Product Liability and Food in Washington State: What Constitutes Manufacturing?

To address the courts\u27 inconsistent interpretations of the WPLA\u27s manufacturer definition, this Comment proposes applying a test that assesses manufacturer liability not only by the apparent physical changes an entity makes to a product, but also by the increased monetary value the entity adds to the product. This approach comports with the intent of the WPLA and Washington common law standards, and leads to highly predictable trial results. Part II of this Comment provides a brief history of Washington\u27s product liability law, from early twentieth century theories of implied warranty to the mid-twentieth century adoption of the pro-consumer strict liability standards of section 402A of the Restatement (Second) of Torts. Part III examines manufacturer liability in Washington after the 1981 adoption of the WPLA. Part IV analyzes the various approaches Washington courts currently use to determine manufacturer liability, specifically focusing on the contradictory outcomes of Almquist v. Finley School Dist. No. 53 and Hadley v. Spokane Produce, Inc. Part V examines an alternative approach for determining manufacturer liability found in Washburn v. Beatt Equipment Co., which uses the “relevant product” framework already present in the WPLA. Part VI proposes a workable test that resolves the inconsistencies in the approach used by the Almquist and Hadley courts by using the Washburn approach as a reference point. This proposed test, named the “value-added” test, will provide Washington courts with a consistent standard to apply when defining manufacturer liability under the WPLA. Part VII concludes by addressing potential concerns about the value-added test and its conformity with the WPLA

Product Liability and Food in Washington State: What Constitutes Manufacturing?

To address the courts\u27 inconsistent interpretations of the WPLA\u27s manufacturer definition, this Comment proposes applying a test that assesses manufacturer liability not only by the apparent physical changes an entity makes to a product, but also by the increased monetary value the entity adds to the product. This approach comports with the intent of the WPLA and Washington common law standards, and leads to highly predictable trial results. Part II of this Comment provides a brief history of Washington\u27s product liability law, from early twentieth century theories of implied warranty to the mid-twentieth century adoption of the pro-consumer strict liability standards of section 402A of the Restatement (Second) of Torts. Part III examines manufacturer liability in Washington after the 1981 adoption of the WPLA. Part IV analyzes the various approaches Washington courts currently use to determine manufacturer liability, specifically focusing on the contradictory outcomes of Almquist v. Finley School Dist. No. 53 and Hadley v. Spokane Produce, Inc. Part V examines an alternative approach for determining manufacturer liability found in Washburn v. Beatt Equipment Co., which uses the “relevant product” framework already present in the WPLA. Part VI proposes a workable test that resolves the inconsistencies in the approach used by the Almquist and Hadley courts by using the Washburn approach as a reference point. This proposed test, named the “value-added” test, will provide Washington courts with a consistent standard to apply when defining manufacturer liability under the WPLA. Part VII concludes by addressing potential concerns about the value-added test and its conformity with the WPLA

The development of a generic systems-level model for combustion-based domestic cogeneration

The provision of heat and power to dwellings from micro-cogeneration systems is gaining credence around the developed world as a possible means to reduce the significant carbon emissions associated with the domestic sector. However, achieving the optimum performance for these systems requires that building design practitioners are equipped with robust, integrated models, which will provide a realistic picture of the cogeneration performance in-situ. A long established and appropriate means to evaluate the energy performance of buildings and their energy systems is through the use of dynamic building simulation tools. However, until now, only a very limited number of micro-cogeneration device models have been available to the modelling community and generally these have not been appropriate for use within building simulation codes. This paper describes work undertaken within the International Energy Agency's Energy Conservation in Building and Community Systems Annex 42 to address this problem through the development of a generic, combustion based cogeneration device model that is suitable for integration within building simulation tools and can be used to simulate the variety of Internal Combustion Engine (ICE) and Stirling Engine (SE) cogeneration devices that are and will be available for integration into dwellings. The model is described in detail along with details of how it has been integrated into the ESP-r, Energy Plus and TRNSYS simulation platforms

Pastures: Towards usable security policy engineering

Whether a particular computing installation meets its security goals depends on whether the administrators can create a policy that expresses these goals—security in practice requires effective policy engineering. We have found that the reigning SELinux model fares poorly in this regard, partly because typical isolation goals are not directly stated but instead are properties derivable from the type definitions by complicated analysis tools. Instead, we are experimenting with a security-policy approach based on copy-on-write “pastures”, in which the sharing of resources between pastures is the fundamental security policy primitive. We argue that it has a number of properties that are better from the usability point of view. We implemented this approach as a patch for the 2.6 Linux kernel.

