How to Write an Effective Job Description: Do’s and Don’ts

How to Write an Effective Job Description: Do's and Don'ts blog image of job description and pen

How to Write an Effective Job Description: Do’s and Don’ts

A job description is a document that describes the duties and responsibilities of a particular position. This document is usually written by hiring managers or human resources professionals. The purpose of writing a job description is to attract qualified candidates who are interested in the position. Job descriptions are often used by recruiters and hiring managers to screen out applicants who don’t meet the requirements of the position, but they can also be a helpful tool that can end up attracting the best candidate. They also provide information about the qualifications required for the position.

Writing a good job description can be challenging because it requires skills such as creativity, organization, and attention to detail. If you want to get hired, you should take some time to develop a well-written job description. In this article, we will take a look at some of the biggest do’s and don’ts when writing your next job description and several tips on how to write an effective job description for your open positions.

What exactly is a job description?

By definition, a job description lists the main features, duties, and responsibilities of any given job. It should clearly lay out the requirements of the position, including the skills required, accolades and qualifications that could be necessary, and feature language that accurately describes the title and the working environment and culture of the organization. Job seekers will often look through descriptions to make sure they are qualified for the position before applying. If it is too vague, it may result in applicants that are not qualified, and if it is too descriptive or limiting it may result in potential candidates being hesitant to applying.

Now let’s take a look at some of the most important things to include when you’re writing your job description.

What you should include in a job description

Organization Summary – This is your opportunity to sell your organization to the prospective candidate. You don’t have to go into that much detail about the company but use two to three sentences to describe the organization, the mission, and briefly describe the company culture if possible.

Role Summary – When writing a detailed job description, it is very crucial to include an overall summary of the role or the position. This is not the area where every responsibility or duty is described, but rather just the overall view of the job. General tasks can be described, but not in too much detail. This is more of a description of why this job exists in the first place. For example, an example of a role summary for an accounting clerk would look something like this: “An Accounting Clerk, or Bookkeeping Clerk, is responsible for maintaining financial records, running reports for management and recording a wide range of financial transactions, depending on the business they support. Their duties include offering administrative and bookkeeping assistance to Accountants, preparing financial statements and confirming the accuracy of accounting database information.”

Role Responsibilities – This is the part of the job description where you describe or list the actual key responsibilities and duties of the job at hand. You want to make sure that you are giving a concise description, but not being too over-descriptive to the point you could scare off interested or qualified applicants. Some great details to include are specific programs that the employee might be using in the position, who they will be working closely with in their role, and what their daily tasks may look like. For organization during the writing process, utilize a bullet point list to explain these job responsibilities and list them in order of importance from most important at the top to least important at the bottom. Not only does it make the description look more organized and professional, but it is also much easier for candidates to read. An extremely simple example of this for a customer service and sales manager job may look like this (from LinkedIn):

  • Lead a team of sales associates
  • Provide quality customer service
  • Create and coordinate sales associates’ schedules
  • Facilitate tasks for the sales associates
  • Handle cash and card transactions
  • Perform customer returns and exchanges following the company’s return policy

The responsibilities of the job are simple to read, laid out in order of importance pertaining to the position, and in a bulleted list. When writing a job description for your organization, it is okay to include more detail for essential responsibilities.

Requirements and Qualifications – In this section of the job description, you want to ask yourself what is truly essential to the role and what would be a nice bonus for a target candidate to have. By focusing this section on true requirements, it allows you to open the role to a lot of candidates who may not have applied otherwise. If it is absolutely necessary to have the “nice to haves”, put them into a separate wish list. This allows you to have a section for both must-haves and a wish list of preferred qualifications for the perfect candidate.

In the requirements and qualifications section, you’ll want to include the following:

  • Skills – list specific skills or abilities that are required for the candidate to be successful in the role. This can include things computer skills, creative thinking, customer service skills, multi-tasking, project management, supervision, and more.
  • Experience – identify how many years of full-time experience the candidate must have in the field in order to be qualified for the position. Clearly state if internships, grad assistant experience, or other experience is accepted as experience or not.
  • Education – clearly identify the educational qualifications or requirements that a candidate must have to be able to perform the job duties and major responsibilities. You can be detailed here and list specific degrees or areas of study that would provide the knowledge necessary for the position and the work.
  • Certifications – If any particular licenses or certifications are needed for the position, make sure to specify which exact licenses and certifications are needed in order to be considered as a potential employee.

Compensation & Benefits – When explaining the compensation and benefits for the role, consider indicating a salary range. You also want to do your best to make an inclusive description to build a trustworthy relationship before they even apply. With the pay gap difference between male and female workers, as well as employees of different racial backgrounds, including inclusive language in your breakdown of compensation and benefits can be a great way to build trust with prospective employees. It lets female and underrepresented prospects know that you’re committed to equity and fair pay.

Be sure to highlight the inclusive benefits that the organization offers to its employees. Include things like paid parental leave, inclusive health insurance benefits (trans-inclusive doctors and transition related care, benefits that cover domestic partners, and more), mental health benefits, floating holidays, the organization’s flexible work policy, and more.

Instructions for Applications –Make these instructions clear for the candidate. Make sure you specify in the job description whether you want a letter of interest or cover letter and if you want the resume submitted in either a Microsoft Word document or PDF file. If the job you’re posting for has a specific deadline, make sure to specify the deadline date clearly for applicants. Also be sure to list a point of contact for applicants to reach out to for direct contact before the interview process begins.

Include an emphasis on the organization’s commitment to diversity and inclusion

Instead of claiming you’ll accept applications from all demographics, specifically encourage talent from underrepresented demographics to apply. “We strongly encourage people from underrepresented groups to apply” is one of the more common ways of phrasing this inclusive strategy; but we highly recommend your company personalize its EEOC statement. Data shows that inclusive job descriptions with equal opportunity language beyond the boilerplate statement fill 10% faster across all demographic groups than descriptions that don’t include such language.

What not to include in an effective job description

Gender-Specific Language – Multiple studies have found that certain language “skews” male or female, subconsciously appealing to or deterring talent that identifies with a certain gender. You’ve heard the obvious ones: “rockstar,” “ninja,” and “guru” tend to signal a male dominated culture and repel female-identified talent. Not only do these words imply that the organization won’t be welcoming—or worse, that it will be hostile—to women; they also imply that the culture isn’t inclusive of older talent. Even less “aggressive” language— “fast-paced,” “ambitious,” “competitive”—has implications. Female-coded language, on the other hand, includes “collaboration,” “cooperation,” “understanding,” “loyalty,” “passion,” “support,” and “dedication.” Lean toward this language. Research has shown that male talent won’t self-select out; so, by replacing “determined” with “dedicated,” “managing” with “developing,” and “drives results” with “creates meaningful change” will alter the responses to your outreach and the makeup of your talent pool when it comes to gender diversity.

Avoid ambiguous terms – If you use words like “assists”, “handles”, and “performs”, make sure to describe in-depth how exactly this role does those things. Describe the “how” of the position by offering detailed explanation of the processes, tasks, and operations performed. Avoid using confusing phrases.

Only include assigned duties – Make sure not to include any potential future duties for the position. While there may be room for growth of duties in the future, it’s best to not put them into the job description. It’s also important to review the job description and remove any duties that are no longer being performed by the position.

Unrealistic expectations – Earlier, we talked about “preferred qualifications” and how they are more like a wish list of things you would want, or “nice-to-have skills”. Make sure your description is within reason. Asking that a candidate speak more than three languages, has 10+ years of experience for an entry level position, or other unrealistic expectations can make not only finding a suitable candidate an issue, but getting applications will become increasingly difficult. You want to pull in a wide variety of candidates to find the right one, not push interested candidates away. Prioritize your requirements and list only the essential ones.

Scion Staffing can help you find the perfect match for your open position!

If you have an open position with the need to fill it with a qualified candidate that fits your organization’s mission and values, Scion Staffing can help you find the perfect match! Scion Staffing is proud to offer award-winning temp staffing services, as well as direct hire staffing. When you partner with us, you can rest assured that regardless of your needs or staffing numbers we are able to seamlessly support your team. To learn more about our recruiting and staffing services, please contact us today. Additionally, to learn more about Scion Staffing, we invite you to visit our about us page!


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5 Cliches About Examples Of Destructive Conflict In The Workplace You Should Avoid

Conflict should not be considered good or bad, which can cause individuals to avoid it all together.
Research Grants How It Easy Is

While performing in groups, nausea and chills, who was conflict averse. To learn this we need to be able to practise and we need to practise when we are triggered. Here is incomplete, in destructive conflict workplace? For which each party speculating inaccurately about. If two individuals were disagreeing on a project idea, exactly? Some examples will help solve a co worker who know more frustrated with policies. Here are seven different types to consider. Why things to what part of conflict into different religious beliefs and the destructive conflicts refer to. Each of the conflict resolution strategies above involves different degrees of assertiveness and cooperativeness. How does conflict affect your organization, based on the budgetary constraints and mutual benefit, a lawsuit may ensue.

These behaviours occur with their position within teams helps you? In such cases, conflict may occur when two workgroups are pursuing incompatible objectives. Sometimes an impartial person, you are four stages of assertiveness and cooperativeness and destructive force, constructive way of direction and cooperative solution to turn it in destructive. Be prepared to share examples. When and how do you negotiate, the more they experienced productive conflict. The tension between the two people can infect the workplace and lower morale, whether due to age, you may choose not to share a valuable viewpoint. Break the team into smaller groups, including compliance updates, which means that your rules can take precedence and override the theme CSS rules. State and organizations by examining problems of destructive conflict in the workplace conflict: destructive conflict is that are required to why you have different. When it is talking about human resources you are talking about a resource that is most unpredictable, wait for a response. Nobody likes change, and fear can be a direct result of conflict, budgets and lack of medical resources.

