Signal-to-noise ratios, instrument parameters and repeatability of Itrax XRF core scan measurements of floodplain sediments

This study used signal-to-noise ratios to assess the effects of increasing Itrax XRF instrument parameters, namely tube voltage, tube current and exposure time, on XRF spectra and measurement repeatability. Tests were performed on cores from British and Irish floodplains. Seven combinations of tube voltage and current and six exposure times were compared using signal-to-noise ratios for eight target elements. Signal-to-noise ratios may be substantially improved by selecting instrument parameters, particularly tube voltage, for specific target elements. They can also be used to assess element profile suitability for interpretation by comparison with the limit of quantification. Repeatability was assessed using the standard deviation of measurements in nine repeat scans. The variation in element levels in the majority of profiles is considerably greater than the variability in individual measurements

Image analysis in sedimentology as application for high-resolution grain size analysis: a case study of lake sediments from Tangra Yumco (Tibetan Plateau)

Abstract HKT-ISTP 2013 B

Texas Two-Stepping Out of Bankruptcy

Johnson & Johnson has a problem. For decades, it sold talc baby powder, a product that made Johnson & Johnson a household name and earned the business billions. But as those babies grew up, they started getting cancer. And then they began suing. Last June, twenty-two plaintiffs cemented a $2.12 billion judgment against Johnson & Johnson for cancer caused by its baby powder. Another 38,000 cases (and counting) remain in progress, each with the potential for a similar verdict. To handle these mass tort liabilities, Johnson & Johnson has followed the lead of many businesses and turned to the bankruptcy courts. But it has done so with a twist. Unlike the businesses that pioneered using bankruptcy for mass torts, Johnson & Johnson is not filing for bankruptcy. Instead, it is dividing itself using an obscure Texas law, moving its assets into one business and its talc liabilities into another, and having the liability-laden business file for bankruptcy. This maneuver, known as the “Texas Two-Step,” threatens the tort recovery of tens of thousands of talc claimants. The Texas Two-Step is the latest addition to a panoply of aggressive techniques debtors have developed to gain the upper hand against creditors. Other scholars, for example, have identified the use of coercive restructuring support agreements and “deathtraps,” third-party releases, and less-than-impartial bankruptcy directors to disadvantage creditors. The use of such techniques has been widely criticized as “bankruptcy hardball,” “the breakdown of chapter 11,” or simply “lawlessness.” It is now time to add the two-step to that catalog and to consider how that aggressive tactic might be counteracted. The balance of this Essay does just that. Part I begins with an explanation of mass torts in bankruptcy and how the Texas Two-Step offers debtors something new. Part II then discusses fraudulent transfer law, the main avenue commentators have considered for tort claimants responding to the Texas Two-Step, and the shortcomings of that avenue. Next, in Part III, this Essay suggests a role for good faith challenges, which tort claimants may bring at the beginning of a bankruptcy and may have resolved far more quickly, enabling claimants to counteract the efficacy of the Texas Two-Step. Finally, the Essay concludes with some reflections on what the two-step means for the longstanding debate on bankruptcy forum shopping and on what the two-step adds to more recent discussions of the ongoing role of common law in bankruptcy’s statutory system

Disaggregating State Bankruptcy

States today face fiscal challenges that they cannot surmount. With trillions in debt and billions in deficits, states are rapidly reaching the point where they cannot satisfy their obligations to pensioners, employees, and residents. This deterioration of state finances has, in turn, revived the debate over whether Congress should expand the Bankruptcy Code to allow states to file for bankruptcy. The debate, though, overlooks how, as a practical matter, bankruptcy is already available to financially distressed states. Chapter 9 of the Bankruptcy Code permits a state’s political subdivisions, public agencies, and instrumentalities to file for bankruptcy if the state authorizes them to do so. A state can therefore make its own debt bankruptcy-eligible by having a government entity—other than the state itself—owe the debt, and by authorizing all government entities in the state to file for bankruptcy. This disaggregation—states operating, and taking on debt, through government entities rather than the state itself—is already the norm. In fact, the vast majority of so-called “state debt,” some ninety percent, is owed not by states themselves, but by government entities eligible to file for bankruptcy. The interaction of disaggregated states and Chapter 9 leads to a doctrinal oddity: Debt owed by the state itself is not bankruptcy-eligible, but that same debt, if owed by a state agency or instrumentality, is bankruptcy-eligible. That doctrinal oddity has enormous significance, both theoretical and practical. For theory, disaggregation shows that states can partition liability, confining distress to a particular entity instead of having that entity’s liabilities threaten the fiscal stability of the whole state. As for practice, disaggregation offers a superior alternative to adding a state bankruptcy chapter to the Code. Disaggregation is simpler, fairer, and has fewer spillover effects, offering states a good way to address their current, dire, fiscal situations