Automated Control System for the Remote-Controlled Torch Positioner

The goal of this project is to design and implement a controls system for Dr. Morscher’s burner rig. The rig serves to simulate jet turbine conditions and test how materials, specifically ceramic matrix composites, react under high temperatures and stresses. Currently, the location of the torch relies solely on manual adjustments and has no automated control system. The improved design will automatically adjust the torch position based on the desired temperature of the sample being tested, therefore maintaining a steady environment for the sample. The current method of manual adjustments for regulating temperature is a crude solution that does not allow for specific testing conditions. We will utilize LabView to create the controls system with the input being the Forward Looking Infrared (FLIR) camera for temperature measurement, and the torch’s distance from the sample being the output. A FLIR camera mount will be modeled and produced to create a stationary position for the camera to take accurate measurements. The torch mount for this setup has already been created, including the servo motors required to move the torch. The main objective of this project is to create a controls system that will allow the mount to automatically move depending on the temperature input by the FLIR camera

Epigenetic Mechanisms of ART-Related Imprinting Disorders: Lessons From iPSC and Mouse Models.

The rising frequency of ART-conceived births is accompanied by the need for an improved understanding of the implications of ART on gametes and embryos. Increasing evidence from mouse models and human epidemiological data suggests that ART procedures may play a role in the pathophysiology of certain imprinting disorders (IDs), including Beckwith-Wiedemann syndrome, Silver-Russell syndrome, Prader-Willi syndrome, and Angelman syndrome. The underlying molecular basis of this association, however, requires further elucidation. In this review, we discuss the epigenetic and imprinting alterations of in vivo mouse models and human iPSC models of ART. Mouse models have demonstrated aberrant regulation of imprinted genes involved with ART-related IDs. In the past decade, iPSC technology has provided a platform for patient-specific cellular models of culture-associated perturbed imprinting. However, despite ongoing efforts, a deeper understanding of the susceptibility of iPSCs to epigenetic perturbation is required if they are to be reliably used for modelling ART-associated IDs. Comparing the patterns of susceptibility of imprinted genes in mouse models and IPSCs in culture improves the current understanding of the underlying mechanisms of ART-linked IDs with implications for our understanding of the influence of environmental factors such as culture and hormone treatments on epigenetically important regions of the genome such as imprints

Aphid Thermal Tolerance Is Governed by a Point Mutation in Bacterial Symbionts

Symbiosis is a ubiquitous phenomenon generating biological complexity, affecting adaptation, and expanding ecological capabilities. However, symbionts, which can be subject to genetic limitations such as clonality and genomic degradation, also impose constraints on hosts. A model of obligate symbiosis is that between aphids and the bacterium Buchnera aphidicola, which supplies essential nutrients. We report a mutation in Buchnera of the aphid Acyrthosiphon pisum that recurs in laboratory lines and occurs in field populations. This single nucleotide deletion affects a homopolymeric run within the heat-shock transcriptional promoter for ibpA, encoding a small heat-shock protein. This Buchnera mutation virtually eliminates the transcriptional response of ibpA to heat stress and lowers its expression even at cool or moderate temperatures. Furthermore, this symbiont mutation dramatically affects host fitness in a manner dependent on thermal environment. Following a short heat exposure as juveniles, aphids bearing short-allele symbionts produced few or no progeny and contained almost no Buchnera, in contrast to aphids bearing symbionts without the deletion. Conversely, under constant cool conditions, aphids containing symbionts with the short allele reproduced earlier and maintained higher reproductive rates. The short allele has appreciable frequencies in field populations (up to 20%), further supporting the view that lowering of ibpA expression improves host fitness under some conditions. This recurring Buchnera mutation governs thermal tolerance of aphid hosts. Other cases in which symbiont microevolution has a major effect on host ecological tolerance are likely to be widespread because of the high mutation rates of symbiotic bacteria and their crucial roles in host metabolism and development

Positive Clinical Psychology and Schema Therapy (ST): the development of the Young Positive Schema Questionnaire (YPSQ) to complement the Young Schema Questionnaire 3 Short Form (YSQ-S3)

Negative schemas have been widely recognized as being linked to psychopathology and mental health, and they are central to the Schema Therapy (ST) model. This study is the first to report on the psychometric properties of the Young Positive Schema Questionnaire (YPSQ). In a combined community sample (Manila, Philippines, n = 559; Bangalore, India, n = 350; Singapore, n = 628), we identified a 56-item 14-factor solution for the YPSQ. Confirmatory factor analysis supported the 14-factor model for data from the Singapore sample as well as 2 other samples; an Eastern sample from Kuala Lumpur, Malaysia (n =229) and a Western sample from the United States (n = 214). Construct validity was demonstrated with the Young Schema Questionnaire 3 Short Form (YSQ-S3) that measures negative schemas and divergent validity was demonstrated for 11 of the YPSQ subscales with their respective negative schema counterparts. Convergent validity of the 14 subscales of YPSQ was demonstrated with measures of personality dispositions, emotional distress, well-being, trait gratitude, and humor styles. Positive schemas also showed incremental validity over and above negative schemas for these same measures thus demonstrating that both positive and negative schemas are separate constructs that relate in unique ways to mental health. Implications for using both the YPSQ and the YSQ-S3 scales in tandem in ST as well as cultural nuances from the use of Asian samples were discussed