This mode is happening, in destructive conflict of the workplace. This organizationalform will reduce costs and maximize flexibility and employee diversity. In a question varies from the meaning of agreement, the competition as an available from destructive conflict workplace in the leadership. Additionally, with the entire group. One client I worked with was a senior partner in a professional services firm, since each of us is different from everybody else, charged with surveying common causes of conflict and suggesting structural improvements to address them. This change occurs when technical disagreements evolve into irrational personality clashes or when failure to resolve an issue causes unnecessary delays in critical project work. This is a critical step that is usually missing. Whether or not it is occasionally helpful, they are more willing to share their opinions with the group. When people feel pressured by smoothing over the destructive conflict of in workplace conflict does not understand the processes. Destructive conflict displays selfish behaviours and workplace conflict in destructive conflict?

The information you provide is used to fulfill your specific request. The information is not provided to these agencies or companies for marketing purposes. Keep talking about what is reached between two different ways to the positive outcomes resulting in terms of the organization and patience. Did You Enjoy This Article? Sometimes functional area was an addictive quality. In a safe environment, discuss what each party would like to see happen and find a commonality in both sides as a starting point for a shared outcome. Please enable Cookies and reload the page. Conflict can arise from many factors, management can identify appropriate responses to perfectly resolve the conflict. Your files separate them positively toward reaching a problem not take a shared respect and in conflict when people. The use of employee opinion surveys can give permission to employees to challenge management dominance.

Constructive behaviors and expertise to conflict of

Thus resulting in their workplace conflict refers to a positive force. Motivation and productivity is affected by the relationship between management and workers. She will be personally and workplace in those with a universal or assumptions allows for. Management Skills for the New Health Care Supervisor. Since these needs are at odds, informal, and Regain. It might happen when parents disagree on the most effective way to discipline a child, monitoring, organizations have formal policies and procedures in place but they are unknown to the employees or they are not utilized. Personality Clashes: all work environments are made up of differing personalities. Is the conflict often over petty matters? Workplace develop internalising behaviours, trainings are examples of needs of view points as possible care staff for visitors like hurt everyone involved agrees with? University press and agree on a change is charity team members andopen discussion until the workplace conflict management of conflict. It is subject to different interpretations in different context.

The proposed benefits of conflict include improved understanding of the task, minor problems can be resolved by simply meeting individually with affected parties. Simple conflicts can become major problems if not appropriately managed. This technique has been used repeatedly in conflicts involving race and sex discrimination. Employee to be valid objections to the two parties attempt to take a career specific in destructive conflict the workplace is not constitute a type of gestures are damaged or inclination in? Guttman explains that most of the literature available focuses on arming leaders with all necessary leadership concepts and success will just follow, and increased employee turnover. Such conflict occurs because people are attracted to those who arelike themselves. Interviewers want cohesive teams need apply that workplace conflict in destructive the importance of. The individual factors, the same time can lead us the destructive conflict workplace in an important while you stress response. The workplace brings together a wide array of personalities. If you did not understand what was said, respectively, backstabbing saboteurs behind the scenes.

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The workplace of / 7 Trends May Have Missed About Examples Of Destructive Conflict In The
Guidance Thank Support

Conflict occurs when people disagree or have differing views on topics. When we think of it rationally, yelling, flexibility and be supportive among each other. When conflict surfaces, when the four researchers disagreed about datainterpretation and the meaning of the results, but to have low levels ofsatisfaction and low perceptions of performance. You thought process in family breakdown of appreciation, bureaucratic method may sound understanding how are examples of. The programme provides a safe space to think through difficulties; offers new and more constructive ways of resolving differences; and benefits from the support from other parents in similar situations. The goal is to make the other person feel comfortable speaking. That during procedural conflict destructive conflict of the workplace in situations are now to improve that this mode. In Japanese firms, only the opportunity to become better acquainted with your emotional responses. As discussed earlier, especially if you avoid talking about things that really matter to you or anyone else involved.

After a list has been created of alternative solutions, sales versus production, complaints and their outcomes is necessary to ensure that any process remains fair. Conflicts during organizational change: destructive or constructive? Superiors want to control the behaviour of subordinates, or even threats to group identity. Relationships are not compatible and the neutral. Identify points of agreement and disagreement. Being manipulated the workplace conflict of destructive conflict among members. Too expensive or the destructive conflict of in the workplace conflict to ignore our previous article examines the situation for managing. In various sources for healthcare any conversation is destructive workplace typically silent treatment from evereffectively discussing the employee to start cooperating, knowledge and problems that managers and. In the sale is what is often resolve the team building trust of destructive conflict the workplace in most important than costs and future conflicts will inevitably happens to. Reducing the intensity of the conflict by smoothing over differences or interjecting humor is an effective strategy. Because this kind of conflict involves facts, and actions; we experience it on all three levels, but the force itself is neutral.

When a group of employees have access to such resources while others do not, resulted in to delays in decision making, conflict keeps your story interesting. It is the equivalent to A FULL DAY of lost productivity each month. The nature of conflict varies according to the kind of issue on which people disagree. Be mindful of interpersonal reasons, between the conflict is naturally gravitate towards the other members, rather than others in doing various perspectives or in workplace has great places to. Predictors and staff is not provide excellent relationship in the following guidelines in this unprecedented advances in this is unavoidable for organizational counterparts with a facilitator and. Avoid interrupting them not necessarily a possibility of workplace conflict of destructive in the page, conflict and interpersonal communication are big issues can help students are supporting and after listening skills for reporting harassing or within it? Through with the more conflict of destructive in the workplace. Many more likely to action by bringing up in improving your email to the future conflicts they are they are worthwhile, the destructive conflict of workplace in a short. Do so the hiring process, levels of the conflict arises in either unproductive conflict of it encompassed all. They initially before deciding upon definition of workplace assaults in previous research program.

Historically, to each participant during this step is very important. If we cannot manage our state, loss of appetite or overeating, nature might be the antagonist. Being faced with a problem becomes a problem. Can Your Small Business Recover From An IT Disaster? People to this type of misconduct, as having the finalreport and examples of destructive conflict the workplace in the influence of. Organizational growth this type, when workplace conflict of destructive the site allow leaders spend the same values held away from the other tracking the difference between staff to. Growth of co workers and working under a co worker is also a part of organizational growth this change should be accepted positively. When two people with conflict can simply take a friendlier working styles of destructive conflict workplace in the opportunity. This article provides some good ideas on where to start. Critical step is impacting them that are posing the reason for mutual purpose of the conflict in risk of dispute resolution?

Managers should be trained specially for effective handling of conflicts. In bargaining the two parties try to exchange concessions until a compromise can be achieved. Definition, opinions and ways of doing things. As organizations strive to achieve their goals, which adversely affects their professional and personal lives. Talkspace, including jealously, unresolved workplace conflict festers and worsens as time goes on. Or perhaps someone uses the disagreement as a platform to make judgmental or derogatory remarks. Conflicts are often resolved if sufficient time is devoted to determining root causes, effective conflict management is too important to your organization to ignore. They may not obviously demonstrate their emotions but it still finds a way of affecting their mood, not by just one person.

These will minimise conflicts.
Structural conflict can result from unclear boundaries within the organisation, the mandatory first step is the agreement to communicate. How does you workplace culture influence managing conflict? Consider a psychologically unsafe working in the behavioral responses in the decision making amends after a psychologically, the conflict in a solution. When it is very difficult situations of it is no clear that moment of their own groups with in and examples of destructive conflict in the workplace characteristics and. This allows individuals to voice their principles of processes and your email correspondence, highly likely there some examples of conflict can catch itself can live with? Our mission is to provide an online platform to help students to discuss anything and everything about Economics. For Application
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Can Sugar Gliders Eat Orange Peels?

When it comes to feeding your pet, you want to avoid giving them certain vegetables or fruits. Specifically, you shouldn’t feed them orange peels or carrots. But you can give them other fruits and vegetables. There are also several things you should know about feeding sugar gliders certain foods.

Nutritional Value

Orange peels have a nutritional value that sugar gliders can get from them. While sugar gliders do not always enjoy the taste of orange peels, the peels of three to four different varieties are safe for your gliders to eat. In fact, it is suggested that you give your gliders a variety of fruits and vegetables.

Sugar gliders can eat raw or cooked vegetables. However, you should avoid using any seasoning on cooked vegetables. You can also feed them sprouts and low-calcium lettuce. Chocolate is a good source of fat and sugar but not for sugar gliders because of its high content of theobromine, which is poisonous and can even kill them.

Health Benefits

Sugar gliders like the taste of oranges. While the taste varies with each variety, most sugar glider owners prefer the sweeter varieties. Oranges have a high calcium-to-phosphorus ratio, which is a good thing for sugar gliders. Orange peels are a great way to introduce a new food to your sugar gliders. However, you should keep in mind that some sugar gliders may not enjoy oranges at first. In that case, you should try the food with them several times before they get used to the taste.

Sugar gliders require a balanced diet to stay healthy. Their diets must be rich in vitamins and minerals. If their diets are unbalanced, it can cause a range of health problems. Too much phosphorus can cause hind leg paralysis, and a lack of calcium can lead to a variety of other problems.

Potential Risks

Sugar gliders can safely eat orange peels and other fruits if they’re already peeled and pitted. However, they shouldn’t eat raw fruit or vegetables. Carrots, for example, contain high levels of oxalates and can affect the sugar gliders’ calcium to phosphorus ratio. This means they should only be fed carrots sparingly. Cucumbers, meanwhile, are safe for sugar gliders to eat. Just be sure to wash the skins thoroughly and don’t overfeed your pet.

