Environmental Issues Associated with Paints and Varnishes Essay Example for Free

Environmental Issues Associated with Paints and Varnishes Essay The paint and coatings manufacturing industry is one of the major chemical processing industries. The major environmental impacts of paints and varnishes are concerning their content of solvents and other chemicals. There is a need to encourage manufacturers to use less of these substances, and to ensure proper environmental management throughout the manufacturing process. Procurement of paints and varnishes is classified as having a high environmental profile and some risk of developing world supply chains. Summary of Life Cycle Record Raw MaterialUse †¢Raw materials include solvents, pigments, dyes, and other chemicals. In addition, other raw materials are used to thin oil-based paints and stains or to clean up the residues left behind, such as turpentine and mineral spirits. †¢Some paints contain petroleum-based by products of the oil industry†¢The main uses of paints and varnishes are for architectural use (e.g. DIY), industrial use and automotive use. †¢VOCs may be released during use. †¢Some paints can emit noxious gases such as toluene and xylene, which are known carcinogens. ManufactureWaste Management/Disposal †¢The main components of the manufacture process are synthesis in a reactor, filtration, blending with other additives and packagingPaint related waste is often categorised as hazardous (special waste) due to its chemical content. Waste Management/Disposal options include: †¢Recycling †¢Incineration Key Impacts and Priority Mitigation Measures The key impacts in relation to paints and varnishes are: †¢Raw materials are often non-renewable and can be based on oil solvents †¢Solvent release, more specifically releases of VOCs to the atmosphere, which contribute to ground-level ozone, global warming and some have specific health effects. (There are more VOCs in gloss than emulsion) †¢Dyes and other chemicals used can also be harmful to health and the environment. †¢Wastewater and other solutions from washing of brushes and other application devices might contain these pollutants. †¢Energy is used during the processing stages. †¢Packaging materials are likely to contain traces of product / solvent residues, which can lead to direct release to the environment through evaporation. †¢Some paints can emit noxious gases such as toluene and xylene, which are known carcinogens. In 1989 the World Health Organisation’s International Agency for Research on Cancer found that professional painters and decorators face a 40% increased chance of contracting cancer. †¢Paint waste at end of life is classed as a hazardous (special) waste. Control Measures – Raw Materials and Manufacture: †¢Implement a structured and independently verified Environmental Management System (EMS) such as ISO 14001 or EMAS. This will help the company use resources efficiently and prevent or minimise pollution. †¢Ensure systems are in place to control loss and wastage of toxic ingredients, in particular solvent management plans. †¢Avoidance of the use of heavy metals such as cadmium, lead, hexavalent chromium, mercury and arsenic; and other substances where possible. †¢Where possible replace toxic and persistent ingredients such as oil, solvents, chemicals and other hazardous substances with less toxic and more degradable ones. Particularly focus on lower solvent alternatives where possible. Control Measures – Procurement Action: †¢Ensure suppliers selected have a high awareness of the potential environmental impacts and are taking the appropriate mitigation measures. †¢Encourage suppliers to develop environmentally â€Å"safer† products and in particular minimise the use of solvents and other chemicals and minimise waste during processing. †¢Avoid oil or solvent based paints where feasible. †¢Be aware that some water thinnable paints contain more chemicals than the oil-based paints they are intended to replace. †¢Select suppliers that can provide more information regarding the specific raw materials they use, and also provide guidance on environmentally safe use and disposal (including packaging). †¢To avoid wasteful use of paints and varnishes ensure the purchase of only the amount required for the job. †¢Where feasible, select a supplier that will allow the return of toxic material packaging for reuse. Control Measures –Use and Waste Management/Disposal: †¢Ensure employees are trained in actions to be taken in relation to waste minimisation, waste management and health and safety †¢Ensure proper labelling and storage of toxic and hazardous materials in secure, bunded areas. †¢Ensure user is trained in instructions for use including wearing of protective equipment such as facemasks, storage conditions (e.g. placing lids on containers when not in use) and cleaning of tools. †¢Ensure adequate ventilation during application. Disclaimer: This document is based on publicly available information and provides details of the environmental impacts associated with paints and varnishes. It contains a description of most commonly used raw materials and the environmental impacts and by-products released. It should be noted that there might be some other commodity types and manufacturing processes not covered within this document.

