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October 2, 2020 California Becomes First State to Ban PFAS in Cosmetics
By Steven M. Siros
On August 30, 2020, the California legislature passed the Toxic Free Cosmetics Act making California the first state to ban certain chemicals from cosmetics. Governor Newson signed the bill into law on October 1, 2020. The new law amends existing regulatory programs in California and provides that cosmetics containing any of a specific list of 24 chemicals will be considered "adulterated" and therefore unable to be sold in California. The specific list of chemicals includes certain phthalates and formaldehyde. However, the chemicals that have received the most attention are various per- and polyfluoroalkyl (PFAS) substances. Although some states have previously implemented legislation banning certain chemicals in cosmetic products (Minnesota banned formaldehyde in certain children's personal care products; Washington requires that certain chemicals in children's products be reported), California has become the first state to implement such a broad ban on these listed chemicals in cosmetics generally.
The ban will take effect on January 1, 2025 providing companies with time to take the necessary steps to eliminate any of the 24 listed chemicals from their cosmetic products. Of course, many companies have already taken steps to eliminate these chemicals from their products especially since many of these chemicals are already on California's Proposition 65 list. However, unlike with Proposition 65 where compliance can be demonstrated by the provision of the requisite warnings, the Toxic Free Cosmetics Act will require elimination of these chemicals (with the exception of unavoidable trace quantities).
We will continue to provide regulatory updates as more states are likely to follow California's lead in regulating these chemicals in various personal care products.
CATEGORIES: Consumer Law and Environment, Contamination, Emerging Contaminants, Toxic Tort
April 21, 2020 Supreme Court issues Landmark CERCLA Ruling Finding that State Law Challenges to USEPA Cleanup Can Be Raised in State Court (But Plaintiffs Still Lose)
On Monday, April 20, 2020, the United States Supreme Court issued a key opinion regarding the preclusive effect of the Comprehensive Environmental Response, Compensation and Recovery Act (CERCLA), 42 U.S.C. Section 9601, on state common law remedies within Superfund Sites. In Atlantic Richfield v. Christian, Case No. 17-1498, the Supreme Court affirmed in part and vacated in part a decision by the Montana Supreme Court that "restoration claims" asserted by private property owners could go forward against a potentially responsible party (PRP) that had previously settled its CERCLA liability with the United States Environmental Protection Agency (USEPA).
The case involves the Anaconda Smelter Site, a Superfund site covering 300 square miles of property contaminated by historical smelter and ore processing operations. In 1983, USEPA identified Atlantic Richfield Co. as a PRP for the site's contamination and the parties entered into a settlement agreement that required Atlantic Richfield to investigate and remediate the site under the oversight of USEPA. In the 37 years since, USEPA has managed an extensive cleanup at the site, which included the removal of 10 million cubic yards of contaminated soil and capping in place an additional 500 million cubic yards of waste over 5,000 acres. Atlantic Richfield estimates that it has spent approximately $450 Million USD remediating the site and that its cleanup is nearly complete.
However, the USEPA-mandated cleanup standards were deemed insufficient by a number of local landowners who allege that their properties remain damaged by Atlantic Richfield's contamination. The landowners asserted common law tort claims against Atlantic Richfield seeking funds to remediate their properties—located within the Superfund Site—beyond the levels required by the USEPA-approved remedy. For example, the plaintiffs sought funding to remediate arsenic levels in their properties' soil to a level of 15 parts per million, rather than the 250 parts per million limit approved by USEPA. In total, the additional cleanup efforts sought by plaintiffs are estimated to cost Atlantic Richfield an additional $50 to $58 million in cleanup costs. Following the Montana Supreme Court's holding that the landowner's restitution claims could proceed in spite of Atlantic Richfield's settlement with USEPA and the ongoing cleanup effort, Atlantic Richfield appealed the issue to the Supreme Court.
