Withdrawing from Congressional-Executive Agreements with the Advice and Consent of Congress

As President Donald J. Trump withdrew the United States from one international agreement after another, many began to question whether these withdrawals required congressional approval. The answer may depend on the type of agreement. Based on history and custom, it appears that the president may unilaterally withdraw from agreements concluded pursuant to the treaty process outlined in the U.S. Constitution. However, the United States also has a long history of concluding international agreements as congressional-executive agreements, which use a different approval process that does not appear in the Constitution. But while academics have spilled ink on Article II treaties for decades, the congressional-executive agreement has received relatively little attention. It is neither clear nor well settled whether the president has the constitutional authority to withdraw unilaterally from this type of agreement. This Note proposes applying Justice Robert H. Jackson’s tripartite framework, first articulated in a concurring opinion to Youngstown Sheet & Tube Co. v. Sawyer (Steel Seizure), to determine whether or not a president may constitutionally withdraw from a congressional-executive agreement without Congress’s consent. However, in certain dire emergency situations or when Congress is physically unable to convene and vote, the president should be permitted to eschew the framework and withdraw the United States from a congressional-executive agreement without waiting for Congress’s consent—so long as the president reasonably believes that withdrawal is in the country’s best interest. To support this approach, this Note also calls for a new reporting statute, similar in structure to the War Powers Resolution, to address the significant information asymmetries between the executive and legislative branches

Assessment of Copper Total Bioaccumulation and Genotoxicity in Boac River, Marinduque Island, Philippines Two Decades Post-Mining Disaster: Pseudodon sp. as Aquatic Fauna Indicator

In 1996, a mining drainage tunnel burst and released copper wastes into the Boac River—rendering it dead. Two decades after the disaster, the river is now used for aquaculture farming. This study assessed the total bioaccumulation of copper and its genotoxicity in the mussel Pseudodon sp. farmed in the river. A total of 30 Pseudodon sp. were collected randomly from the downstream tributaries of the river in September 2015. Total bioaccumulation in terms of total copper concentrations was determined by atomic absorption spectrometry and the genotoxicity by micronucleus cytome assay. The total copper concentrations were present in the soft tissues (Mean + Standard Error of the Mean [SEM] of 0.0550 + 0.0003 ppm). Genotoxic indicators of nuclear alterations showed the formation of micronuclei yielding the highest frequency (Mean + SEM of 10.257 + 0.793 per 1000 cells). Binucleated, nuclear buds, agranular, apoptotic, and necrotic nuclear anomalies were likewise evident. Total copper concentrations and the frequency of the hemocyte micronuclei occurrences showed a significant relationship (r=0.366; p = 0.047) while the other nuclear abnormalities were not significantly related to the total copper concentrations. Continuous biomonitoring of mining-affected areas is necessary to safeguard people’s health from the effects of mining wastes. Keywords: bioaccumulation · copper · energy use · genotoxicity · heavy metal · mining · nuclear abnormalitie

Integrative model of behavioural intention: the influence of environmental concern and condition factors on food waste separation

Purpose This paper positions environmental concern as the antecedent of attitude, subjective norm and perceived behavioural control. It also sets to expand the theory of planned behaviour by including two condition factors: favourable situation and facility availability on the intention to separate food waste at source. Design/methodology/approach The study collects data by using self-administered questionnaires on 682 respondents in Malaysia. Structural equation modelling is employed to test the conceptual model and the proposed hypotheses. Findings The results show that environmental concern positively influences attitude and subjective norms, which, in turn, influences food waste separation intention. Favourable situation and facility availability are found to influence the separation intention. Originality/value This study is one of the earliest studies to investigate residents’ intention to participate in food waste separation at a source that employs the expanded theory of planned behaviour with environmental concern and condition factors

Data on experimental investigation of Methyl Ester Sulphonate and nanopolystyrene for rheology improvement and filtration loss control of water-based drilling fluid