The Republic: Protagoras, Gorgias, and Meno :: Philosophy Morals Neo Aristotelianism Papers

The Republic: Protagoras, Gorgias, and Meno One vigorous line of thought in contemporary moral philosophy, which I shall call ‘Neo-Aristotelianism,’ centers on three things: (1) a rejection of traditional enlightenment moral theories like Kantianism and utilitarianism; (2) a claim that another look at the ethical concerns and projects of ancient Greek thought might help us past the impasse into which enlightenment moral theories have left us; (3) more particularly, an attempt to reinterpret Aristotle’s ethical work for the late twentieth-century so as to transcend this impasse. The "Neo-Aristotelian" Rejection of Plato Neo-Aristotelians like Martha Nussbaum(1) and Alasdair MacIntyre,(2) in spite of their many differences,(3) are therefore united not only in their positive turn to Aristotle but also in their rejection of Plato and Plato’s Socrates.(4) And yet some features of these rejections invite further reflection. Nussbaum, for example, consistently recognizes that the Socratic-Platonic project requires us to remake ourselves: "In short, I claim that [in the Protagoras] Socrates offers us, in the guise of empirical description, a radical proposal for the transformation of our lives." (FG 117, LK 112) But to what extent has she done justice to the particular kind of remaking Plato has Socrates offer us? More pointedly, does she acknowledge the extent to which Socrates aims at focussing his interlocutors on a process of questioning, rather than simply handing doctrine over to them?(5) Or has her Socrates been flattened out, his dialogical style rendered monological, so as to support her ov erall thesis more easily?(6) As for MacIntyre, does he see clearly enough the parallel between his own work and Plato’s when he says that in his earlier dialogues "Plato is pointing to a general state of incoherence in the use of evaluative language in Athenian culture" (AV 131)? Mutatis mutandis, isn’t this precisely what the opening chapters of After Virtue attempt to show? And to what extent must MacIntyre’s "quest for the good" in his crucial chapter "The Virtues, the Unity of a Human Life and the Concept of a Tradition" be committed to a Platonic, rather than Aristotelian, notion of the good? When he says "now it is important to emphasize that it is the systematic asking of these two questions ["What is the good for me?" and "What is the good for man?"] and the attempt to answer them in deed as well as in word which provide the moral life with its unity" (AV 219, emphasis added), isn’t it Plato’s Socrates who serves as the ultimate source of i nspiration here?

Differences in Competencies between ADN vs. BSN Essay

According to the society of Human Resources Management, competency means the knowledge and skills required to perform a job, which all contributes a positive outcome. Even though the competency among ADN and BSN are almost similar, there are slight variations based on the departments where the nurse work, such as management level of care and neonatal department. Good start of an introduction. Consider a topic sentence here that states: this paper will describe†¦Ã¢â‚¬ ¦.. An Associate Degree Nurse is one who completed the 2 year program or 3 year diploma this is not true, these 2 are different course by a school of nursing, community, or junior college. They demonstrate competencies in various aspect of patient care. ADNs are competent to perform assessment by collection of patient’s health history, including past medical and surgical history. They perform the physical assessment by gathering information, such as height and weight, vital signs, and head to foot assessment, including all body system. They are also competent to perform cognitive, psychosocial, spiritual, and functional level assessment. After assessing the patient, they find out the nursing diagnosis using their knowledge, skills, and experience. The ADN analyzes the patient’s condition using their age, cultural diversity, and risk factor. He/she then formulates and plans the care by prioritizing the patient’s need based on Maslow’s hierarchy needs, in which patient’s safety is the first importance. They formulate the plan of care by critical thinking, reflection, and problem solving skills. Before they implement the treatment regimen, they let the patient make health care choices by