An Overview of Solstices and Equinoxes

The June and December solstices mark the longest and shortest days of the year. The March and September equinoxes, meanwhile, mark the two days of each year when day and night are of equal length. June Solstice (Approximately June 20-21) The June solstice begins summer in the Northern Hemisphere and winter in the Southern Hemisphere. This day is the longest of the year in the Northern Hemisphere and the shortest of the year in the Southern Hemisphere. North Pole: The North Pole (90 degrees north latitude) receives 24 hours of daylight, as it has been daylight at the North Pole for the last three months (since the March Equinox). The sun is 66.5 degrees off the zenith or 23.5 degrees above the horizon.Arctic Circle: It is light 24 hours a day north of the Arctic Circle (66.5 degrees north) on the June solstice. The sun at noon is 43 degrees off the zenith.Tropic of Cancer: On the June Solstice the sun is directly overhead the Tropic of Cancer (23.5 degrees north latitude) at noon.Equator: At the equator (zero degrees latitude), the day is always 12 hours long. At the equator, the sun rises daily at 6 a.m. local time and sets at 6 p.m. local time. The sun at noon at the equator is 23.5 degrees off the zenith.Tropic of Capricorn: In the Tropic of Capricorn, the sun is low in the sky, at 47 degrees from the zenith (23.5 plus 23.5).Antarctic Circle: At the Antarctic Circle (66.5 degrees south), the sun makes the briefest of appearances at noon, peeking at the horizon and then instantaneously disappearing. All areas south of the Antarctic Circle are dark on the June Solstice.South Pole: By June 21, it has been dark for three months at the South Pole (90 degrees south latitude). September Equinox (Approximately September 22-23) The September equinox marks the beginning of fall in the Northern Hemisphere and spring in the Southern Hemisphere. There are 12 hours of daylight and 12 hours of darkness at all points on the earth’s surface on the two equinoxes. Sunrise is at 6 a.m. and sunset is at 6 p.m. local (solar) time for most points on the earth’s surface. North Pole: The sun is on the horizon at the North Pole on the September equinox in the morning. The sun sets at the North Pole at noon on the September equinox and the North Pole remains dark until the March equinox.Arctic Circle: Experiences 12 hours of daylight and 12 hours of darkness. The sun is 66.5 degrees off the zenith or 23.5 degrees above the horizon.Tropic of Cancer: Experiences 12 hours of daylight and 12 hours of darkness. The sun is 23.5 degrees off the zenith.Equator: The sun is directly overhead the equator at noon on the equinox. On both equinoxes, the sun is directly over the equator at noon.Tropic of Capricorn: Experiences 12 hours of daylight and 12 hours of darkness. The sun is 23.5 degrees off the zenith.Antarctic Circle: Experiences 12 hours of daylight and 12 hours of darkness.South Pole: The sun rises at the South Pole after the Pole has been dark for the past six months (since the March equinox). The sun rises to the horizon and it remains light at the Sout h Pole for six months. Each day, the sun appears to rotate around the South Pole at the same declination angle in the sky. December Solstice (Approximately December 21-22) The December solstice marks the beginning of summer in the Southern Hemisphere and is the longest day of the year in the Southern Hemisphere. It marks the beginning of winter in the Northern Hemisphere and is the shortest day of the year in the Northern Hemisphere. North Pole: At the North Pole, it has been dark for three months (since the September equinox). It remains dark for another three (until the March equinox).Arctic Circle: The sun makes the briefest of appearances at noon, peeking at the horizon and then instantaneously disappearing. All areas north of the Arctic Circle are dark on the December solstice.Tropic of Cancer: The sun is low in the sky, at 47 degrees from the zenith (23.5 plus 23.5) at noon.Equator: The sun is 23.5 degrees from the zenith at noon.Tropic of Capricorn: The sun is directly overhead the Tropic of Capricorn on the December solstice.Antarctic Circle: It is light 24 hours a day south of the Antarctic Circle (66.5 degrees north) on the June solstice. The sun at noon is 47 off the zenith.South Pole: The South Pole (90 degrees south latitude) receives 24 hours of daylight, as it has been daylight at the South Pole for the last three months (since the September equinox). The sun is 66.5 degrees off the zenith or 23.5 degrees above the horizon. It will remain light at the South Pole for another three months. March Equinox (Approximately March 20-21) The March equinox marks the beginning of fall in the Southern Hemisphere and spring in the Northern Hemisphere. There are 12 hours of daylight and 12 hours of darkness at all points on the earth’s surface during the two equinoxes. Sunrise is at 6 a.m. and sunset is at 6 p.m. local (solar) time for most points on the earth’s surface. North Pole: The sun is on the horizon at the North Pole on the March equinox. The sun