Atlantic Richfield argued that plaintiff's claims were barred because CERCLA §113 strips courts of the jurisdiction to review challenges to USEPA cleanup plans. Atlantic Richfield further argued that plaintiffs' restoration claims were precluded by CERCLA §122(e)(6), which provides that "no potentially responsible party may undertake any remedial action" at the site without EPA approval. Atlantic Richfield cautioned that the Montana Supreme Court's contrary reading of CERCLA would throw a wrench into the Act's carefully balanced settlement scheme by allowing landowners at Superfund sites to "shred EPA's plans and impose different, and potentially detrimental, multimillion-dollar cleanups." In an amicus brief, The Chamber of Commerce and other industry groups sided with Atlantic Richfield, arguing that the Montana Supreme Court's ruling would create "chaos across the Nation's Superfund sites, with EPA pursuing one remediation course and various ad hoc private lawsuits mandating different, potentially dangerous or conflicting remediation work." An amicus brief was also filed by the Solicitor General on behalf of the United States, which argued that the Supreme Court should deny Atlantic Richfield's writ of certiorari because the Montana Supreme Court had yet not reached a final judgment in the underlying dispute and review of the proposed questions was premature at the current state of litigation. However, the Solicitor's amicus brief went on to state that—in the event the Supreme Court granted certiorari—the Court should find that that Montana Supreme Court erred in holding that the landowner's claims for restoration damages did not constitute "challenges" to USEPA's selected remedy under CERCLA §113. The Solicitor reasoned that enactment of the landowner's proposed restoration actions would "directly impact the implementation" of USEPA's existing remedy and that the proposed actions therefore constituted a challenge to the cleanup.
In response, plaintiffs argued that their common law claims were not barred by CERCLA §113 because the claims did not "arise under" CERCLA. In addition, the plaintiffs argued their claims for money to restore their property did not constitute a "challenge" to the cleanup because plaintiffs were not seeking to overturn the USEPA order or otherwise asking the court to review that order. Rather, plaintiffs were merely seeking to compel Atlantic Richfield to "restore" their impacted properties by further removing impacted soils that remained unaddressed by the USEPA cleanup order based on Minnesota common law statutes.
In a split opinion, the Supreme Court ultimately held that the plaintiff's state law claims against Atlantic Richfield were not precluded by CERCLA, but that the plaintiffs could not move forward with additional restoration activities without first securing approval from USEPA. First, the court held that §113 did not divest the Montana Supreme Court of jurisdiction over plaintiff's claims because the state common law claims did not arise under CERCLA. However, the Supreme Court went on to find that—as owners of property located within the Superfund Site—plaintiffs were themselves PRPs for the Anaconda Smelter Site. Thus, under CERCLA §122, plaintiff were precluded from implementing any remedial actions at the site without first securing USEPA approval. As reasoned by Chief Justice Robert's majority opinion, "under the landowners' interpretation, property owners would be free to dig up arsenic-infected soil and build trenches to redirect lead-contaminated groundwater without even notifying EPA…[w]e doubt Congress provided such a fragile remedy to such a serious problem."
Justice Alito filed a separate opinion—concurring in part and dissenting in part—in which the Justice endorsed the Court's finding that plaintiffs were PRPs under CERCLA. However, Justice Alito argued that the court should not have reached the question of whether state courts have jurisdiction to entertain "challenges" to EPA-approved cleanups. Justice Alito went on to clarify his understanding that under the Court's majority opinion, "the Montana Supreme Court has two options on remand: (1) enter a stay to allow the landowners to seek EPA approval or (2) enter judgment against the landowners on their restoration damages claim without prejudice to their ability to refile if they obtain EPA approval." Under either scenario, USEPA approval would be required and therefore Justice Alito concluded that the Court should not have opined on the jurisdictional question.
Justice Gorsuch also filed a separate opinion concurring in part and dissenting in part, in which Justice Thomas joined. Justice Gorsuch agreed that the Montana state court had jurisdiction over plaintiffs' state law claims but disagreed with the Court's conclusion that plaintiffs were PRPs under CERCLA and therefore precluded under CERCLA §122 from challenging the USEPA cleanup plan. Justice Gorsuch argued that CERCLA was enacted to supplement, not supplant, state common law remedies available to innocent landowners damaged by third-party contamination. Thus, Justice Gorsuch opined that plaintiffs' state law claims should be allowed to go forward without the need to secure permission from USEPA.