providing accurate and reliable information. The ADN are competent to delegate the patient care to other authorized health care personnel by giving relevant instructions and supervisions. They implement the treatment within his/her accepted professional nursing practice in a different clinical setting. They also make sure to give teaching about the treatment, which includes the effects and side effects of drugs and expected outcome. These all help the patient to alleviate their anxiety about the health status. Finally, they evaluate the outcome and effectiveness by reassessing and continuous monitoring. Moreover, ADNs provide physical competencies like gross and motor skills, strength, and mobility by moving and positioning the patient by using proper body mechanism. Their sensory perception provides a safe environment. They are competent in life saving practices, such as cardiac monitoring and airway management. They provide patient care by giving I.V, oral medications, blood transfusions and wound care. They demonstrate care and respectful behavior towards the patient, family, and other co-workers. Need to reference data within the text Bachelor of Science Degree in Nursing is a 4 year bachelor program accredited by a college or university. A BSN has the same medicalbedside nursing skills of an ADN. He/she provides the same patient care by assessment, diagnosis, planning, implementation, and evaluation. They also have physical competencies and sensory perception. Apart from that, they do their clinical judgment by using their critical and analytic thinking, which they earned through researches and evidence based practices. They have sufficient emotional stability to be responsible and accountable during a highly stressful event. They know how to deal with unexpected and changing environment. They show interpersonal skills and communication skills by interacting positively with patient, family, and large communities both in verbal and written form. Their logical and analytic thinking in patient management will help them to acquire higher education. Moreover, they creatively respond to continuously changing health system. Good review of BSN competencies. Again, need to reference within the text. An ADN acquired knowledge and skills from years of experience in clinical practice. They work with patients in a relatively short time. However, a BSN has knowledge and skills based on their researches, evidence based practice, leadership, and management. Their skills help them to provide a better patient care in a short time period. For an ADN, the nursing is a job and have little commitment to the work. Without considering the long term results, they move from one job to another. However, BSN is a career, which is a life time dedication that requires development and on-going learning. They can function at high intellectual levels and carry a strong professional identity and follow code of ethics. They are more accountable, independent, and responsible. Nursing care and approaches to decision-making are different based upon the educational preparations. For example, we had a 50 year old patient in our floor that came with left hip fracture. The patient underwent an open reduction and internal fixation of left hip. After 4 hours of post anesthesia care, the patient came to the floor. The ADN, who is the primary care nurse, assesses the patient and carried out all post-op orders. The patient was drowsy and was on morphine PCA. After 2 hours, the patient suddenly woke-up with pain in the left hip. The ADN gave more pain medicine and monitored the respiratory status. All of a sudden patient complained of shortness of breath. The nurse found the patient’s oxygen saturation dropped to 82 percent. She stopped the PCA pump and put the patient on 2 liters of oxygen yet the patient was complaining about severe pain in her hip. Apparently, the patient continued to complained of chest pain and her oxygen level continued the same. The RN called the charge nurse, who is a BSN. She assessed the patient and went through the patient history. Suddenly, she called the rapid response team; meanwhile, she ordered a stat chest x-ray by thinking that patient had a pulmonary embolism and transferred the patient to ICU. Later, we came to know the patient had pulmonary embolism. In this situation, the RN gave the basic treatments according to the knowledge from her experience. On the