Data presented in this article focused on the application of Methyl Ester Sulphonate (MES) surfactant and nanopolystyrene in water based drilling fluid. Data from rheology study using Bingham and Power law models showed that the synergy of MES and nanopolystyrene improved the formulated drilling fluid. Filtration study under LPLT and HPHT conditions showed that MES and nanopolystyrene drilling fluid reduced filtration loss by 50.7% at LPLT and 61.1% at HPHT conditions. These filtration data were validated by filter cake permeability and scanning electron microscope images

Penerapan Prinsip-prinsip Good Corporate Governance pada Perusahaan Keluarga di Bidang Distribusi Gula

Penelitian ini mengkaji tentang penerapan Corporate Governance dengan menggunakan prinsip transparansi, akuntabilitas, responsibilitas, independensi, dan kesetaraan. peneliti mengumpulkan data dengan metode wawancara dan observasi. Setelah mendapatkan data, peneliti memastikan keabsahan data dengan metode trianggulasi sumber, yaitu dengan membandingkan hasil wawancara , data- tertulis dan juga hasil observasi. Dari penelitian yang dilakukan oleh penulis, ditemukan bahwa Perusaahaan telah melaksanakan sebagian dari prinsip-prinsip GCG. Rekomendasi penulis kepada Perusahaan adalah agar Perusahaan dapat menerapkan seluruh prinsip GCG dengan baik melalui perbaikan prinsip akuntabilitas dan independensi untuk meningkatkan kinerja Perusahaan

Liver Cancer Cell of Origin, Molecular Class, and Effects on Patient Prognosis

Primary liver cancer is the second leading cause of cancer-related death worldwide and therefore a major public health challenge. We review hypotheses of the cell of origin of liver tumorigenesis and clarify the classes of liver cancer based on molecular features and how they affect patient prognosis. Primary liver cancer comprises hepatocellular carcinoma (HCC), intrahepatic cholangiocarcinoma (iCCA), and other rare tumors, notably fibrolamellar carcinoma and hepatoblastoma. The molecular and clinical features of HCC versus iCCA are distinct, but these conditions have overlapping risk factors and pathways of oncogenesis. A better understanding of the cell types originating liver cancer can aid in exploring molecular mechanisms of carcinogenesis and therapeutic options. Molecular studies have identified adult hepatocytes as the cell of origin. These cells have been proposed to transform directly into HCC cells (via a sequence of genetic alterations), to dedifferentiate into hepatocyte precursor cells (which then become HCC cells that express progenitor cell markers), or to transdifferentiate into biliary-like cells (which give rise to iCCA). Alternatively, progenitor cells also give rise to HCCs and iCCAs with markers of progenitor cells. Advances in genome profiling and next-generation sequencing have led to the classification of HCCs based on molecular features and assigned them to categories such as proliferation-progenitor, proliferation-transforming growth factor β, and Wnt-catenin β1. iCCAs have been assigned to categories of proliferation and inflammation. Overall, proliferation subclasses are associated with a more aggressive phenotype and poor outcome of patients, although more specific signatures have refined our prognostic abilities. Analyses of genetic alterations have identified those that might be targeted therapeutically, such as fusions in the FGFR2 gene and mutations in genes encoding isocitrate dehydrogenases (in approximately 60% of iCCAs) or amplifications at 11q13 and 6p21 (in approximately 15% of HCCs). Further studies of these alterations are needed before they can be used as biomarkers in clinical decision making

A High Diffusive Model for Nanomaterials

Considerable attention is today devoted to the engineering of films widely used in photocatalytic, solar energy converters, photochemical and photoelectrochemical cells, dye-sensitized solar cells (DSSCs), to optimize electronic time response following photogeneration. However, the precise nature of transport processes in these systems has remained unresolved. To investigate such aspects of carrier dynamics, we have suggested a model for the calculation of correlation functions, expressed as the Fourier transform of the frequency-dependent complex conductivity σ(ω). Results are presented for the velocity correlation functions, the mean square deviation of position and the diffusion coefficient in systems, like TiO2 and doped Si, of large interest in present devices. Fast diffusion occurs in short time intervals of the order of few collision times. Consequences for efficiency of this fast response are discussed in relation to nanostructured devices