Jenner & Block's Corporate Environmental Lawyer will continue to track and update on this case as it is remanded back to the Montana Supreme Court.
CATEGORIES: Cercla, Toxic Tort, Water
PEOPLE: Steven M. Siros, Matthew G. Lawson
February 21, 2020 EPA Announces Regulatory Determination to Regulate PFAS in Drinking Water
On Thursday, February 20, 2020, the U.S. Environmental Protection Agency ("EPA") announced a preliminary regulatory determination that the agency will seek to implement regulatory limits for Per- and Polyfluoroalkyl Substances (PFAS) in public drinking water across the United States. The regulatory determination is a key step in the creation of a Maximum Contamination Level ("MCL") that will act to limit the quantity of PFAS permitted in public drinking water. In its preliminary regulatory determination, EPA proposes setting MCL levels for two PFAS substances, perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS), which EPA has determined meet the statutory criteria to become regulated contaminants under the Safe Drinking Water Act. To meet this criteria, EPA had to find that: (1) the consumption of PFOS and PFOA may result in adverse health effects; (2) PFOS and PFOA have been identified in public water supplies at frequencies and levels sufficient to cause a public health concern; and (3) that new regulation presents a meaningful opportunity to reduce the health risks posed by PFOS and PFOA.
As part of its announcement, EPA will seek public comments on its preliminary findings for the next 60 days. Critically, the preliminary regulatory determination offers no insight into the regulatory levels EPA anticipates setting for PFOS or PFOA. Through its voluntary Health Advisory Level ("HAL"), EPA currently recommends that municipalities maintain a maximum limit of 70 parts per trillion of PFAS in drinking water served to the public. While the HAL is referenced in EPA's preliminary regulatory determination, it is unclear whether EPA will look to set PFOS or PFAS' mandatorily MCL at a similar level. EPA's election to regulate PFOS and PFOA kicks off a two-year period for the agency to determine an appropriate MCL for the contaminants. Following the formal proposal of an MCL, the agency has another 18 months to set its final drinking water requirements.
The release of a preliminary regulatory determination marks a critical step in EPA's implementation of its PFAS Action Plan. Under the PFAS Action Plan, EPA has committed to "identifying and understanding PFAS, [ ] addressing current PFAS contamination, preventing future contamination, and effectively communicating with the public about PFAS." The plan sets forth four overarching goals for regulating PFAS:
Consider the creation of an MCL for PFOA and PFOA;
Begin necessary steps to propose designating PFOA and PFOS as "hazardous substances" through available federal statutory mechanisms, including CERCLA, RCRA, TSCA and the CWA;
Develop and implement groundwater cleanup recommendations for PFOA and PFOS at contaminated sites;
Develop toxicity values or oral reference doses for various PFAS chemicals.
Under the Trump Administration, the EPA has repeatedly affirmed that addressing the emerging contaminant PFAS is a key and ongoing priority for the agency. As stated in the PFAS Action Plan, "the EPA has heard clearly the public's desire for immediate action to address potential human health and economic impacts from PFAS in the environment." In fact, despite proposing large cuts to EPA's overall budget, the Trump Administration's proposed budget for 2021 requests an additional $6 million dollars from Congress to carry out EPA's PFAS Action Plan. "Under President Trump, EPA is continuing to aggressively implement our PFAS Action Plan – the most comprehensive cross-agency plan ever to address an emerging chemical," stated EPA Administrator Andrew Wheeler. "With today's action, EPA is following through on its commitment in the Action Plan to evaluate PFOA and PFOS under the Safe Drinking Water Act."