rises at the North Pole at noon to the horizon on the March equinox and the North Pole remains light until the September equinox.Arctic Circle: Experiences 12 hours of daylight and 12 hours of darkness. The sun is 66.5 off the zenith and low in the sky at 23.5 degrees above the horizon.Tropic of Cancer: Experiences 12 hours of daylight and 12 hours of darkness. The sun is 23.5 degrees off the zenith.Equator: The sun is directly overhead the equator at noon on the equinox. During both equinoxes, the sun is directly over the equator at noon.Tropic of Capricorn: Experiences 12 hours of daylight and 12 hours of darkness. The sun is 23.5 degrees off the zenith.Antarctic Circle: Experiences 12 hours of daylight and 12 hours of darkness.South Pole: The sun sets at the South Pole at noon after the Pole has been light for the past six months (since the September equinox). The day begins on the horizon in the morning and by the end of the day, the sun has set.

The Religious Place Of Worship I Attended - 1397 Words

Identification: The religious place of worship I attended was a Jewish institution. The denomination was a reform Jewish Synagogue, and the name of the place of worship was called Temple Israel and is located at 2310 Virginia Drive, Ottawa, Ontario Canada, K2C 1N2. I attended the Saturday Shabbat service on September 26, 2015 at 10:15am and ran till 11:45. As people entered in Temple Israel they hand them a prayer book called Mishkan T’filah, and sheet that says â€Å"Ten Commandments Of Synagogue Etiquette† the ten commandments follows â€Å"1. Respect the Sanctuary as a place of prayer, reflection and joyous worship, 2. Be respectful in your behaviour and dress, 3. Join us in prayer and not in side conversations, 4. Treat the Siddurim with respect, 5. No cell phones or PDA’s use in the sanctuary, 6. No texting during the service, 7. No photography, 8. No eating, drinking, or gum chewing in the sanctuary, 9. Wish your neighbor Shabbat Shalom, 10. Have a joyous Shabbat. The Mis hkan T’filah is written in Hebrew with English translations. Building: The outside building is a light dirt colour brown all around, the building is one story with a basement. The door is a large wooden rectangle under a brick arc. The entrance into the synagogue was filled with books shelves, with a front desk, there was a display of the tree of life on the south wall. This tree of life had glass leaves with messages from the elementary school they have. Once I entered into the main area of worship throughShow MoreRelatedMy Journey At Seattle Pacific University1582 Words   |  7 Pages For the first eighteen years of my life I was raised in a conservative Southern Baptist church. During my journey at Seattle Pacific University, I have been attending different church traditions in order to find my own individual faith. One church that I have attended is Holy Apostles Greek Orthodox Church. 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Diabetes Is The Most Common Form Of Diabetes - 1723 Words

August, 28th, 2014 Diabetes in the United States Introduction Type 2 diabetes is the most common form of diabetes which affects 90% to 95% of the population. In the United States, approximately 1.7 million new cases of diabetes were identified in 2012 and the disease affects 29 million Americans or 9.3 percent of the population (Statistics About Diabetes, 2014). In 2012, the total financial burden of diabetes was estimated to be $245 billion which included $176 billion in direct medical costs and $69 billion in reduced productivity (American Diabetes Association, 2013). Those who have type 2 diabetes are unable to control insulin levels resulting in a condition called insulin resistance. In the first stages of the disease your body†¦show more content†¦Additionally, obesity rates are also rising among children and adolescents, especially those who are Hispanic. In the early 1990s, for example, 23 percent of white girls aged six to 11 were overweight as compared to 29 percent of Mexican-American girls. Poor compliance with exercis e and a Western diet that is high in fat and sugars, but low in fiber is an obvious factor contributing to obesity and the high rates of diabetes among the population (Statistics, 1999). Another risk factor contributing to the high prevalence of diabetes is socioeconomic disparity. In general, racial minorities are disproportionately poor, undereducated and lack health insurance. According to the National Center for Health Statistics, the poor and undereducated die younger and suffer more health problems than people with greater wealth status and education. The poor typically live in substandard housing or in low-income neighborhoods with plentiful fast-food restaurants, but few grocery stores that carry healthy foods, resulting in higher rates of obesity. In urban neighborhoods, a lack of sidewalks and crime-free parks also may discourage the daily physical activity needed for a healthy lifestyle. Because of this inequity non-whites live an average of five fewer years than whites, and diabetes is a major contributor to that statistic.