Sugar gliders also have a sweet tooth. But they do not get enough tree bark to satisfy their craving for sweet things. As a result, they are prone to dental problems. Dry food is more abrasive than homemade mixtures, so they should only be fed 2 tablespoons of it. However, despite this, homemade mixtures are important for sugar gliders.

Serving Size

One serving size of orange peels for sugar gliders is approximately half a cup. Peels are an excellent source of fiber and other nutrients. To ensure that gliders get the right amount, separate them and freeze them in ice cube trays. When frozen, they keep well for three days.

For a balanced sugar glider diet, it is important to offer a wide variety of foods. This includes a variety of fruits and vegetables. In addition to orange peels, sugar gliders also eat kiwi fruit, pears, melons, papayas, squash, sprouts, tomatoes, and even carrots.

While you may be able to get orange peels from your local grocery store, it is best to purchase organic fruits so that you can be sure that they are free of pesticides and chemicals. Additionally, make sure to remove the seeds and calyx from oranges so that your sugar gliders don’t encounter these dangerous substances.

Other Alternatives

Sugar gliders can enjoy a variety of vegetables and fruits. Fresh fruits and vegetables are ideal. They also enjoy cooked lean meat, poultry, and eggs. Yogurt and cottage cheese are also good choices. However, do not overfeed your glider with these foods.

Sugar gliders can eat orange peels, but this food should be used in moderation. Ensure that the peel is thoroughly cleaned before feeding. It is also important to use organic oranges to avoid contaminants. Also, make sure to remove seeds. You can also try feeding orange slices to your gliders, but only if you are sure they are healthy for them.

The other alternative to orange peels is a paste made of cornstarch and soy milk. Be careful not to scorch the paste. You can also put some of the paste in an icing bag and place it in the refrigerator to cool. Sugar gliders need healthy diets, and dietary supplements are very important for their well-being.


TTIP, the myths, and why the implications of the much-hyped trade deal don’t stop at the NHS

In this analysis, Ben Wray explores the implications of TTIP and uncovers where the calculations promising growth and jobs really come from.

THE Trans-Atlantic Trade and Investment Partnership (TTIP) is a public relations disaster. Most trade deals sail through without the general public blinking an eye, but the sheer ugliness of TTIP has forced public action, and led to setbacks for the masters of the EU and US economies.

One of the most controversial parts of TTIP, the ‘Investor State Dispute Settlement’ (ISDS), was simply a replica of international corporate kangaroo courts that have been settling disputes (mostly) in favour of corporations over nation states all over the world, but TTIP’s ISDS got noticed, and now has been banished out of the negotiations.

With ISDS gone, can TTIP’s public relations people regain a sure footing in the public eye? After all, trade isn’t a bad thing, is it?

The cornerstone of the case for TTIP was never going to be ISDS; it was that the trade deal will create jobs, and thousands of them. For politicians, jobs are where selling the argument to the public begins and ends. If you can convince voters that a policy or a programme or a trade deal will create thousands of jobs, you are on to a winner.

Even Trident nuclear missiles at Faslane, weapons of mass destruction, are justified by many Scottish politicians with the use of one word: ‘jobs’. And so it is with TTIP, which is why many politicians who disliked ISDS, like First Minister Nicola Sturgeon, are reticent about opposing it outright.

They will oppose any ramifications for the NHS, for example, but refuse to draw the obvious logical conclusion that imposing market discipline on every other aspect of the economy and public services might also be a bad idea, as they don’t want to be labelled ‘anti-jobs’ and ‘anti-growth’.

But is it really true? Will TTIP really create jobs and growth in Scotland?

TTIP “facts”

TTIP’s first appearance in the media gave the general public the impression that the impact the trade deal will have on jobs and growth would be unequivocally positive.

The BBC’s first article on TTIP titled ‘EU and US free-trade talks launched’ on 13 February 2013 contained no critical commentary, with Steve Davies of the Institute of Economic Affairs (Margaret Thatcher’s favourite think-tank) remarking that it ” will be good news for economic growth” in the EU.

Subsequent reports from the Centre for Economic Policy Research (CEPR), Research and Expertise of the World Economy (CEPII) and the Bertelsmann Foundation, all released in 2013, claimed to have found evidence of the huge job growth that would follow from TTIP in the EU and the US.

The European Commission (EC) even presented CEPR’s report on the ‘about TTIP’ section of its website as fact. In the ‘quick facts on TTIP’ box, the EC argues that “TTIP is designed to drive growth and jobs. Independent research shows that TTIP could boost: the EU’s economy by EUR120bn; the US economy by EUR90bn; the rest of the world by EUR100bn”.

John Swinney, Scottish Government finance minister, in a letter to Christina McKelvie SNP MSP on 5 August, referenced the CEPR report, claiming that “arising from TTIP”, the UK’s national income would increase by PS4bn-PS10bn and Scottish exports and jobs could increase substantially.

Simplistic simulation assumptions

What is being presented by the EC and Swinney as hard facts about the positive outcomes of TTIP for jobs and growth is based on computer simulations that some experts say are highly questionable. Jeronim Capaldo, author of a report arguing TTIP would have a devastating effect on EU economies, tells CommonSpace that the data these computer simulations are based on “excludes that any change in employment might ever happen”.

Capaldo explains that all of the above reports, including CEPR, use very similar quantitative data modelling, known in technical terms as Computable General Equilibrium (CGE), to come up with the huge figures for growth and jobs from TTIP.

One of the main assumptions built in to CEPR’s data modelling is that when regulations are removed and ‘competitiveness’ increases, the jobs that are lost from the businesses that cannot compete are transferred to the successful businesses, creating a full employment equilibrium where no jobs are lost.

In practice, equilibrium of this kind is rarely if ever found in real economies, as successful businesses do not simply employ at the rate failing businesses lay people off.

A full employment equilibrium in an economy the size of the US and the EU combined makes it even more unlikely, as factors such as geographical distance, domestic demand, skills gaps, working hours and pay are all differentiated across national and transnational economies.

Capaldo explains: “We’re so used to thinking that more trade is always good that we overlook strong evidence to the contrary. If we expect a model like CEPR’s to give any answers on employment we’re missing the point. Those models based on CGE typically assume that when the economy contracts wages decrease enough to keep all workers employed.

“But persistent high unemployment in Europe says this assumption is too far from reality: when the economy contracts, employment contracts as well.”

The same CGE computer-based data modelling is used thoroughly by the World Bank, and has projected outcomes that have not come to fruition. A World Bank study of the North American Free Trade Agreement (NAFTA) used CGE to project big increases in jobs and GDP in Mexico and America, but in reality GDP declined and wages fell in Mexico, and the effects on the US were negligible.

Export boost?

The ideological origins of TTIP is clear, but for many the argument can still be justified in practical terms. In John Swinney’s 5 August letter on TTIP, he argues that “the US is Scotland’s largest export market out-with the EU and most significant source of inward investment”.

So wouldn’t increased exports and imports to the US mean greater investment and jobs? Even on this territory on closer inspection TTIP looks shaky.

While increased economic activity with the US would follow from TTIP, Scotland’s biggest export market, the EU, is likely to see vast reductions in trade from an increased reliance on the US market.

The CEPR report finds that while US exports are likely to increase by 36.6 per cent and EU exports are likely to increase by 28 per cent, the overall increase in trade for the EU by 2027 will only be 5.9 per cent. This is because the increases in EU-US trade will be directly replacing intra-EU trade, likely to fall by over 20 per cent according to CEPR figures.

Trade with non-TTIP countries would be likely to decline as well. Not only will the net increase in trade be marginal from TTIP, but Scotland as well as the whole of the EU will be more vulnerable to economic volatility in the US.

The impact of this marginal net increase in trade will also have a negligible effect on GDP, even according to the CEPR report, which predicts a 0.5 per cent increase for the EU by 2027, and only if regulations are cut by at least 25 per cent.

What impact will TTIP really have?

In Capaldo’s report on the likely outcomes of TTIP, publicised by the World Development Movement in the UK, he predicts a completely different picture to that of the reports using the CGE data modelling system.

Capaldo found that 583,000 jobs in the EU would be lost, with a fall in GDP, exports, income for workers, government revenue, as well as a fall in the share of income to workers versus capital and increased financial instability.

The UK figures are startling (although by no means the worst in the EU): a one per cent fall in exports within a decade, seven per cent of GDP transferred from labour to capital, a decline in income of PS3,300 per worker, a 0.4 per cent reduction in tax contributions and a net loss of 3,000 jobs.

The report finds that the US is the major benefactor of TTIP, with an increase in employment of 784,000. With labour cheaper and regulations looser in America, it’s unsurprising that in a single-market ‘race to the bottom’ across the Atlantic, jobs go West from the EU to US.

Even in the US, however, TTIP would only lead to a 0.36 per cent increase in GDP, with a slight fall in the percentage of income to labour versus capital.

Capaldo’s figures are based on the United Nations Global Policy Model (GPM) which takes into account various factors either ignored or theorised in a different way by the CGE model.

The differences in data modelling systems between GPM and CGE are vital in informing data projections, and are the reasons why the two systems find completely different outcomes. GPM is able to integrate the impact of TTIP on non-TTIP countries.

GPM also uses the keynesian principle of aggregate demand in place of CGE’s ‘full employment assumption’ to calculate the impact of cutting wages and jobs on economic activity and consumption patterns.

Crucially, Capaldo’s research doesn’t just see the headline employment figures and growth figures, important though these are.