other hand, the BSN treated the patient from her critical thinking and high level of knowledge, which saved the patient’s life. Good patient care scenario The ADN can handle the critical patient situation very minimally by using her basic knowledge, skills, and experience with the help of other person. However, the BSN can handle the same situation independently with his/her critical thinking. Different level nurses have different roles in a hospital, even though they have same preliminary education about providing forthe patient care. The job expectations, patient interactions and contact are different in perspective of the RN’s and BSN’s duty. Good conclusion . . References Catalano, J.T. (2003).Nursing now: Today’s issues, tomorrow’s trends. Philadelphia: F.A. Davis. Need to put title into italics Competencies and Performance Standards Essential for Nursing Practice.( 2011) St Louis University. Retrieved from http://www.slu.edu/x19905.xml Hollis, Forster, RN (2011) ADN vs. BSN Retrieved from need to include date of retrieval http://nursinglink.monster.com/education/articles/3842-adn-vs-bsn

Does a Mother owe a Duty of Care to her unborn child - Free Essay Example

Sample details Pages: 9 Words: 2605 Downloads: 5 Date added: 2017/06/26 Category Law Essay Type Argumentative essay Tags: Childhood Essay Duty Essay Did you like this example? ASSIGNMENT 1: TOPIC 2 OVERVIEW Traditionally, legal protection was rarely granted to unborn child and in the event they were granted such protection, it was strictly dependent on their live birth.[1] Since then, the law governing a motherà ¢Ã¢â€š ¬Ã¢â€ž ¢s liability for prenatal injury has evolved and varies drastically across many jurisdictions. For example, in Canada, the courts generally take into account several policy factors to grant them immunity from liability. It is to be expected that a large majority of society would accept the proposition that a mother is required to care for and protect her child for many reasons such as emotional and moral reasons. Don’t waste time! Our writers will create an original "Does a Mother owe a Duty of Care to her unborn child?" essay for you Create order However, it is unclear whether such a percentage would agree with the fact that a mother would be liable for causing prenatal injuries to her unborn child. Perhaps the most important issue of granting mothers full immunity is that the child would not be compensated for their prenatal injuries from their mother and also from third parties like insurers. This article will examine the current law across various jurisdictions like Canada and the United Kingdom (particularly the various policy considerations adopted) in order to ascertain the most suitable approach to be implemented in Australia, since the question whether a mother owes a duty of care towards her unborn child is still unsettled in this jurisdiction. This article will also consider arguments for and against imposing a duty of care. Lastly, it concludes with a suggestion that a mother should not be liable for causing prenatal injury to her unborn child other than in motor vehicle accidents[2] and why this will be the mos t appropriate approach. INTRODUCTION Essentially, a duty of care is à ¢Ã¢â€š ¬Ã‹Å"an obligation imposed on a person to take reasonable care to ensure that they do not cause another person to suffer harmà ¢Ã¢â€š ¬Ã¢â€ž ¢.[3] The relationship between a parent and a child is one such circumstance that draws such a duty of care to be imposed in some jurisdictions. It has been accepted by many that the duty of care outlined above will only accrue when a child is born and possesses legal rights.[4] Having said that, some commentators are of the view that since a fetus is completely dependent upon his mother for nourishment and life, a pregnant woman should owe a similar duty of care to her unborn child.[5] It is without a doubt that the right of an unborn child to sue its mother will bring about several ethical and moral issues that will put a strain on family ties. In Australia, when a child is born it is automatically entitled to sue for breach of rights.[6] The courts have extended this view to include situations wh ere the unborn child sustains injuries prior to being born.