Questions on Milk Markets, Prices, and Price Setting

Supply and demand: Markets, Prices and price setting 1. Explain what happens to price and quantity of milk when the following events occur: a. More people start eating cereal for breakfast. The assumption is that if more people start eating cereal for breakfast, the demand for milk will rise because people use milk on their cereal. There are substitutes for milk, including soy milk, almond milk, and other milk-like products. In addition, some people eat cereal without milk, wetting it with another substance or simply eating it dry. For example, granola-based cereals are often consumed like trail mix, rather than in the traditional bowl-of-milk format. Therefore, there may not be a one-to-one correlation between increased cereal consumption and increased milk consumption. However, if cereal consumption increases and the consumption has the same pattern as current cereal consumption, then milk consumption will increase. This is will increase demand. 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Childcare and Education Unit 4 Free Essays

string(80) " devised pieces of equipment that encourage children to develop certain skills\." child Unit 4 – Assignment| Michelle Pieh| | Children Play| | Rebecca Myring| 11/16/2009| | Introduction Play is the main way in which children learn and therefore play affects all aspects of a child’s development. Valuing children’s play: Props should be encouraged. Allow the use of their own experience. We will write a custom essay sample on Childcare and Education Unit 4 or any similar topic only for you Order Now Own interests. Playing on their own should be encouraged. Work in a way that suits them. Adult encouragement to be engagement. Play as a way of communication. Recreate familiar themes. Transport resources to where they wish. Learn best when they are enjoying themselves. Allow for time and space. Facts about play: Through play children learn about their world. Play is considered to be a primary need of children. The stages of play change as a child grows older. The characteristics of play change as different stages of development are reached. All children go through the stages of play as they grow develop. Children develop at different rates therefore some children may take longer to go through a particular stage. D1/D7) Setting 1 – Zoo adventure play area Setting 2 – Park Setting 3 – Beach Setting 1 – A zoo adventure play area is an enclosed area containing play equipment. D7) It has wheel chair, pushchair/pram access. It has a variety of facilities ranging from a cafe with outdoor seating area for adults to sit and watch their children play to toilet facilities for all. In the play area there is specialised staff for children that have disabilities so they can help them join in with any games that are going on. The play area where the children can play has a safe outside area where children can play without parents worrying about the children getting hurt. The area is animal themed and the toys outside are animal shaped and patterned such as a swing in the shape of a lions mane and is yellow and orange to show it is a lions mane. A slide is in the shape of a zebra’s tongue the top of the steps is the head and the handles are the mouth opened wide and the slide is the tongue. Setting 2 – A park is an enclosed area where children can play without parents having to worry about their child going out of the park onto a street near a main road. There may be different parts in the park that are specially designed for each age range. For example: Babies/small children there may be a soft play area, bucket swings that a child can be harnessed into, small low sit on toys and a small slide. Aged 6 -10 children there may be a bigger slide, seesaw, roundabout, swings, small trampolines, climbing frames and tyre swings. Teenagers there may be basketball courts, tennis courts, football nets, running track, climbing wall/ abseiling wall, golf course, wire swings, zip wire, a weather pitch for all sports and a big trampoline that has a net around it to keep them safe whilst jumping. Setting 3 – The beach is a large area containing sand and water. The children like making sand castles. They also like feeling the different textures e. g. Water and sand mixed together. The children also have a chance to have a donkey ride. D7) There are also ramps for access for wheel chairs, push chairs/ prams. On the beach there needs to be parental supervision. D2) Age range for zoo – between 18-24 months to 16years Stage of play for the zoo is spectator aged between 18 months – 24months to 4 years and co – operative play for aged 4+ children. Age range for park – 2 years to 16 years Stage of play for the park is spectator 24 months to 4 years and co –operative for aged 4+ children. Age range for beach – 2 years to 16years Stage of play is spectator 24 months to 4 years and co –operative for aged 4+ children. Co – operative play is where children play together with shared goals. Play can be quite complicated and children are supportive. D3) The type of play that goes on is: Zoo – physical