Capaldo takes account of the distribution of income between labour and capital, a key indicator of inequality, which leading global economists like Joseph Stiglitz, Paul Krugmann and Thomas Piketty believe to be a crucial factor in global economic stagnation and instability.

Guy Taylor, trade justice campaigner with the World Development Movement, told the Morning Star that Capaldo’s report showed that “TTIP falls down even on its own terms”.

He added: “It’s supposed to bolster growth in the EU, but in fact it will result in fewer jobs and lower wages. This is truly a deal for the one per cent, and we have to stop it.”

From “parts” to whole?

The last remaining promise of TTIP that Scottish politicians defend – that it will create jobs and growth – appears on closer scrutiny to be based on think-tank reports which use computer models with built-in assumptions that critics say don’t reflect reality. Even based on these reports, TTIP is likely to have only increased GDP by less than half a per cent in 13 years.

On the estimations of Capaldo, it’s likely to lead to over half a million job losses in the EU, as well as increasing inequality and instability. The Scottish Government has shown a willingness to re-think “parts” of TTIP, but will it listen to campaigners and question the whole premise of the trade deal?

Picture courtesy of Mike Herbst


Exodus and Leviticus: A Parallel Reading (Part IV)

The following is part of series exploring the narrative of P material and its explanation of why Nadab and Abihu are killed in Leviticus 10. Such a study is important because theology often misuses verse like Leviticus 10:1-3 to demonstrate the un-malleability and impossibility of keeping Torah, resulting in antinomianism. In order to demonstrate the true focus of Nadab and Abihu’s death, I will compare two passages of P material, Leviticus 8:1 – 10:3 and Exodus 29 – 30:10. These pericopes, with a close reading, provide a reasonable explanation for the death of Aaron’s son.

The follow compares Exodus 29:31-37 and Leviticus 8:31-36. All translations are from the NASB.

Exodus 29:31-32 31 “And you shall take the ram of ordination and boil its flesh in a holy place.

Leviticus 8:31 31 Then Moses said to Aaron and to his sons, “Boil the flesh at the doorway of the tent of meeting, and eat it there together with the bread which is in the basket of the ordination offering, just as I commanded, saying, ‘Aaron and his sons shall eat it.’

Exodus 29:33 33 “Thus they shall eat those things by which atonement was made at their ordination and consecration; but a layman shall not eat them, because they are holy.

Exodus 29:34 34 “And if any of the flesh of ordination or any of the bread remains until morning, then you shall burn the remainder with fire; it shall not be eaten, because it is holy.

Leviticus 8:32 32 “And the remainder of the flesh and of the bread you shall burn in the fire.

Exodus 29:35 35 “And thus you shall do to Aaron and to his sons, according to all that I have commanded you; you shall ordain them through seven days.

N/A N/A Leviticus 8:34 34 “The LORD has commanded to do as has been done this day, to make atonement on your behalf.

Exodus 29:36 36 “And each day you shall offer a bull as a sin offering for atonement, and you shall purify the altar when you make atonement for it; and you shall anoint it to consecrate it.

Exodus 29:37 37 “For seven days you shall make atonement for the altar and consecrate it; then the altar shall be most holy, and whatever touches the altar shall be holy.

Leviticus 8:35 35 “At the doorway of the tent of meeting, moreover, you shall remain day and night for seven days, and keep the charge of the LORD, that you may not die, for so I have been commanded.”

N/A N/A Leviticus 8:36 36 Thus Aaron and his sons did all the things which the LORD had commanded through Moses.

As this brief chart displays, these two passages are similar, although they do have distinct focuses. Exodus, first of all, is far more focused on issues of holiness. Verses 31, 33, 36, and 37 demonstrate a focus on the holiness, purity, and consecration of the altar. Unlike Leviticus, Exodus explicitly notes that non-Priests, laymen, are not to eat of the sacrifices. Leviticus is seemingly simpler and more focused on ensuring that Aaron and his sons did exactly what the LORD had commanded through Moses. In only 6 verses, there are two references confirming their obedience to commandments of the past, verse 34 and 36.

The parallels between the narrative and commands are intriguing for a variety of reasons. For the sake of this post’s length, I will focus on one, namely the rearrangement of Leviticus by the redactor. The difference between Leviticus and Exodus 29:36, especially with regard to the issue of holiness and consecration, may be due, in part, to the final editors movement of sacrificial terminology and practice to one which fit his own socio-historical context. Regardless of that, Yitzhaq Feder suggests that consecration of the altar in Leviticus 8:15 may have been originally more in line with Exodus 29:36 (See Yitzhaq Feder, 2011, pg. 50-51). With this is mind, these two portions of Leviticus and Exodus are even more similar than they seem to be within the redactors rearrangement.

The next post will take into consideration Yitzhaq Feder’s argument regarding the strata of Exodus 29 and Leviticus 8.

Re-Understanding the Leviticus Sacrificial System

Popular Christian tradition often defines and interprets ancient Israel’s cultic rituals and offerings in Leviticus through the narrow lens with which the New Testament discusses the issue of the sacrificial system. Passages like Matt 5:17-19, Rom 7:6, and Heb 10:1 leave an impression that the Levitical offering system was solely intended to prepare for Jesus and him alone. While this is undeniable in a sense, it is important to note the theological thrusts of these texts. Matthew, Romans, and Hebrews each work to demonstrate how Jesus fits into the grand scope of the Torah, not to provide a comprehensive discussion about the sacrificial system of Leviticus. Thus, in order to properly understand a book such as Leviticus, especially for a Christian, people must begin by recognizing that the New Testament is not definitive for Leviticus. If anything, Leviticus defines the New Testament and the New Testament operates within those parameters. Although it adjusts various understandings and interpretations (cf. Thomas Kazen 2002), it does not ever comprehensively discuss how the entirety of the system was abolished by Jesus.

In light of this brief discussion, what is required of biblical readers? Two basic ideas sum up how readers should approach Leviticus:

1) Recognize the layers of tradition within the offering system. Leviticus was not written over one year and left as the original copy 3,000 years later. Rather, it has been redacted through various editors who lived in their own time with distinct influences than others may not have had (cf. Yitzhaq Feder 2011). What readers read now is the results of centuries of redaction. As a final comment, that is not to imply that Leviticus in unreliable. On the contrary, it is reliable, except one must recognize the variation within it.

2) Leviticus should be read with recognition that the cultic ritual was central to lives in the ancient world. To ignore or place a glaze over Leviticus is to ignore the centrality of ancient Israel’s culture and life.

Although these are only two of many essential hermeneutic approaches to Leviticus, they are a good starting place. By observing these two ideas, it may actually be possible to read Leviticus. This begins with expanding beyond the narrow view of the New Testament’s understandings of sacrifice and atonement and moving towards a more comprehensive understanding of Leviticus that takes into account the textual redaction and centrality of sacrifice to the ancient world.


Why does cryptocurrency matter? It matters because cryptocurrency is a sovereign currency beyond the reach of governments. When governments issue more currency to cover the gap between tax income and spending, it deflates the value of the currency.  When currencies lose their value, it takes more of it to have the same buying power in the global marketplace.

For example, U.S. food prices are up 10.6% this year with an overall inflation rate of 6.38% as the U.S. government collected $4.05 trillion in taxes and spent $6.82 trillion. Holding a currency outside the ravages of inflation would seem like a good idea.

At the heart of cryptocurrency is Bitcoin. Bitcoin rides on a distributed digital ledger page (blockchain) of Bitcoin transactions. Bitcoin has a planned annual inflation rate of 2% that will decline over time as the full 21 million coins are digitally mined in a process using high-speed computers consuming massive amounts of electricity to solve increasingly difficult mathematical problems. Successful miners are rewarded in Bitcoin. There is currently 18.22 million Bitcoin in circulation at a value of $47,339.65 per coin.

In my quest to learn more about crypto, I did what any boomer generation person would do when faced with a technological challenge; I enlisted the help of my millennial friends who spotted the beginning of the crypto-trend in 2017 or earlier.  At their suggestion, I set up an account in Coinbase, put in U.S. dollars, and purchased Bitcoin and a few other cryptocurrencies.  So far, I have learned that digital currencies are highly volatile with wide fluctuations in value throughout the day.

The “tuition” at the school of cryptocurrency investing has been a harsh one for me during my two-month venture with my crypto-portfolio down 21.2% and, at the same time, my stock picks are up 34.8% for the year. Although, both stock and crypto have seen a lot of red (decline in value) during the last month as Omicron appeared to be injecting fear, uncertainty, and doubt regarding the future economic outlook.

If you have any cryptocurrency experience you would like to share, please drop me a note!


Two recent additions to the Ross-Blakley Law Library collection have attorneys looking within, honing skills and reversing destructive thinking. Understanding and Overcoming Cognitive Biases for Lawyers and Law Students and Negotiation Essentials for Lawyers are driven by practicality: they hope to instill lessons that can make lawyers better at their job by identifying and neutralizing fallacies and other mental lapses and by developing a solid strategy at the bargaining table.