[7] It is well established that the courts have held third parties like negligent road users[8] and doctors[9], liable for injuries inflicted onto an unborn child. Although the child possessed no legal rights when the damage was inflicted, it materializes when it is born and hence, reflects the laws of negligence which states that a cause of action does not accrue until damage or harm is suffered. Conversely, the courts are reluctant to apply such standards of care when it concerns prenatal injuries inflicted upon an unborn child by its mother resulting in à ¢Ã¢â€š ¬Ã‹Å"maternal immunityà ¢Ã¢â€š ¬Ã¢â€ž ¢ for such injuries. Currently in Australia, a mother owes no such duty of care towards her child except in the event of road accidents.[10] It should be noted at this stage that whilst Australia has not applied such a duty of care in such circumstances, the courts have neither rejected it completely[11], unlike the appro aches adopted in Canada and United Kingdom. CURRENT LAW CANADA In Canada, policy factors have to be taken into account before reaching a decision as to whether a mother owes a duty of care to her unborn child. This issue was dealt with in the landmark cases of Winnipeg Child and Family Services (Northwest Area) v G (DF) [1997] 3 SCR 925 (Winnipeg Child and Family Services) and Dobson (Litigation Guardian of) v. Dobson [1999] 2 S.C.R. 753 (Dobson), where the Supreme Court of Canada had first tackled this issue. Dobson involved a claim against a pregnant mother for causing injuries to her unborn child due to her negligent driving. Her fetus was apparently damaged in this and had to be delivered prematurely via caesarean section on the day of the accident. As a result, the child was born with cerebral palsy. A tort claim was brought by the maternal grandfather on behalf of the child in order to claim from his fatherà ¢Ã¢â€š ¬Ã¢â€ž ¢s insurance policy so as to cover the damages caused by negligent driving. The majority in this case found that a pregnant woman should not be held liable in the situation as a claim for negligent driving should be treated no differently to any other negligent acts of the mother.[12] McLachlin JJ goes on to add that imposing such a liability would restrict a womanà ¢Ã¢â€š ¬Ã¢â€ž ¢s rights. Specifically à ¢Ã¢â€š ¬Ã‹Å"they would lose their liberty and not be treated equally with other women in societyà ¢Ã¢â€š ¬Ã¢â€ž ¢[13]. The majority then went on to cite the test laid out in Kamloops[14]. Following Kamloops, the Court said a duty of care is recognized if the involved parties are closely related and if the issue raises questions about public policy. One might argue that although a fetus and its mothers are usually seen as one person, the Court in this case addressed the issue as if they were two separate people. It is also vital to note that the à ¢Ã¢â€š ¬Ã‹Å"reasonable pregnant womanà ¢Ã¢â€š ¬Ã¢â€ž ¢ standard of care is an objective test. The majority in this case deemed it to take into account in this case[15] as it will raise many issues regarding a pregnant womanà ¢Ã¢â€š ¬Ã¢â€ž ¢s personal lifestyle choices which will have a negative impact on her privacy and way of life. Eventually, the majority came to a conclusion that public policy factors associated with imposing a duty of care on mothers towards their unborn child à ¢Ã¢â€š ¬Ã‹Å"are of such a nature and magnitude that they clearly indicate that a legal duty of care cannot and should not be imposed by Courtsà ¢Ã¢â€š ¬Ã¢â€ž ¢.[16] Hence, the Court held that the public policy considerations were paramount and outweighed any sufficiently close relationship between the parties that gave rise to the duty of care and that the mother did not owe a duty of care her unborn child even in circumstances where it involved motor vehicle accidents. It should be noted that Australian courts reach a different decisions as times due to the fact that emphasis is not placed on applying the public policy considerations in such cases. Also, when it concerns motor vehicle accidents in Australia, the mother is held liable for prenatal injuries caused to her unborn child if she was negligent without weighing the public policy considerations. In Winnipeg, the Supreme Court of Canada held that a pregnant woman who was addicted to glue sniffing could not be taken away against her will in trying to protect the interest of her unborn child. The Court concluded that they had no jurisdiction to interfere in such matters and that it was beyond the scope of the Courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s power to detain a pregnant woman against her will. As such, the Court stated that, à ¢Ã¢â€š ¬Ã‹Å"To extend the law of tort to permit an order for the detention and treatment of a pregnant woman for the purpose of preventing harm to the unborn child would require major changes to the existing law à ¢Ã¢â€š ¬Ã‚ ¦ these are the sort of changes which should be left to the legislatureà ¢Ã¢â€š ¬Ã¢â€ž ¢.