play Park – pretend play Beach – discovery play Zoo – At the zoo children would be involved in physical play. They would do this by finding different equipment to play on. Using all the different equipment they would exercising which would form their muscles, stamina, balance and Co-ordination. (Tassoni P, Hucker K, 2005, Pg 163) Park – At the park they would find different equipment to play on. They would pretend to act out things and pretend that they are other people. This will enable children to use their imagination and develop their own imaginative ideas. (Walker M, Beaver, M Brewster, J Neaum, S and Tallack, J 2008 Page 195) Beach – They would discover sand and water. They would also discover mixing sand and water. They may find shells, crabs, star fish and jelly fish. D4) Zoo is physical play – An example of a zoo play area would be playing on the monkey bars which would be developing their gross motor skills. This will develop whole body and limb movements, co-ordination and balance. Walker M, Beaver, M Brewster, J Neaum, S and Tallack, J 2008 page 194) Park is pretend play – An example of pretend play at a local park would be a child playing on a climbing frame that has a wheel on it and they are pretending it is a ship/boat, aeroplane/helicopter. Beach is discovery play – An example of a beach would be discovering different shells, sea life, boats, and textures of sand by building sand castles. Mixing sand and water together to make sand pies. Developing knowledge and understanding of the world. D5) Beach discovery play and Maria Montessori theory. The main points of Maria Montessori’s theory are: Children pass through particular development stages. This is the essential for the child to be able to learn. * Montessori developed a structured education programmed based on these stages, including a number of specially devised pieces of equipment that encourage children to develop certain skills. You read "Childcare and Education Unit 4" in category "Papers" * Limited emphasis is placed on counting, reading and writing these will follow once the basic social and emotional development has taken place. * A Childs natural will to learn should be encouraged to foster a lifelong motivation for learning. * Children should be encouraged to work alone. Montessori felt the best learning occurred when children were focused, silent and completely absorbed in a task. * Montessori did not believe in free play and did not encourage children to develop their own ideas –play needed to have a learning focus. (Garhart M C, 2000, Pg 21-37) Maria Montessori believed that children learn by doing practical activities and by playing outdoors. D6) Setting 1 – zoo adventure play area * In the adventure play area with children aged 18-24 months to 16 years, an obstacle course could be arranged to include either a route over a high climbing frame or a lower route through it. The risks would be bumping into others, slipping and falling. I have chosen this activity as it will allow children to understand risks e. g. heights, bumping of the body parts. The challenge would be learning their limitations. Setting 2 – park In the park with children aged 2 years to 16 years, a park play area could be set up in the shape of a trim trail to include a variety of apparatus that provide challenges. The risks would be bumping into others, slipping and falling. The risks that the children will learn to understand are bumping into other children, slipping on play equipment and falling off of play equipment. The challenge that they might have to overcome is to see how high they can swing on a swing whilst feeling comfortable. Setting 3 – beach On the beach with children aged 2 years to 16 years, provide activities e. g. digging and making sand castles which challenges them to be sensible when handling the sand. The risk would be getting sand in their/other people’s eyes, risk of drowning in the sea, risk of being bitten by crabs and getting stung by jelly fish. The risks could be getting sand in their eyes, getting bitten by animals and drowning in the water. The challenge they will have to vercome is learning about what can happen if they touch certain animals. C1/D7) Setting 1 – zoo adventure playground Challenge and risk activity chosen in (D6) was obstacle course. Resources that would be used: * Climbing frame with monkey bars, lower and higher side. * Tunnels. * Under and over bars. Health and safety equipment: * Safe area. * Helmet. * Knee pads and elbow pads. * Safety mats, non slip floor. * Supervision. * Appropriate footwear, clothing. These resources have been chosen because: For children’s own welfare and safety. They allow children to achieve the learning outcomes that have been planned for. They meet individual children’s needs- D7. Provides different levels of play for age range and ability. Setting 2 – park Challenge and risk activity chosen in (D6) was trim trail. Resources that would be used: * Apparatus e. g. swings, balance walking logs, climbing nets, tyres, swinging logs. Health and safety equipment: * Safe area. * Knee pads, elbow pads. * Helmet. * Supervision. * Appropriate