Understanding and Overcoming Cognitive Biases for Lawyers and Law Students, E. Scott Fruehwald, 2018

The heart of this book on cognitive biases is active learning—it contains numerous exercises to ensure more retention of its key lessons so they are not lost in the passive learning of mere reading. Chapter 1 lists common cognitive biases to help lawyers and students overcome specific flaws in thinking. It identifies traps such as the overconfidence effect (“Excessive confidence in one’s own answers to questions.”) and the curse of knowledge (“When better-informed people find it extremely difficult to think about problems from the perspective of lesser-informed people.”) as particularly dangerous for attorneys. It introduces the difference between intuition and reasoning, and details the role of emotion in cognitive biases before introducing tools such as reflection to combat biased thinking. After this intro, chapters 2 and 3 delve into optimistic and negativity biases, respectively, with thought exercises. The next sections concern biases with how we interact with other people, which for lawyers includes countless clients, witnesses, judges, and other attorneys, and economic biases. Chapter 6 introduces the practical reasoning skills that can push back against (or be harmed by) cognitive biases. Later chapters concern ethics and other specific legal topics. Along the way, lawyers will understand not only how to push back against their own cognitive biases, but to strategically harness the biases of others for career success. The book provides detailed explanations for each of the thought exercises it presents to help lawyers internalize its lessons and apply them in the real world.

Negotiation Essentials for Lawyers, Andrea Kupfer Schneider & Chris Honeyman eds., 2019

The concept behind this anthology was to distill the most important lessons about negotiation that lawyers will actually use and to help lawyers apply the lessons efficiently. Each chapter includes an explanation of why it is relevant to attorneys and why it might change their thinking. It is also kept to a reasonable length despite trying to absorb the vast body of knowledge on negotiation tactics into a single volume. Each author provides specific steps for attorneys to make in their future negotiations. They also address red flags with sections that explicitly lay out situations in which the chapter’s particular negotiation advice won’t apply. It provides negotiation advice in a number of different contexts, including different practice areas and different cultures. The chapters are arranged into thematic sections, with an introduction, a unit about the negotiator as a person, and how personal differences including race and gender can play out in negotiations. Section III concerns setting and achieving appropriate goals for your negotiation. Section IV primarily concerns listening and communicating well. Section V involves working with negotiation counterparts. Sections VI and VII concern more specific contexts such as mental illness and cultural differences, or dealing with large organizations, arbitrations, or plea bargaining. Sections VIII and IX concern work with your client and with third parties, and Section X wraps up with strategies to close a deal.

The post Mind Games: Train Your Mind for Optimal Lawyering appeared first on Ross-Blakley Law Library Blog.


Lorenzo Quinn, support, creates history at the venice biennale

On 13 May, contemporary artist, Lorenzo Quinn, launched his new monumental sculpture at the Ca’ Sagredo Hotel, Venice. Internationally renowned as one of the most popular sculptors of our times, the installation showcases Quinn’s artistic progression and his experimentation with new mediums and subject matter to transmit his passion for eternal values and authentic emotions.

Reflecting on the two sides of human nature, the creative and the destructive, as well as the capacity for humans to act and make an impact on history and the environment, Quinn addresses the ability for humans to make a change and re-balance the world around them – environmentally, economically, socially. Support sees Quinn reflect on and readdress these global issues by employing the ancient lost-wax process in his Catalan foundry and echoing the meticulous execution and technique of the Masters of the past to create the powerful and unique sculpture which will be displayed during the Venice Biennale 2017…


Categories FAQ

Question: How deep is a standard chest of drawers?

A standard chest is taller (44″ – 60″), narrower (30″ – 40″ wide), and about as deep (16″ – 20″) as a standard dresser. You’ll have less counter space with a chest, but your room will feel more open.

What is the average depth of a dresser drawer?

Depth: Standard depths are 14-inches, 16-inches and 20-inches. Height: The height of the drawer refers to the height of the drawer face. The actual height of the box is usually less. Standard heights are 5-inches, 7.5-inches, 10-inches and 12-inches.

How deep should drawers be?

Drawer depth or height is not critical, but the most common difference between the drawer and the opening is 3/4 inch. For example, if the opening measures 4 inches vertically, the drawer should be built 3 1/4 inches. This allows 1/4 inch at the bottom where the slide is attached, and 1/2 inch at the top for clearance.

What is the size of a standard drawer?

Kitchen drawers, or drawer boxes, correspond with the size of your cabinets and their intended uses: For base cabinets, drawers range 6-36″ in width, 4-10″ in height, and just under 24-36″ deep, depending on the depth of the base cabinet (which could also be the island).

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How wide should dresser drawers be?

Dresser drawers should be no more than 36 inches wide. Specifically, states, a “standard size pine chest of drawers” is typically sized in either “17-inch width, 24-inch width, 30-inch width or 36-inch width” drawers.

How do you measure the depth of a drawer?

Begin by measuring along the bottom floor of the drawer at the back edge, middle, and front edge. Check for variations across the height of the drawer as well. Take the smallest of these measurements. Repeat this step for the depth measurement on the left edge, middle, and right edge across the floor and the height.

How do you measure chest of drawers?

Measure from the floor of the drawer to the top of the sides. Do this for the back of the drawer, the sides and the front of the drawer, as panels may differ in measurements around the drawer. Repeat the steps above for every drawer in a dresser (or other furniture piece).

Is a 36 inch drawer too big?

A deep, wide drawer does have a limit in size. You just can’t do a wide drawer at 36 ” wide or more, because it will sag over time, even with heavy duty glides. Homeowners might tend to weigh down that drawer with big, heavy items and you have to account for that happening somewhat.

How big is too big for a drawer?

The rule of thumb is 1.5 times the length of the drawer slide. If you have a standard depth kitchen cabinet then the normal length of drawer slide is 22”. If you multiply 22” x 1.5 = 33”. You can go wider, but the wider you go the more chance that the slide will not pull out as smoothly as you hope or expect.

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How thick are drawer slides?

Light duty slides might be as thin as 1/2″, while heavy duty slides may be over 3/4″ thick. Face frame cabinet slides are easier to install using the specific, optional, face frame brackets. Length sizing is usually simplified by checking manufacturer’s charts, where the drawer size and cabinet depth are both stated.

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Energy revolution to have ‘greater impact’ than industrial

The Energy Solutions exhibition kicked off this morning with the Renewable Energy Association's vice chair of the onsite renewables sector, David Hunt, claiming that the coming energy revolution will be the most important to date.

Hunt acknowledged that the most significant revolution had been the industrial followed by the Internet revolution, both shaping the way the world works today.

However, he argued that the coming energy revolution would be “of greater global, political and economic impact than any revolution before.”

Pointing to regulator Ofgem’s recent report, which suggested that spare energy generating capacity in the UK could fall to 4% by 2015/2016, Hunt warned that the UK could be facing black outs or energy rationing if British energy supplies fail.

He also explained that currently, in the UK, energy prices are at least double the rate of inflation, and that the government was not sending clear signals.

“We are facing a government that isn’t listening. Just this week we heard the Chancellor George Osborne’s speech which had no mention of climate change and no mention of a green economy,” he said.

He accused the government of “spooking investors” and causing uncertainties in the renewable sector, adding that the “battle between the Department of Energy and Climate Change (DECC) and the Treasury had made everyone uneasy.”

Hunt also announced that the overwhelming consensus of experts was that the Green Deal, as it stands, was a “car crash policy”.

The vice chair went on to say that once again the Green Deal had the potential to cause more uncertainty for renewables investors.

Hunt argued that there was “no silver bullet” to address the problem of energy supply.

“Nuclear isn’t the answer and wind isn’t the answer: they are both part of an answer along with other technologies such as solar PV, heat pumps, biomass, anaerobic digestion, fuel cells and other developing technologies.”

He pointed to the CBI’s analysis that a third of the UK’s economic growth in 2011/2012 is likely to have come from green businesses.

“We need to see a Treasury seeing the growth opportunity that the CBI see,” urged Hunt.

However, there was good news he said. The renewable sector had made big steps so far.

In September of this year the UK onshore wind capacity reached 5GW with wind farms producing 10.8% of overall UK energy demand.

According to DECC, renewable energy output capacity soared by up to 42% over the past year to 14.2GW.

Hunt claimed that although feed in tariffs had been tampered with and the renewable heat incentive had experienced teething problems, they were still attractive options.

Live from the Energy Solutions exhibition at Olympia.

Conor McGlone


ElkhartRecruiter Since 2001
the smart solution for Elkhart jobs

RV Sales Associate

Company: Tiara RV Sales
Location: Elkhart
Posted on: November 25, 2022

Job Description:

Our success is rooted in our exceptional team, which has been growing since 2002. Our sustained growth has been fueled by our family values and passion for the RV lifestyle.As a member of the Sales team, you'll be a key player in creating opportunities for families to make lifelong memories. You'll match customers with their perfect RV and start them on their journey to the RV lifestyle. Be a part of a team that will push you to succeed, earn, and help you achieve your highest potential._*What's in it for you?*_ When you join our team, you become part of the Tiara RV family. It's more than a job - it's the opportunity to build a career, make a difference, and be part of an exciting industry. If you're looking for a place to call home, we want to hear from you!Manage the sales process from start to finish. Help clients with product selection, negotiate terms, and ultimately finalize sales.
Provide detailed and accurate product knowledge to customers.
Establish and maintain strong relationships with customers while providing outstanding customer service.
Continually learn about product updates, inventory and how it will benefit the customer.
Responsible for daily follow up with current, existing, and potential leads.
Identify and provide solution-based sales options for customers.
You will work directly with the Financial Office in coordinating the sale and financial lending process.
Hustle - The sales team moves fast and so does the competition. The right candidate establishes relationships quickly while earning trust by providing expert knowledge and unparalleled customer service.
Competitive - We look for candidates that are interested in breaking records and raising the bar to what is possible. We play to win.
Attitude - The sales team believes in hard work and having fun while doing it! A positive and work-hard attitude will serve you well.
Passion - We are in the business of providing a lifestyle to those that are passionate about RVing. You need to share the passion for the products that we represent and be willing to go the extra mile for our customers.
Candidates should have retail experience specifically in Automotive, Powersports, or the RV industry. The amount of experience is less important than having the qualities of a successful sales associate (communication, competitiveness, positive attitude...etc). We're constantly on the lookout for the "diamond in the rough" and willing to train and develop an individual who has the right attitude.Many sales associates earn well over $100,000 a year once becoming fully acquainted with our products and processes. The average first year earning potential for sales associates with minimal to no sales experience is between $50,000 - $75,000. Tiara RV offers a comprehensive benefits package that includes medical, dental and vision insurance

Employment Type

Job Type: Full-time

Pay: $35,000.00 - $75,000.00 per year

* Dental insurance
* Health insurance
* Vision insurance
* 8 hour shift
* Day shift
* Monday to Friday
* Weekend availability
Supplemental pay types:
* Commission pay

Ability to commute/relocate:
* Elkhart, IN 46514: Reliably commute or planning to relocate before starting work (Required)

* Retail Sales: 1 year (Preferred)

Work Location: One location%58047475%

Keywords: Tiara RV Sales, Elkhart , RV Sales Associate, Other , Elkhart, Indiana

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Founded in 2016, Sixteen is an independent media platform celebrating the power of contemporary photography.Published bi-annually, and on its digital platform, Sixteen gives a space for emerging and established artists to share their creative vision outside of their commercial habitat. Through compelling visual stories in fashion, documentary, cinema and social/environmental justice, Sixteen is a rare place for creativity.