A Systematic Review on Water Hyacinth (Eichhornia crassipes) as a Biosorbent of Cadmium

Water hyacinth has gained a noteworthy reputation as the worst invasive macrophyte for its alarming proliferation rates, threatening transportation and irrigation systems and ecosystem biodiversity. Sustainable efforts have found the plant to demonstrate efficiency in sequestering toxic heavy metals such as cadmium from marine environments. Cadmium presence in water, primarily caused by anthropogenic sources, poses public health risks due to its toxicity. Consequently, studies on the applications of Eichhornia crassipes and the removal of cadmium have become active research areas in recent decades. This review presents literature related to the Cd sorption capacity of water hyacinth biosorbents. The effects and optimization of parameters including treatment, temperature, pH, initial sorbate and sorbent concentration have been explored in classical and competitive adsorption models. Investigations on kinetics, equilibrium, and desorption studies have also been conducted. From the gathered literature, water hyacinth biosorbents show potential for industrial-scale applications, but its metal recovery and utilization in multi-metal and continuous sorption may require further evaluation

Particle-Based Monte-Carlo Simulations of Steady-State Mass Transport at Intermediate Péclet Numbers

Conventional approaches for simulating steady-state distributions of dilute particles under diffusive and advective transport involve solving the diffusion and advection equations in at least two dimensions. Here, we present an alternative computational strategy by combining a particle-based rather than a field-based approach with the initialisation of particles in proportion to their flux. This method allows accurate prediction of the steady state and is applicable even at intermediate and high Péclet numbers (Pe>1) swhere traditional particle-based Monte-Carlo methods starting from randomly initialised particle distributions fail. We demonstrate that generating a flux of particles according to a predetermined density and velocity distribution at a single fixed time and initial location allows for accurate simulation of mass transport under flow. Specifically, upon initialisation in proportion to their flux, these particles are propagated individually and detected by summing up their Monte-Carlo trajectories in predefined detection regions. We demonstrate quantitative agreement of the predicted concentration profiles with the results of experiments performed with fluorescent particles in microfluidic channels under continuous flow. This approach is computationally advantageous and readily allows non-trivial initial distributions to be considered. In particular, this method is highly suitable for simulating advective and diffusive transport in microfluidic devices, for instance in the context of diffusive sizing.Financial support from the Biotechnology and Biological Sciences Research Council (BBSRC), the European Research Council (ERC), the Frances and Augustus Newman Foundation as well as the Swiss National Science Foundation is gratefully acknowledged

Particle-Based Monte-Carlo Simulations of Steady-State Mass Transport at Intermediate Péclet Numbers

Conventional approaches for simulating steady-state distributions of dilute particles under diffusive and advective transport numbers involve solving the diffusion and advection equations in at least two dimensions. Here, we present an alternative computational strategy by combining a particle-based rather than a field-based approach with the initialisation of particles in proportion to their flux. This method allows accurate prediction of the steady state and is applicable even at intermediate and high Péclet numbers (Pe>1) where traditional particle-based Monte-Carlo methods starting from randomly initialised particle distributions fail. We demonstrate that generating a flux of particles according to a predetermined density and velocity distribution at a single fixed time and initial location allows for accurate simulation of mass transport under flow. Specifically, upon initialisation in proportion to their flux, these particles are propagated individually and detected by summing up their Monte-Carlo trajectories in predefined detection regions. We demonstrate quantitative agreement of the predicted concentration profiles with the results of experiments performed with fluorescent particles in microfluidic channels under continuous flow. This approach is computationally advantageous and readily allows non-trivial initial distributions to be considered. In particular, this method is highly suitable for simulating advective and diffusive transport in microfluidic devices, for instance in the context of diffusive sizing.Financial support from the Biotechnology and Biological Sciences Research Council (BBSRC), the European Research Council (ERC), the Frances and Augustus Newman Foundation as well as the Swiss National Science Foundation is gratefully acknowledged