footwear and clothes These resources have been chosen because: For children’s own welfare and safety. They are appropriate to age range and stage of development of the children. They meet individual children’s needs – D7. Setting 3 – Beach Challenge and risk chosen in (D6) was digging sandcastles. Resources that would be used: * Spade. * Bucket. Health and safety: * Clean area. * Safe area. * Goggles. * Supervision from parent’s/carers. These resources have been chosen because: Encourages exploration. Encourages open minded play. They meet individual needs – D7. B1) Giving children activities that challenge them and make them understand risks by: Build’s up resilience as they become more aware of challenges that they will experience in the future and it will help them to become more comfortable, confident when faced with the kind of challenge. Bruce D. Perry M. D. Ph. D Professor of Child Psychiatry, Department of Psychiatry and Behavioural Sciences). Develops an awareness of potential hazards. Younger children’s awareness of hazards is further raised through staff’s gentle reminders, for example, prior to activities, such as cooking. Children benefit from ind ividual towels and soap dispensers, which reduce the risk of cross? infection. To, ensure that the risk of potential hazards is minimised. Children also develop confidence and self-esteem because staffs build positive, trusting relationships with them. (Ofsted Creche report) Prevents boredom. As young children don’t understand time the way grown-ups do but boredom is not always a bad thing, it can also get children thinking creatively and can pay to take a more active role in preventing boredom. (Sanders, M. R. ; Christenson, A. P. (1985). Pg’s 13, 101-117). Builds confidence. As they do the activities again again they will have confidence in doing the activity as they will know how to do it. Potential learning opportunity such as they learn that you have to follow instructions to get to the end product. Provides mental stimulation. E. g. helps children to function for longer. Maria Montessori developed a method for young children, which was rooted in the senses and involves manipulating everyday objects and following highly structured activities that engage children but rarely allow them to fail. Develops essential life skills. E. g. money, telling the time, addition/subtraction and measurements etc. Activities that provide children with a challenge and risks: Climbing frame – know their own limitations but not put off but to overcome it and be determine. Hopefully next time they won’t climb as high and only go half way so they learn from previous times. B2) Adult led sessions are often used to introduce children to exploration and investigation through play. This helps them to develop their own play agenda and ideas. Children appreciate adults who help to keep their play flowing as long as they don’t take over. How they would do this? Exploration: Involve them in activities. E. g. Building Sandcastles, Finding sea shells and stones. Encourage them to learn about new things. For example colours, numbers and letters. Plan activities that relate to children’s experiences. E. g. Places were on holiday. Encourage activities that encourage exploration. E. g. Making ice or jelly. Offer a variety of activities. E. g. collage making, beading or outdoor play. How they would do this for investigation: Provide equipment. E. g. Bucket and spade or binoculars and magnifying glass. Provide plenty of time. To allow children to finish the activity so they get the whole potential. Present activities that allow solving problems e. g. floating and sinking. Allow the children to work together. So they can work as a team member and listen to other children’s ideas and try to solve things together. Introduce new subjects and topics. To help develop further knowledge. A1) Name of theorist wrote about in D5 was Maria Montessori. Maria’s main ideas and theories are: Children pass through particular developmental stages. This is essential for the child to be able to learn. Montessori developed a structured education programme based on these stages including a number of specially developed pieces of equipment that encourage children to develop certain skills. Limited emphasis is placed on counting reading and writing. Children should be encouraged to work alone. To encourage confidence in what they think. Montessori did not believe in free play and did not encourage children to develop their own ideas. Influences on today’s practice: There are many Montessori schools throughout Europe usually privately run. The method promotes a carefully planned environment that neither allows children total freedom nor imposes activities on them. Some nurseries follow the plan completely and purchase Montessori equipment and use her theories with a flexible programme. (Garhart M C, (2000) Page 21-37) What difference (if any) might there be if the adult was aware of this theory? If the adult was aware of the theory the adult would be aware of discovery play and be able to plan activities in more depth. They will also be