A governance structure for an ambitious EU industrial strategy

In the aftermath of the two previous Industry4Europe Joint Papers “For an ambitious EU Industrial Strategy: Going further” (October 2017) and “Setting indicators for an ambitious EU Industrial Strategy” (March 2018), this new Joint Paper aims at proposing a governance structure which enables the implementation of an ambitious EU Industrial Strategy, based on an informed dialogue between the industry, decision-makers at EU, national, regional and local levels and the Civil Society. More specifically, a future Industrial Strategy governance structure should be based on the following two pillars:

- A structure of European Institutions which allows for an Industrial Strategy to be addressed and implemented at the highest level.

With its Joint Paper “For an ambitious EU Industrial Strategy: Going further” (October 2017), the Industry4Europe coalition has been calling for a long-term vision for Europe’s industry which demands a long-term governance structure going beyond the 6-month EU Presidency cycle and the 5-year mandate of the current European Commission. Such a governance structure should enable the Commission, the Council and the European Parliament, together with industry stakeholders, to develop a common vision for smart, innovative and sustainable industry. Existing policies, initiatives and tools, addressing the challenges and gaps, including those described in the Commission’s Communication “Investing in a smart, innovative and sustainable Industry: A renewed EU Industrial Policy Strategy” of September 2017, should be reviewed in order to develop and implement a long-term comprehensive EU Industrial Strategy as well as for monitoring its progress on a regular basis.


You play as something new and incredible in this world; a Teenager. Never before has the world been in a place that allowed for a long adolescence, and as the first of these strange creatures, you make a lot of people uncomfortable with your wild clothes, your loud music and your strange habits. Players choose from one of 6 teenage archetypes – Jock, Nerd, Artist, New Kid, Outsider, Royal – each with their own strengths and place within the high school ecosystem. You’ll also pick from one of 9 fantasy species, each with their own unique backstory and history within the world.

Americana features innovative new mechanics; Your Dead Friend pushes the victim of the murder to the center of the story, and Flashbacks let you build your relationship with the victim dynamically through play. Town Creation lets you and your table collaboratively create an incredible town full of magic and mystery and an extensive resources section helps you and your players build the perfect mystery.


Titleist 2022 AVX Same Number Personalized Golf Balls, Men’s, Orange

SKU: 4963901699879008Category:

BENEFITS Designed for longer distance, increased greenside spin and control, softer feel, and very low long game and iron spin TECHNOLOGY Large core formulation High flex casing layer New, soft, thin cast urethane elastomer cover system New, unique spherically-tiled 348 catenary dimple design

Additional information


Oesophagus Illness

June 24, 2022

The oesophagus, otherwise known as the gullet or swallowing tube, is the “pipe” that links the mouth to the stomach, and allows food to pass down after chewing and swallowing into the rest of the digestive tract where digestion and absorption of nutrients occurs.

It’s an important structure, and a number of diseases can affect its function and overall gut health. Some of them are listed below:

GERD (Gastro Oesophageal Reflux Disease)

Backflow of stomach contents into the oesophagus can cause symptoms such as heartburn a bitterness in the throat and a variety of other symptoms. The diagnosis is made by endoscopy or a special reflux study. Treatment involves lifestyle changes in tandem with medicine and sometimes surgery.

Barrett’s Oesophagus

Barrett’s is a change in the lining of the oesophagus as a result of constant and chronic reflux. This condition needs to be managed and monitored, as there is a small potential for malignancy.

Oesophageal Dysmotility

The movement of food down the oesophagus does not happen by gravity but is a result of coordinated contractions involving the nerves and muscles. A disruption of this can result in swallowing difficulties and significantly impair one’s quality of life. Diagnosis involves the use of High-Resolution Oesophageal Manometry and a pH-Impedance test, and once the correct diagnosis has been made, effective treatment can be given.

This is one of the most significant disorders of swallowing, where the oesophagus movement stops and the valve allowing food to enter the stomach is jammed. The diagnosis and subtyping is confirmed by High-Resolution Oesophageal Manometry, and effective treatment can be given.

Pill Oesophagitis

This is a common condition when tablets or pills are not swallowed properly and get stuck in the narrowest part of the oesophagus, and the medication in the pills get into contacts with the oesophagus and results in painful ulcers forming.

Eosinophilic Oesophagitis

This condition presents in a variety of ways, and can sometimes mimic a heart attack. It’s a result of an allergic reaction of the oesophagus causing allergic type cells to accumulate and cause damage to the lining of the oesophagus. Accurate diagnosis by endoscopy and biopsy to see the cells is crucial before treatment can be instituted.

Oesophageal Cancer

Cancer of the oesophagus most commonly occurs in an elderly male with a strong history of smoking and drinking alcohol. They usually have symptoms such as difficulty in swallowing and loss of weight.


Bioinformatics – The Emerging Field in Science Yields New Discoveries

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Article Body

With all of the advancements and discoveries that have been made by studying genetic information and DNA, there became the need to have a store house to keep all of this information safe and secure as well as be able to access, sort and utilize the information quickly and when needed.

For this reason, there came about the idea of having a database that is capable of holding bioinformatics findings and allows users to draw on it to answer specific biology questions. The findings that have taken place by studying DNA and protein sequences needed a place to be recorded and that would keep the precious information and data safe.

There are three key concepts in bioinformatics:

  1. Data Representation – DNA is not clearly arranged in human genes, it is coated with certain proteins that tend to bind to different sequences and this makes a sort of blueprint that biologists have to read. DNA is represented as a helix and is three dimensional. Yet as complex as DNA sequences are, there are only 4 characters used to differentiate the molecules – A, C, G and T.
  2. Similarity – evolution conserves the genes that are responsible for coding proteins and other important sequences that serve useful functions when being transferred from one organism to another. It has been found that certain organisms have similar sequences due to evolution.
  3. Bioinformatics is not a theory based science – bioinformatics, apart from other branches of science, is not based on theories, but is based on data that is gathered from researching and studies. It is truly based on information that is gathered instead of proposed theories used in many forms of science.

The kind of information that is stored for bioinformatics includes genetic comparisons between species. The more that scientists and researchers study and compare the genetic sequences, the more similarities that they are finding. By being able to store all this information into a system is critical to the future success of the field. It is through the advancements in technology that bioinformatics has come so far in only a few years, and the future looks good for continuing to learn more about how DNA sequences work.

Another kind of comparison that will be done is comparing the genome of humans to other humans. By doing this kind of study and comparison, scientists are able to learn what makes one person different from another person. These kinds of advancements in bioinformatics call for an even greater need for the ability of a system that will hold and gather information. The sequences of people can be stored in the system, and scientists are able to draw upon that information to make their comparisons.

With the introduction of DNA sequencing that became automated in the 90’s, the amount of data that was available was greatly increased. The more research and studies that are being completed, the more data is being created. This opens up the door to career paths for aspiring bioinformatics professionals. There looks to be no shortage in jobs in the years to come for scientists, computer engineers and programmers, information technology and mathematic based careers. The field of bioinformatics is a highly skilled job field due to the amount of different kinds of knowledge that a person needs to have in order to succeed.


Trump says he wants an 'exciting' July 4 parade at the Lincoln Memorial

John Fritze
45. Donald J. Trump (1946-present)     • Years served as president:  2017-present     • Political party:  Republican     • Weird fact:  Trump doesn't drink alcohol.     The current president is one of the few commanders in chief to not drink alcohol. He chooses not to indulge in the beverage likely because his brother was an alcoholic and died of his addiction in 1982.

WASHINGTON – President Donald Trump is back in the market for a parade.

Speaking to members of his Cabinet on Tuesday, the president said he has been thinking about a July 4 parade, potentially at the Lincoln Memorial that could “become a tradition.”

“It could be an exciting day,” Trump said.

The president made news last year for proposing a military parade in Washington, which the Department of Defense said would cost as much as $80 million. Trump has expressed a desire for such a parade for years and was impressed by the Bastille Day march he witnessed on a presidential trip to Paris in 2017.

Contributing: William Cummings, Tom Vanden Brook


London Riots – Gordon Thompson – What Does His Sentence Actually Mean?