Designing Designer Bankruptcy

Today\u27s mass torts are headed to bankruptcy. Be it Purdue Pharma \u27s opioids, United States of America (USA) Gymnastics\u27 sexual abuse, Pacific Gas and Electric Company\u27s (PG&E) wildfires, or Johnson & Johnson \u27s talc, masstort defendants have determined that bankruptcy-not class actions, multi district litigation, or one-off state suits-is the way to manage their mass-tort liability. But today\u27s mass-tort bankruptcy is not the mass-tort bankruptcy of yesteryear, when the whole business filed for bankruptcy. Instead, these modern mass-tort bankruptcies are designer bankruptcies, where the defendant uses its corporate structure to choose which assets and which liabilities enter bankruptcy. To take today\u27s marquee example, Johnson & Johnson, facing 38,000 tort suits alleging that its talc caused cancer, put those tort liabilities into a distinct limited liability company and had that company file for bankruptcy. Meanwhile, the remainder of Johnson & Johnson, including the division responsible for talc, continued to operate normally, staying outside of bankruptcy entirely. This Article takes stock of those designer bankruptcies. It begins by tracing their evolution from the original Manville Model, which emerged from asbestos litigation in the 1980s, to the contemporary Texas Two-Step, made famous by Johnson & Johnson. The Article then situates these designer bankruptcies in a new theoretical framework, one drawn from organizational law, to understand the promise of designer bankruptcy (for tort victims and businesses alike) and the dangers to tort victims of being shortchanged by those designer bankruptcies. The Article then translates that framework into recommendations for Congress and for courts to better design these designer bankruptcies to capture the value of sound design while protecting tort victims

Imaging air volume fraction in sea ice using non-destructive X-ray tomography

Although the presence of a gas phase in sea ice creates the potential for gas exchange with the atmosphere, the distribution of gas bubbles and transport of gases within the sea ice are still poorly understood. Currently no straightforward technique exists to measure the vertical distribution of air volume fraction in sea ice. Here, we present a new fast and non-destructive X-ray computed tomography technique to quantify the air volume fraction and produce separate images of air volume inclusions in sea ice. The technique was performed on relatively thin (4–22cm) sea ice collected from an experimental ice tank. While most of the internal layers showed air volume fractions 5 mm). While micro bubbles were the most abundant type of gas bubbles, most of the air porosity observed resulted from the presence of large and macro bubbles. The ice texture (granular and columnar) as well as the permeability state of ice are important factors controlling the air volume fraction. The technique developed is suited for studies related to gas transport and bubble migration

Arctic hydroclimate variability during the last 2000 years : current understanding and research challenges

Reanalysis data show an increasing trend in Arctic precipitation over the 20th century, but changes are not homogenous across seasons or space. The observed hydro-climate changes are expected to continue and possibly accelerate in the coming century, not only affecting pan-Arctic natural ecosystems and human activities, but also lower latitudes through the atmospheric and ocean circulations. However, a lack of spatiotemporal observational data makes reliable quantification of Arctic hydroclimate change difficult, especially in a long-term context. To understand Arctic hydroclimate and its variability prior to the instrumental record, climate proxy records are needed. The purpose of this review is to summarise the current understanding of Arctic hydroclimate during the past 2000 years. First, the paper reviews the main natural archives and proxies used to infer past hydroclimate variations in this remote region and outlines the difficulty of disentangling the moisture from the temperature signal in these records. Second, a comparison of two sets of hydroclimate records covering the Common Era from two data-rich regions, North America and Fennoscandia, reveals inter- and intra-regional differences. Third, building on earlier work, this paper shows the potential for providing a high-resolution hydroclimate reconstruction for the Arctic and a comparison with last-millennium simulations from fully coupled climate models. In general, hydroclimate proxies and simulations indicate that the Medieval Climate Anomaly tends to have been wetter than the Little Ice Age (LIA), but there are large regional differences. However, the regional coverage of the proxy data is inadequate, with distinct data gaps in most of Eurasia and parts of North America, making robust assessments for the whole Arctic impossible at present. To fully assess pan-Arctic hydroclimate variability for the last 2 millennia, additional proxy records are required.Peer reviewe

B Cells Negatively Regulate the Establishment of CD49b+T-bet+ Resting Memory T Helper Cells in the Bone Marrow

During an immune reaction, some antigen-experienced CD4 T cells relocate from secondary lymphoid organs (SLOs) to the bone marrow (BM) in a CD49b-dependent manner and reside and rest there as professional memory CD4 T cells. However, it remains unclear how the precursors of BM memory CD4 T cells are generated in the SLOs. While several studies have so far shown that B cell depletion reduces the persistence of memory CD4 T cells in the spleen, we here show that B cell depletion enhances the establishment of memory CD4 T cells in the BM and that B cell transfer conversely suppresses it. Interestingly, the number of antigen-experienced CD4 T cells in the BM synchronizes the number of CD49b+T-bet+ antigen-experienced CD4 T cells in the spleen. CD49b+T-bet+ antigen-experienced CD4 T cells preferentially localize in the red pulp area of the spleen and the BM in a T-bet-independent manner. We suggest that B cells negatively control the generation of CD49b+T-bet+ precursors of resting memory CD4 T cells in the spleen and may play a role in bifurcation of activated effector and resting memory CD4 T cell lineages