aware of the benefits of discovery play. How do you think the theory will affect an adults understanding of children’s play? They might think that something that the child is playing is not discovery. So this might not give the children as many opportunities. A*) The role of the adult in providing activities and supporting children’s play is to provide relevant resources to enable children to do specific activities e. g. ard making needs – card, glue, sticking things/materials. An adult also sets out a play area for the children to play in. Adults make suggestions to widen the children’s knowledge and to support them when playing. Adults should also ask the children questions to develop their understanding. The adult considers the children’s needs e. g. provide activities for different levels of needs â€⠀œ (D7). I had no idea that there was so much to play. I had no idea that there was a lot of planning towards play and how play was actually structured rather than just giving a child a toy and telling them to play. I am now more confident in advising children when they are playing. I am now in a better position as I would be able to extend opportunities by asking the child questions. I have learned all the different stages and types of play. The types of play are:| The stages of play are| Creative play. | Solitary aged 0-2 years. | Pretend play. | Spectator aged 2-2 and a half years. | Physical play. | Parallel aged 2 and a half – 3 years. | Manipulation play. | Associative – 3 – 4 years. | Discovery play. | Co – operative aged 4+ years. | Bibliography websites used www. teachingexpertise. com http://nationalstrategies. standards. dcsf. gov. uk www. ofsted. gov. uk Www. raisingchildren. net. au Bibliography books used Tassoni P, Hucker K (2005) Planning Play and the Early Years 2nd Edition. Oxford – Heinemann (Page 163) Walker, M Beaver, M Brewster, J Neaum, S and Tallack, J (2008) Child care and Education CACHE Level 2 Cheltenham; Nelson Thornes LTD (Page 195) Garhart M C, (2000) Theories of childhood—an introduction to Dewey, Montessori, Erickson, Piaget and Vygestsky. Redleaf Press – Yorkton (Page 21-37) Sanders, M. R. ; Christenson, A. P. (1985). A comparison of the effects of child management and planned activities training across five parenting environments. Journal of Abnormal Child Psychology, Pages 13, 101-117. Professional People Bruce D. Perry, M. D. , Ph. D. , is the Thomas S. Trammell Research Professor of Child Psychiatry, Department of Psychiatry and Behavioural Sciences, Baylor College of Medicine; and Chief of Psychiatry, Texas Children’s Hospital, Houston, Texas. How to cite Childcare and Education Unit 4, Papers

Healthcare Administration

Questions: 1. Fully describe what the Common Law is?2. Explain the concept of "forseeability".3. What is ERISA and how does it affect health insurance? 4. Explain two proposals for Tort Reform. Answers: 1. Common law: The common law is a court decision that may change over time. The health care industry is one of the huge industries in the US. The health care law can affect those people who provide, receive and pay for, regulate the health care services. The law is consisted by the rules. The local people in the society must abide these rules. The Common law is derived from the judicial decisions. It is a judge-made-law. The common law was created when the judiciary process interprets previous legal decisions with respect to a case. It suggests to laws, which depend on the society and principle of the culture. These principles are used in the court cases. In the United States, common laws are used to guarantee parallel outcome for the same cases. The higher court could make a decision on a case and the lower court must follow that verdict. If the court finds a case different from previous cases heard by other courts, its verdict is likely to build precedent for future cases on that topic. The term common law was first coined in the 12th century during the supremacy of Henry II of England. The newly formed common states of America followed their personal forms of common law, detach from the other federal law. The federal courts of the country use the common law when deciding federal cases. In some cases, federal court might hear a case under the state law. If the court ordain a case to be fundamentally dissimilar from previous cases heard by other courts, its verdict is likely to make precedent for future cases on that topic. In the United States, the Supreme Court rules on the common law in assortment cases. The common law can be diff erentiated into two parts such as pure common law and interstitial common law. The pure common law arises from the traditional and implicit authority of court. On the other hand, interstitial common law consists with the judicial interpretation of the constitution. Therefore, the basic purpose of the common law is to establish different facts such as locate related status, past cases that appertain. 