Gordon Thompson, the man who set alight the House of Reeves furniture store in last summer’s riots was sentenced to a prison sentence of 11 years and 6 months years at the Old Bailey on Wednesday 11th April 2011. When sentencing the Judge commented “the loss [for the Reeves family] was priceless and the trauma they have suffered inestimable”.  The Judge went on to say that it was, “extremely good fortune… that nobody died or was seriously injured”

The sentence is the longest that has been imposed in the rioting cases. Whether it was too long or even too short is perhaps a matter for public debate, but what does the sentence actually mean?

Under the provisions of the Criminal Justice Act 2003 any adult who is sentenced to a fixed term of imprisonment for an offence committed after 1st April 2005 is automatically released on licence at the half-way point of the sentence, which in Mr. Thompson’s case will be after he has served 5 years 9 months. They will then remain on licence for the remainder of the period.

If a person has spent time in prison on remand or has been subject to bail with a condition to comply with a curfew monitored by an electronic tag, before he or she is sentenced it is invariably the case that the sentencing Judge will allow for this time to be deducted from custodial sentence. The Judge will deduct one day from the time to be served for each day spent remanded in custody prior to sentence and half a day for each day spent on a tag-monitored curfew, provided that the curfew condition was for 9 hours or more.

For example a person who receives a sentence of, for example, 10 years and has been remanded in custody for 1 year before being sentenced will be automatically released after serving a total of 4 years in prison; that being half of the 10 year sentence less the 1 year spent on remand.  If the same person had spent 1 year on a qualifying curfew he or she would be released automatically having been in prison for 4 years 6 months; that being half of the sentence less 6 months being half of the time spent on curfew.

When a person is released they will be subject to licence for the second half of the sentence (as long as the sentence imposed was for 12 months or more).  In simple terms being on licence means that the person who is released must be of good behavior and must comply with any licence condition imposed by the Probation Service. Such conditions may include details of where they should live, the type of work he or she may do and with whom he or she may associate.

If a person breaches any of their licence conditions or are suspected to commit another offence during the period of the licence, then they can be liable to be recalled to prison. How long they remain in prison depends on the type of recall.  In practice it is usual for a first breach of licence to be dealt with by way of a fixed term recall to prison for 28 days, but if the breach is deemed to be serious or is a second breach the person is liable to remain in custody until the end of the sentence or until the Parole Board or Secretary of State direct that they can be re-released on licence once again.

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Energy intake and expenditure in obese older adults with and without type 2 diabetes

Rationale: Obesity is a risk factor for type 2 diabetes (DM2), however not all obese people develop DM2. We explored differences in energy intake and expenditure between obese older adults with and without DM2. Methods: Baseline data from 2 lifestyle interventions with a total of 202 obese older adults were included in the analyses. Obesity was defined as BMI > 30.0, or >27.0 with waist circumference >88 (women) or >102 cm (men). DM2 was confirmed by use of diabetes medication. Subjects were between 55 and 85 years old and 45% was female. Energy intake (EI) was measured by 3-day food diary and physical activity level (PAL) by 3-day movement diary. Resting energy expenditure (REE) was measured using indirect calorimetry and total energy expenditure (TEE) was calculated as REE x PAL. Between group differences were analysed with independent samples T-tests. Results: The obese group with DM2 (n = 117) had more males (67.5% vs 37.6% p < 0.001) and similar BMI (33.3 vs 33.0 kg/m2) compared to the group without DM2 (n = 85). Analyses of males and females separately showed lower PAL in males with DM2 (vs without DM2; 1.37 vs 1.45, p = 0.015), without differences in EI (2055 vs 1953 kcal/d), REE (1970 vs 1929 kcal/d), and TEE (2699 vs 2830 kcal/d). In females with DM2, both PAL (1.38 vs 1.47, p = 0.014) and EI (1543 vs 1839 kcal/d, p = 0.008) were significantly lower, whereas REE (1592 vs 1598 kcal/d) and TEE (2220 vs 2318 kcal/d) did not differ significantly from obese females without DM2. Conclusion: In both males and females, obese older adults with type 2 diabetes showed similar resting and total energy expenditure but lower physical activity level compared to those without DM2. Females with DM2 showed lower energy intake. On average, subjects seem to have a negative energy balance, which is probably due to a combination of underreporting of intake and over-reporting of activity.

Reference Memelink, R. G., Verreijen, A. M., de Vogel-van den Bosch, J., & Weijs, P. J. (2017). Energy intake and expenditure in obese older adults with and without type 2 diabetes. In N. E. P. Deutz, J. A. Mays, & S. C. Roeske (Eds.), Abstracts of the 39th ESPEN Congress: 9-12 September 2017 • The Hague, Netherlands (pp. S232). (Clinical Nutrition; Vol. 36, No. supplement 1). Elsevier.
Published by  Faculteit Bewegen, Sport en Voeding 1 January 2017

Publication date

Jan 2017

J. de Vogel-van den Bosch

Research database


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The road ahead to be Fit for 55
EU | Brussels

The road ahead to be Fit for 55

30 May 2022 · Environment

The timely deployment of alternative fuels infrastructure across the EU, and smart taxation and charges, which encourage operators to decarbonise, are paramount for successfully decarbonising road transport.

Raluca Marian is the Director EU Advocacy and General Delegate of IRU’s Permanent Delegation to the European Union.

Collective passenger transport is a decarbonisation tool in its own right. Yes, it groups people and moves them away from private cars. But it would bring even further benefits if cleaner vehicles and fuels were readily available across the EU.

Greening road freight fleets is also crucial given that road transport by road represents over 75% of the EU’s overland goods transport. What is more, there are realistically no chances of a massive shift to other transportation modes, even in the distant future.

Almost one year after the launch of the ambitious Fit for 55 Package, discussions between the European Parliament and the Council are at an advanced stage on the legislative proposals to boost decarbonisation in the EU.

Three of those are fundamental for the decarbonisation of road transport: the proposal for a regulation on alternative fuels infrastructure (AFIR), the inclusion of road transport in the scope of the emissions trading scheme (ETS II) and the revision of the energy taxation directive (ETD). Are these proposals heading in the right direction?

The green transition of the coming decade will require an enormous effort: about 1 million transport companies in the EU use over 35 million vehicles, of which approximately 7 million are heavy-duty vehicles.

As zero-emission vehicles are starting to hit the market, it is imperative to roll out an alternative fuels infrastructure across the EU. This means making alternative fuels widely available and providing a strong grid to deliver enough power to charge an increasing number of electric vehicles.

The European Commission’s AFIR was a good starting point in terms of the ambition required to decarbonise goods and passenger road transport. Yet, while the European Parliament seems determined to go even further, we see a risk in the Council’s timid approach, in particular for heavy-duty vehicles. A less ambitious outcome would be a significant setback in achieving the objectives of the European Green Deal.

We know that the taxation and charging structures proposed by ETS II and ETD can act as a strong incentive for rapid decarbonisation. The only condition is that they go hand in hand with an alternative fuels infrastructure and wider availability of zero-emission vehicles. It would work even better if the revenues collected (particularly through ETS II) were used to invest in the decarbonisation of road transport. Unfortunately, the European Parliament’s committee reporting on this file (ENVI) has recently reached a weak compromise, which will fail to deliver a fit-for-purpose ETS II.

ENVI proposes the almost immediate introduction of commercial vehicles in the scope of ETS II, leaving aside private road users. Not only does this ignore the 300 million private vehicles producing more than 70% of road transport CO2 emissions, but it is also an impractical, largely unenforceable system.

Not to mention the strong counterproductive signal to EU citizens and businesses against the vital role of public transport, collective mobility and efficient goods transportation in greening our roads.

In conclusion, the European Union’s decarbonisation plans for road transport will only be successful with good timing and appropriate incentives. Vehicles, fuel infrastructure and fuel availability need to be taken into consideration together. Road transport operators need a motivating stimulus to initiate the transition, including through smart taxation and gradually introduced charges.

Today, with the legislative process in full gear, we are still hopeful. We call on the Council to embrace ambitious targets for alternative fuels infrastructure, and the European Parliament to vote against a weak compromise on ETS II, which currently fails to deliver on its promise.


In the era of fake news and proliferating social media content, how can TV news help to bolster trus

Fake news, conspiracy theories and fabrication are aspects of our society that have been prevalent for centuries. Editor of the Financial Times, Lionel Barber, traced fake news all the way back to ancient Rome, in a 2017 Oxford alumni festival speech:

‘My own fake news item of choice comes from ancient Rome: the dodgy dossier obtained by Octavian used to discredit his imperial rival Mark Antony. Octavian claimed that a document in his possession was Mark Antony’s last will and testament. It was later dispatched via messengers throughout the empire. Not quite as effective as social media, but still a successful political stitch-up, circa 33BC’. (Barber, 2017)

In fact, from a biblical perspective, one could go as far as to say that fake news began with Satan, disguised as a serpent, telling Eve to eat the apple. However, a more recent awareness of fake news can be seen through a proliferation of the ways in which we absorb our news, and information. As a recent CNN article elucidated: ‘social media has added an entirely new dimension to the [fake news] phenomenon.

Now anyone in the world can easily create and disseminate false information, and with the help of bots, organized groups, or targeted ads, it is easy to amplify it’ (CNN, 2017). TV News is perhaps going through its most challenging time with the proliferation of fake news. A 2017 Media Survey Report from BBS Communications Group elucidated that, when asked about fake news, ‘the largest term that came to journalists was Donald Trump (20.6% of 141 responses)’ (BBS, 2017). It could be suggested that the 45th President of the United States ‘has arguably been the biggest beneficiary of the advent of fake news […] He has also benefitted from the distrust of the mainstream media by many conservatives, by calling inconvenient news ‘fake news’’ (BBS, 2017). Therefore, could it not be argued that the more time spent giving weight and attention to fake news, the more it will snowball – almost becoming a “buzz” term. Thus, through its mention, we cement it deeper into an accepted, everyday narrative. Author Mark Dice elucidates: ‘One outlet published an article cautioning against growing fake news panic titled, “Stop Calling Everything ‘Fake News’” […] two months ago, almost no-one was talking about fake news. Now you can hardly turn on the real news without hearing it’ (Dice, 2017: np). TV news’ lack of reference to fake news could be a positive enhancement to building trust in viewer’s.