CATEGORIES: Consumer Law and Environment, Sustainability, Toxic Tort, Water
January 13, 2020 Failure to Designate PFAS as Hazardous Substance May Doom Medical Monitoring Lawsuit
The fact that neither perfluorooctanoic acid (PFOA) nor perfluorooctane sulfonic acid (PFOS) is classified as a hazardous substance may prove fatal to plaintiffs' efforts to convince a federal court to allow a novel citizen suit to proceed. In the case of Kristen Giovanni, et al. v. Navy which is pending in the U.S. District Court for the Eastern District of Pennsylvania, plaintiffs brought a citizen suit under a Pennsylvania cleanup statute seeking to compel the Navy to monitor residents for potential health issues linked to PFOS and PFOA exposure. In October 2018, the Third Circuit Appellate Court affirmed an earlier ruling from the district court that had rejected plaintiffs' efforts to compel the Navy to undertake a government-led health assessment, finding that such a request constituted an impermissible challenge to an ongoing CERCLA response action. The Third Circuit concluded that plaintiffs' request for a government-led health study sought injunctive relief that could potentially interfere with the ongoing response action at the site. Plaintiffs' request for medical monitoring, on the other hand, sought to compel the Navy to fund a trust, which the Third Circuit concluded was not a challenge to ongoing response actions at the site.
During a hearing following remand from the Third Circuit, the district court judge noted that Section 1115 of Pennsylvania's Hazardous Sites Cleanup Act (HSCA) (which provides for a citizen-suit right of action) only provides relief for HSCA designated "hazardous substances." Although plaintiffs' counsel argued that PFOA and PFOS fell within the HSCA's definition of "hazardous substances," in fact neither substance has been designated as a "hazardous substance" under CERCLA, nor have they been so designated by the Pennsylvania Department of Environmental Protection. In what may be foreshadowing of how the court intends to rule, the judge noted that if he were to dismiss plaintiffs' case, in the event that either the state or U.S. EPA were to designate PFOA and/or PFOS as "hazardous substances," plaintiffs would be able to file a new lawsuit.
CATEGORIES: Climate Change, Hazmat, Sustainability, Toxic Tort, Water
December 30, 2019 New York Bans PFAS Chemicals in Firefighting Foam as Industry Fights for Exemptions
On December 23, 2019, New York Governor Andrew M. Cuomo gave conditional approval to a state ban on firefighting foams containing per- and polyfluoroalkyl substances (known as "PFAS"). PFAS, commonly referred to as "forever chemicals" due to their ongoing persistence in the environment, are a family of man-made chemicals commonly found in a variety of products, including food packaging, cookware, stain-resistant clothing, and, in the case of perfluorooctane sulfonic acid (PFOS), many types of firefighting foams. According to the U.S. EPA, PFAS chemicals are not only "extremely persistent in the environment," but have also been linked to numerous health conditions including cancer in humans.
The legislation ("A445A") requires the New York Office of Fire Prevention and Control to promulgate regulations that will provide guidance for state agencies and local government to avoid the purchase of firefighting foams containing PFAS compounds and outright prohibits the manufacture of PFAS containing firefighting foams within two years of the effective date of the bill. As a condition to his approval, Governor Cuomo noted that an amendment to the current legislation was needed to allow discretionary use of firefighting agents containing PFAS where no other viable options exist. On the basis of an agreement with the New York legislature to implement these amendments, the Governor conditionally approved the bill.
With the enactment of the legislation, New York becomes the third U.S. state to ban PFAS chemicals behind Washington and New Hampshire. In addition, six other states have enacted some form of partial prohibitions on the use of foams containing PFAS chemicals. In response to the recent state legislation, the FluoroCouncil has affirmed that use of firefighting foam containing PFAS "is credited with saving lives and property" and that use of such foams may be essential for extinguishing fires caused by flammable liquids.