2. Foreseeability Concept of Foreseeability: the foreseeability suggests the proximate cause in the law of negligence. The proximate cause might involve the primary cause of the injury to any individual. It is a concept used in tort law. Foreseeability is primarily used to limit the liability of a party to his act that might create a risk of foreseeable harm to any individual in the society. It indicates that individual can understand the effect of the harm caused by a party in the society. Under the negligence law, it has been clearly said that the every individual should perform his or her act properly to avoid the harmful effect. It could facilitate to reduce the risk of the injury to any individual in the society. Most of the time, foreseeability causes the physical injury to the person. In the contract law, the concept of foreseeability is used to prevent the consequential damages to those cases that are predictable. It is the leading choice to determine the proximate cause. The law restricts the scope of accountability based on the type of damage and the mode of the impairment. However, it does not include the extent of the injury. It can be explained such as unforeseeable type of harm and unforeseeable manner of harm. In unforeseeable type of damage, an individual who cause grievance to other person is not liable if the category of injury is not created by applying force. It is under the negligence act. On the other hand, unforeseeable way of harm occurs when an individual cause injury to another person is not legally responsible for a superseding cause. 3. ERISA and its effects on Health insurance The federal law suggests The Employee Retirement Income Security act of 1974. It sets least standard of most voluntarily established pension and the health plans in the private industry. The prime role of this law is to provide the protection for individuals in the society. It requires the plan for providing the plan information to the participants about plan features and funding. ERISA also grant fiduciary liability for the people who control and manage the plan assets. It requires a plan to set up a objection. ERISA appeals procedure for the participants to get benefits from their individual plan. The law provides rights to the participants to appeal for reimbursement and breaches of fiduciary responsibility. There have been number of amendments to the ERISA act. It expands the protection to health benefits plan for participants and beneficiaries. One of the important amendments is the Consolidated Omnibus budget Reconciliation Act (COBRA). It allows some workers and their family t o get the right for continuing their health coverage for a limited time after certain events. A further important amendment is the Health insurance Portability and Accountability Act (HIPAA) that provides new protection for the working Americans and their families. However, ERISA does not provide the group health plan. States can indirectly regulate the healthcare plans, which provide the benefits through insurance contracts. It also raises money by imposing premium taxes. However, they cannot do the same thing with self-funded plans. State regulation of the employee benefits can cause three problems such as cost of taxes, cost of dealing with substantive and the cost of identifying. As per the law, the court decided that any individual could not recover any damages as he has suffered by wrongful denial. Moreover, it does not cover punitive damages. Therefore, it can be assessed that over the years, ERISA has become less employee friendly. 4. Tort reform proposal 1st proposal Most of the people do not know whether they are applicable for claiming the benefits. Moreover, they do not aware of their protection. The temporarily disabled people want their medical bills and other injury related expenses. The tort system actually delayed the system of providing benefits to the victim. In case of high amount, the tort system takes long time to investigate the incident and after that, the victim gets the benefit. Therefore, it is a lengthy process. It is proposed to implicate trade-off that would reduce nearly all short-term disability cases from the tort system. However, the trade-off would be a difficult task, as it would be based on the typical arrangements that many employee already have. 2nd proposal Many people cannot work due to their disability. It makes them deprived of doing normal activity in daily life. Many people have been suffering from serious and permanent impairment or disfigurement. Therefore, it is proposed to reshaping the tort law so that those people could easily get the compensation. Through the engagement of reshaping the compensation system, the tort system could provide better support to the victims. The modern compensation must be incorporate in each department of the tort system. Once again, a trade is proposed to make victims and defendants better off. In the modern compensation policy, the victims should not provide the large amount of their benefit to the lawyers. Therefore, the tort defendants are required to pay successful tort plaintiffs reasonable legal fees. On the contrary, many victims do not bother about the benefits of the tort system and they sort out the issues by their own. This system must be changed.