to is already evident in his audience. If it is not, then he is not attempting to change their mind at all. This text presents the concept of an illusion in a new light. It is a definition, however, that this author finds interesting. Any dogma, or even theory, that one believes to be truth without subtantiating it for oneself is an illusion. Freud is misguided, however, in assuming that the existence of God cannot, and has not already, been substantiated. Though he limits religious doctrines authenticity to three claims, there are other means by which one might experience the presence of a God. For example, a personal experience with a God should, according to Freud, substantiate its existence. Without such an experience, though, it should be recognized that he is correct in saying that it is an illusion. Yet this illusion that he refers to seems to be presented in a negative light. There are so many things that are a mystery to humanity, and any theory that an individual entertains will always be an illusion until they can substantiate it. The only way to avoid this is to believe in nothing at all, to doubt any theory that comes ones way. This is more than simply an impractical way to live, it is an empty and purposeless life. Even if one leads a life at the whim of an illusion, it still has direction and Freud seems to disregard the importance of this essential aspect of life. One of the most striking features of this text is its strong philosophical basis. The very large maJorlty 0T It Is an expresslon 0T Freuds personal DelleTs regar01ng numanlty ana religion. Considering his strong advocation of substantiating ones dogmas, the text is mpty of research, physiological explanation or even a single case study. One cannot be so naive to demand accurate statistics on matters as broad as religion and culture in its entirety. However, considering the nature of topics that are discussed, this text cannot be considered a scientific publication. It is the speculation of a psychologist. As such, the most apparent link to the course content of Professor Barrons personality psychology course is found in Freuds description of neuroticism in children and adults. He explains that these neuroses can be removed by psycho- analytic therapy, as explored in class. However, this concept is incorrectly adapted to humanity as a whole. As Freud said, man personifies that which he does not understand. In the same way, Freud has personfied the history of humanity so that he might better describe it according to his own theories of personality development. Beyond this, The Future of an Illusion scarcely enlightens the reader on the development of personality, for that is not its purpose. It is a philosophical piece, advocating social change by means of abdicating religion. References Freud, S. (1928). The Future of an Illusion. Retrieved from https://read. amazon. comn astn=B00D119YAK

Significance of Customer Portfolio Management in Modern Business Essay

Significance of Customer Portfolio Management in Modern Business Environment - Essay Example In order to identify the changing customer preferences, firms are to manage their customer portfolios. Many advanced technologies are available today that can manage customer portfolios and thereby keep in touch with changing customer interests. Keeping well planned customer portfolios can strengthen customer relations and thereby customer retention for a long term. A loyal customer is an invaluable asset of any organisation that contributes to the accomplishment of the firm’s long term goals and objectives. Scholars reflect that efficient customer portfolio management at different levels of an organisation is a fundamental driver of strategic as well as financial success. The concept of customer portfolio can significantly contribute to the firm’s efforts to retain the profitable segments of its customers because customer portfolio is a potential way to achieve enhanced customer satisfaction. According to experts, â€Å"in much the same way that we can examine a portf olio of products or brands, the importance of customers as assets and investment centres mandates a similar portfolio analysis† (Hooley, et al. 2008, p.436). This paper will explore the concept of customer portfolio management. ... Thorough analysis of customer portfolios can assist a company to identify how a specific customer group is performing. To illustrate, customer portfolios can be beneficial for a construction company to evaluate the account receivable of home builder customer group to obtain a clear view of the level of financial risk, in case there is a slowdown in the market for homes. A company’s customer portfolio is comprised of customers who are grouped together based on or more ‘strategically important variables’ (Ibid). Generally each customer is linked to just one particular group in the portfolio. At one point, each customer is treated as unique and at another point all customers can be treated as identical (Ibid, p.125). While observing the corporate world, most of the firms are strategically positioned somewhere between these two points. Referring to various customer management theories, it may not be a good strategy to manage all customers in the same way unless such a policy makes strategic sense for doing so. Customers vary on the grounds of revenues and cost profiles and each customer has different tastes, preferences, and expectations (Yang & Peterson, 2004). As a result, a company has to manage customers in different ways considering their particular needs and wants. To make it more clear, customized product and face to face account management may satisfy the interests of some customers in the B2B context whereas standardized product and web-based self-service would be more effective in meeting the needs of some other customers. Undoubtedly, customers constitute an invaluable asset of any organisation regardless of its size and nature (Conejo, 2013). Unlike what many people think it is not factors

Equity and Trusts Essay Example | Topics and Well Written Essays - 2500 words

Equity and Trusts - Essay Example By the delivery of the gift, it can thus be understood that the gift can be considered as perfect when the donor of the gift actually surrenders the control or the right of the property. The intention of the donor making the gift is identified by the court with regard to certain circumstances. These circumstances include the relationship between the parties involved in the exchange of the gift, behaviour of the donor in the event of the exchange of the gift and the actual amount of the gift. The donor must also possess the legal capacity to deliver a gift to someone. Correspondingly, the final element is the acceptance of the gift wherein the person taking the gift must accept it at the time of the delivery. On completion of these three elements, the court would recognise such gift as a ‘perfect gift’. If in any case, the court is unable to identify the following three elements in the exchange of the gift then it is considered as the ‘imperfect gift’, which was also ruled in the Milroy v Lord case2. The aim of this study is to reveal the actual meaning of the perfect gift and the process through which the law has developed exception that the equity is unable to assist the volunteer to perfect an imperfect gift. The study has also tried to analyse the scope of further development in the particular area. Exceptions to the Maxim That ‘Equity Will Not Assist a Volunteer to Perfect an Imperfect Gift’ In the Milroy v Lord case, the main issue intended to prove whether the transferor of the property was really the trustee so that the gift could be treated as a ‘perfect gift’ or an ‘imperfect gift’ if otherwise. The question that rose in the context of this case was that the property was actually registered in the name of Tom Medley or was this was only an interest of Elena in order to enjoy the full right of the property. The case was in possession of the property and the limitations that were levied on the equity of the gift. Elena, niece of Tom Medley was getting married very soon. After the marriage of Elena, Medley had given some dividends from the shares to Elena, which was immediately handed over to the trustee or the Lord. Lord had deposited these shares in the Bank of Louisiana. Soon after the death of Medley, various issues rose such as whether these shares in the bank came under the possession of Medley or were they are the part of Lord’s property. Nevertheless, the real fact was that the shares were not once enumerated in the name of Lord rather it was always in the name of Medley3. At the end of the case, the court held a decision that Elena had no possession of any kind of property in the Bank of Louisiana as the title was never handed over to Lord from Medley. In this case, Lord was only acting as the trustee of the shares but the actual beneficiary was Elena. This case has given rise to a number of issues such as the ‘creation of trust’ and the ex ception that the ‘equity will not assist a volunteer to perfect an imperfect gift’4. In a general sense, trust is a legally binding agreement in which an individual transfers the legal control of the property to another person, namely the trustee, to manage the property effectively for the sake of the beneficiary. A trust usually is levied during the lifetime of the individual