[17] UNITED KINGDOM The current law in the United Kingdom surrounding this issue is very similar to that adopted in Australia.[18] The Congenital Disabilities (Civil Liability) Act 1976 (UK) grants mothers a legal immunity from liability for causing prenatal injuries to her unborn child. However, the court cited that a legal duty should be imposed where it is the result of a motor vehicle accident.[19] Section 2 of the Congenital Disabilities Act states: A woman driving a motor vehicle when she knows (or ought reasonably to know) herself to be pregnant is to be regarded as being under the same duty to take care for the safety of her unborn child as the law imposes on her with respect to the safety of other people; and if in consequence of her breach of that duty her child is born with disabilities which would not otherwise have been present, those disabilities are to be regarded as damage resulting from her wrongful act and actionable accordingly at the suit of the child. In enacting this leg islation, the United Kingdom Law Commission also took into consideration public policy factors that was applied in other jurisdictions.[20] AUSTRALIA As discussed above, only a third party, who is not the mother of the unborn child, can be found to have owed a duty of care to the child.[21] In Lynch v Lynch (by her tutor Lynch) (1991) 25 NSWLR 411 (Lynch v Lynch), a mother was found guilty of negligent driving, causing an accident which resulted in cerebral palsy in her unborn child. Public policy factors were not applied in this case as Clarke JA held that the question before the court was à ¢Ã¢â€š ¬Ã‹Å"very narrow and related specifically to road accidents.à ¢Ã¢â€š ¬Ã¢â€ž ¢[22] The court also took into account whether there was a presence of a compulsory motor vehicle insurance in concluding whether the mother owed a duty of care to her unborn child.[23] The majority decision in Lynch v Lynch was affirmed and cited in Bowditch v McEwan [2002] QCA 172 (Bowditch v McEwan). It has been long established that a duty of care is owed to pedestrians and other road users.[24] However, Watt v Rama extended this duty of care to inco rporate fetuses injured in road accidents. In this case, a mother who was pregnant caused injuries to her unborn child as a result of her negligent driving. The child subsequently suffered from epilepsy and brain damage. The mother denied that she owed her unborn child a duty of care whilst it was still in her womb. However, the Victorian Supreme court held that since the child was born handicapped as a result of the injuries sustained while it was still in its motherà ¢Ã¢â€š ¬Ã¢â€ž ¢s womb, attracts a duty of care. As a result, it was immaterial whether the child was born or not when the injury was sustained, so as long as the victim fell into a category of people that would be affected by a negligent act caused by someone else. Although the Australian courts are required to specifically apply public policy considerations in ascertaining whether a duty of care exists, it is not as rigid and explicit as the approach adopted in Canadian courts. ARGUMENTS FOR IMPOSING A DUTY OF CARE There are many factors that needs consideration when a jurisdiction imposes a duty of care that will attract an ethical and legal difficulties. The pivotal argument put forth in cases in imposing a duty of care is that a fetus is solely dependent upon its mother for nutrition in order for it to develop healthily.[25] Hence, it is reasonable foreseeable that any negligent acts would have a undesirable impact on the unborn child. Unquestionably, the proximity test would satisfy the neighborhood principle established in Donoghue v Stevenson.[26] In addition, by imposing a duty of care, a mother will most likely act in the best interests of her unborn child. For example, a pregnant woman might refuse to attend medical checkups or follow medical advice that would benefit the unborn child. Also, she might refrain from harmful activities like smoking and drinking that will negatively impact upon an unborn child. ARGUMENTS AGAINST IMPOSING A DUTY OF CARE. Some factors would prevent such a duty from being imposed due to the repercussions it might have on the society as well as in their personal lives. This mainly revolves around preserving the autonomy and privacy of a pregnant woman.