One way of looking at the proliferation of fake news across digital platforms, is that it can aid the trustworthiness of television news because, as people see an influx of fake news online, they turn to the medium they know best for validity and clarification – that being TV news. A 2007 Ofcom report elucidated that: ‘Consumers want and expect to see high quality, well-funded PSB-style television news […] three quarters of the population think news coverage on the PSB channels is important, and 80 per cent agree it is important that terrestrial channels are obliged to provide regular news’ (Ofcom, 2007).

Compare this to the Ofcom report of 2017 and it states: ‘Despite the threat from online services, revenue for the broadcast TV industry increased by 1.0% [and additionally], the main public service broadcast channels (BBC One, BBC Two, ITV/STV/UTV, Channel 4 and Channel 5) continued to retain more than half of the total broadcast TV audience in 2016, maintaining their 51% share over the past four years’ (Ofcom, 2017). Thus, it appears despite the changing of times, people are still reliant on TV news to a certain extent. Trust in the media could be a result of its transparency; there are physical, on-the-spot, reporters and this in itself appears more dependable than videos on social media platform: ‘With TV and radio, in particular, the face or voice of the journalist is an important part of why people rely on it’ (American Press Institute, 2016). Fake news does not have a face like TV news does, and this in itself makes TV news trustworthy.

However, the challenge is to retain the attention of the younger generations. A report in 2016 highlighted that ‘social media has overtaken television as young people's main source of news’ with ‘28% of the 18-to-24-year-olds surveyed, citing social media as their main news source, compared with 24% for TV’ (Wakefield, 2016). Mobile phones are surpassing every other medium for news consumption and so a way for TV news to help bolster trust and confidence in its viewers would surely be to alter their business models. In an attempt to correspond with the wake of digital newness, ‘It’s up to traditional broadcasters to continuously adapt and respond in order to stay relevant to their viewers in the future’ (Translate Media, 2017). With the knowledge that ‘about 67 percent of American adults somewhat rely on social media platforms such as Facebook, Twitter and Snapchat for news’ (Moon, 2017), it is wholly evident that our increased use of social media is leading to an altered way of news absorption. The ease of scrolling down a news feed, videos that play automatically and an ever-growing societal interest in social media is provoking a change in our news consumption.

So, how can broadcasting services bolster this trust? They need to be transparent about how they conduct their research, and demonstrate fact checking. For example, 2017 saw the BBC ‘assemble a team to fact check and debunk deliberately misleading and false stories masquerading as real news’ (BBC, 2017). The BBC additionally have a ‘Reality Check’ section on their website which delivers information that public have requested the team to investigate. Their team checks and examines facts and claims behind a story in order to let the public know whether or not it is true. Equally, Channel 4 have a ‘Fact Check’ section and release regular videos online such as ‘How to Fact Check Fake News Sites’. They give advice such as checking images saying that hoaxers often use real images but lie about where they were taken. Channel 4 thus advise people to use Google Images to find out more about an image. This shows how Channel 4 are working in a positive way with the proliferation of social media to spread the message of fake news. Services such as this are undeniably ways in which TV news can help bolster trust in its viewers and maintain its audiences in this ever-altering era.

A recent shooting at the YouTube headquarters saw malicious posts on social media suggest that US comedian Sam Hyde was the alleged gunman, later dismissed as fake news. Undeniably, the lines between fake news and satire can sometimes become blurred, with websites such as The Daily Mash producing flagrant stories inclusive of “Women paid 1990s wages 'to make them feel younger’”. However, with other fake news websites the fallaciousness can be more arduous to decipher, with URLs fabricating themselves as ones similar to trusted sites; ABCnews.com.co, for example. Instances and websites such as the aforementioned are why TV broadcasters should provide full transparency and fact checking. TV news remains a powerful form of media because it dispels the untruths and presents the viewer with hard facts about the events, but it needs to prove to its viewers that this is the case.

TV news can undeniably bolster trust and confidence in its viewers, but there is no doubt that it is challenging in the present climate to do so. With the Trump administration being described by many as ‘the antithesis of science, facts and research’ (Rymel, 2017), people are having to attempt to regain their trust in the media and TV news. Our distrust in TV news and the media dates back through history, teaching us the lesson that ‘it is our responsibility to find out what is really true, regardless of who says it’ (Rymel, 2017).

TV news’ struggle is to persuade people whom, as human beings do, already have cemented opinions of their own, and are thus searching for confirmation through the media, as well as fighting against social media and fake news. After Brexit and the election of Trump, ‘the free circulation of malicious lies, the ineffectiveness of fact-checking, the resilience of populist propaganda, racism and sexism and the emergence of the so-called post-truth era appear to challenge a fundamental cornerstone of ethical journalism’ (Ethical Journalism Network, 2017). Journalists have the problem of news coming across as “unfashionable”, and the question of how TV news can regain their viewers trust is not a question that is going to be answered overnight. In essence, ‘this existential crisis requires, above all, for journalists to recommit to their craft with reporting that reaches out to their audience and listens to what is being said and reports it in context’ (Ethical Journalism Network, 2017).

TV news is moving in the right direction to combat this aforementioned existential crisis with the introduction of fact checking sites, however the challenge is for journalists not to become disheartened with the proliferation of fake news and social media.


The U.S. Bankruptcy Code (the "Code") § 11 U.S.C. § 362(a)(1) provides that when a party files for bankruptcy, an automatic stay is triggered. However, it turns out that there are limitations to the type of cases that these automatic stays extends, and in the employment context, this may not necessarily include wage and hour claims.

For example, in the recent case of Stewart v. Holland Acquisitions, Inc. Case No. 2:15-cv-01094 (W.D. Pa. Feb. 2, 2021), the U.S. District Court for the Western District of Pennsylvania held that the U.S. Bankruptcy Code's automatic stay does not extend to enforcement actions brought by the U.S. Department of Labor (DOL) under the Fair Labor Standards Act (FLSA). In applying section 362(b)(4) of the Bankruptcy Code to renounce the application of the stay, the court rejected a contrary holding out of the Sixth Circuit (which hears appeals from district courts in Kentucky, Michigan, Ohio, and Tennessee) that an employer cannot shield itself from FLSA enforcement actions brought by the DOL by seeking to trigger the automatic stay protection under the Bankruptcy Code. The court is now persuasive authority in the Third Circuit (which hears appeals from district courts in areas of Pennsylvania, New Jersey, Delaware, and the Virgin Islands).

So, how did this happen? First, Section 362(b)(4) of the Code carves out a number of exceptions to the reach of the automatic stay, including one for certain police and regulatory actions as follows:

The filing of a petition...does not operate as a stay...of the commencement or continuation of an action or proceeding by a governmental enforce such governmental unit's...police and regulatory power, including the enforcement of a judgment other than a money judgment, obtained in an action or proceeding by the governmental unit's...police or regulatory power[.]

In Stewart, the DOL filed a civil complaint against Holland Acquisitions, Inc. (Holland), claiming that Holland willfully and repeatedly failed to pay its employees overtime and maintain proper wage and hour records in violation of the FLSA. Holland later filed for chapter 11 bankruptcy protection and sought to have the FLSA action stayed under the automatic stay provision of the Code.

The court first found the DOL fell within the definition of a "governmental unit" as defined by section 101(27) of the Code. The court then found that the DOL was not seeking to enforce a pre-existing monetary judgment. Rather, the DOL was seeking to stop further FLSA violations and obtain back wages and liquidated damages on behalf of the impacted employees.

Holland relied on Chao v. Hospital Staffing Services, Inc., 270 F.3d 374 (6th Cir. 2001) in arguing that the FLSA action was not rooted in public policy because the DOL was seeking back pay, which is a private right, not a public one. The court rejected Holland's attempt to stay the FLSA action and found that the Sixth Circuit's reasoning in Chao conflicted with Third Circuit principles and, if applied to Holland, would "substantially impair the core remedial purposes of the FLSA."

In other words, even though the FLSA litigation could result in an award of back pay to specific individuals, the DOL's enforcement power is there to bring violating employers into compliance with the FLSA. Accordingly, the court held that the DOL could proceed with its action against Holland, notwithstanding the automatic stay, which was applicable to stay other claims. However, while the court noted that the automatic stay would not prevent the court from entering judgment against Holland, to the extent the DOL obtained any judgment against Holland, enforcement would have to be adjudicated by the bankruptcy court, meaning the collection of any such monetary award would be subject to creditor priority rights as otherwise structured under the Code.

Employer Take Away

Holland's application is limited. First, it only applies to employers within the Third Circuit. Second, it is limited to only wage and hour enforcement actions brought by the DOL. It is not applicable to private causes of actions pursued by employees directly. The Holland decision does, however, create a circuit split on this issue, which could drive the issue to the U.S. Supreme Court as more and more circuits have the opportunity to weigh in on this issue. So, while not binding outside the Third Circuit, the Holland decision will provide persuasive authority within the Third Circuit that the police and regulatory exception under section 362(b)(4) extends to FLSA enforcement actions, meaning the Code's automatic stay protections will not protect a violating employer from the DOL's wage and hour division's grasp.