[27] As discussed in this article, Cory J in Dobson v Dobson, made it clear that a pregnant womanà ¢Ã¢â€š ¬Ã¢â€ž ¢s rights must be upheld as first and foremost, she is a human being and should be afforded the same rights as others. The courts are also reluctant on imposing a general duty of care as this would encourage children to sue their parents in negligence. If this trend continues, it could have adverse effects on the relationship between the mother and the child as well as the rest of its family.[28] However, this reason on its own is not sufficient to complete eradicate the duty of care owed to an unborn child. SUGGESTED APPROACH FOR AUSTRALIA? On one hand, it is very important for a mother to consider how her actions might have an impact on her unborn child, however, it is not in the hands of the judiciary to dictate how she should live her personal life as that would interfere with her right to privacy. While Australian courts have not imposed a general duty of care in such cases, it has not been rejected as well. 1 [1] Lenow, The Fetus as Patient: Emerging Rights as a Person?, 9 AM. J. L. MED. 1, 3 (1983). [2] Watt v Rama [1972] VR 353. [3] LexisNexis, Encyclopaedic Australian Legal Dictionary, LexisNexis https://www.lexisnexis.com.au. [4] X and Y (by her Tutor X) v Pal (1991) 23 NSWLR 26, 30 (Mahoney JA). [5] Beal, Can I Sue Mommy? An Analysis of a Womans Tort Liability for Prenatal Injuries to Her Child Born Alive, 21 San Diego L. Rev. 325, 326 (1984). [6] X and Y (by her Tutor X) v Pal (1991) 23 NSWLR 26, 30 (Mahoney JA). [7] X and Y (by her Tutor X) v Pal (1991) 23 NSWLR 26, 41 (Clarke JA) stated that: à ¢Ã¢â€š ¬Ã‹Å"In principle it should be accepted that a person may be subjected to a duty of care to a child who was neither born nor conceived at the time of his careless acts or omissions such that he may be found liable in damages to that child.à ¢Ã¢â€š ¬Ã¢â€ž ¢ [8] Watt v Rama [1972] VR 353; Road Accident Fund v Mtati (332/2004) [2005] ZASCA 65; [2005] 3 All SA 340 [9] Yvonne Joyce McLennan v McCallum [2007] WADC 67. [10] Lynch v Lynch (1991) 25 NSWLR 411 affirmed in Bowditch v McEwan [2002] QCA 172. [11] Kate Wellington, à ¢Ã¢â€š ¬Ã‹Å"Maternal Liability for Prenatal Injury: The Preferable Approach for Australian Law?à ¢Ã¢â€š ¬Ã¢â€ž ¢ (2010) 18 Tort Law Review 89, 90. [12] Dobson (Litigation Guardian of) v. Dobson, [1999] 2 S.C.R. 753 (Lamer CJ, LHeureux-DubÃÆ' ©, Gonthier, Cory, McLachlin, Iacobucci, Binnie JJ; Major, and Bastarache JJ dissenting). [13] Dobson (Litigation Guardian of) v Dobson [1999] 2 SCR 753, [19] (Cory J). [14] City of Kamloops v. Nielsen (1984) 2 SCR 2. [15] Do, Christina and Mapulanga-Hulston, Jackie. The ethical and legal conundrum: Should a mother owe a duty of care to her unborn child? [online]. Journal of Applied Law and Policy, 2013: 5. [16] Dobson (Litigation Guardian of) v Dobson [1999] 2 SCR 753, [76] (Cory J). [17] Winnipeg Child and Family Services (Northwest Area) v G (DF) [1997] 3 SCR 925. [18] Do, Christina and Mapulanga-Hulston, Jackie. The ethical and legal conundrum: Should a mother owe a duty of care to her unborn child? [online]. Journal of Applied Law and Policy, 2013: 9. [19] Congenital Disabilities (Civil Liability) Act 1976 (UK), s 2. [20] United Kingdom, Law Commission, Injuries to Unborn Children, Report No 60 (1974) Cmnd 5709, pp 53-64. [21] Watt v Rama [1972] VR 353 affirmed in X and Y (by her Tutor X) v Pal (1991) 23 NSWLR 26. [22] Lynch v Lynch(by her tutor Lynch)(1991) 25 NSLR 411, 415 (Clarke JA). [23] Do, Christina and Mapulanga-Hulston, Jackie. The ethical and legal conundrum: Should a mother owe a duty of care to her unborn child? [online]. Journal of Applied Law and Policy, 2013: 8. [24] Manley v Alexander [2005] HCA 79. [25] Do, Christina and Mapulanga-Hulston, Jackie. The ethical and legal conundrum: Should a mother owe a duty of care to her unborn child? [online]. Journal of Applied Law and Polic y, 2013: 3. [26] Donoghue v Stevenson [1932] AC 562. [27] Bowditch (by his next friend Bowditch) v McEwan [2001] QSC 448, [10]. [28] Dobson (Litigation Guardian of) v Dobson [1999] 2 SCR 753, [46] (Cory J).