Regulation of PFAS chemicals is also being considered at the federal level. As noted in a prior blog by the Corporate Environmental Lawyer, a federal bill is currently being considered that would require the U.S. EPA to promulgate drinking water standards for PFOS as well as perfluorooctanoic acid (PFOA), another common chemical in the PFAS family. According to the Congressional Budget Office (CBO), the estimated cost of implementing these federal standards across the country are likely to exceed "several billion dollars." The Corporate Environmental Lawyer will continue to update on forthcoming or pending state and federal legislation regarding PFAS chemicals.
CATEGORIES: Air, Climate Change, Greenhouse Gas, Hazmat, Sustainability, Toxic Tort
July 29, 2019 Exploring the E-Suite with Elizabeth Anderson, Ph.D., Fellow ATS, Chief Science Officer and Senior Fellow, Exponent, Inc.; formerly, Carcinogen Assessment Group and Office of Health and Environmental Assessment, U.S. EPA
Exploring the E-Suite with Elizabeth Anderson, Ph.D., Fellow ATS, Chief Science Officer and Senior Fellow, Exponent, Inc.; formerly, Carcinogen Assessment Group and Office of Health and Environmental Assessment, U.S. EPA
I understand that you worked for U.S. EPA when it was first started as a federal agency in the early 1970s. What was your role at the "new" U.S. EPA?
I led the health sciences assessment work for the first 14 years after U.S. EPA was formed in December 1970. At the time, U.S. EPA was a very small agency. I was the only health scientist in an eight-person Office of Technical Analysis, reporting directly to U.S. EPA's first Administrator, Bill Ruckelshaus. He is an extraordinary person—a terrific and committed leader, who also knew how to make hard work fun. The Administrator asked me to lead an intra-agency committee to write a cancer policy to address the zero risk tolerance expectation for substances with some evidence, often conflicting, of carcinogenicity, as indicated by tumors in animals or humans. Another challenge was that substances could be ubiquitous or important to our society. We knew a "zero tolerance" policy for all possible carcinogens would be unworkable, so my committee reported out a process rather than a cancer policy. That process was the first use of risk assessment to organize what is known and unknown about the likelihood that exposure to a particular agent might cause illness. On the assumption the agent might cause illness, the next step is to define what levels of risk and exposure would be acceptable and protective of public health. The concept of risk acceptance was novel at the time and was introduced in a social and political climate aimed at seeking the ideal, i.e., zero risk.
My office at U.S. EPA conducted and I co-authored more than 150 risk assessments between 1976 and 1983 as a basis for defining major regulatory policy. The National Academy of Sciences published its endorsement of this risk assessment process in 1983. The Academy's report, referred to as "The Red Book," inspired national and international adoption of the U.S. EPA's approach to risk assessment started by my intra-agency committee. I led the effort to expand the health assessment program, which resulted in establishing the central risk assessment office for the Agency—the Office of Health and Environmental Assessment. This office reported directly to the Administrator, who granted us wide latitude to expeditiously conduct our assessments.
What was your professional and academic background leading to your involvement in health risk assessment?
My academic background is in synthetic organic chemistry, the chemistry of making organic molecules, amongst other applications, to be biologically active. I was pre-med at the College of William and Mary, but I was strongly discouraged from pursuing medical school "because I would be taking the place of a man" (a quote from the Chairman of the Chemistry Department). Instead, I was granted a fellowship at the University of Virginia to pursue a master's degree in synthetic organic chemistry. Next, I applied for a unique fellowship being granted by the U.S. Department of Defense and completed my Ph.D. work in synthetic organic chemistry. During those early years of U.S. EPA, my degree and training best fit the Agency's needs. There were no degrees in toxicology, relevant applications in epidemiology were just emerging, and mechanism of action had received little attention. I was fortunate to be in the right place at the right time.
What was it like to be part of the start of a new federal agency?
Most of all, it was challenging. Following the civil rights movement, the anti-Vietnam war movement, and 20 million people marching on the first Earth Day, the spirit of the time was that significant change can happen; every move at EPA was front-page news. We all felt a sense of urgency to make a difference and establish scientific credibility for all decisions that the Agency had to make. U.S. EPA inherited a rapidly cascading series of enabling legislation starting with the Clean Air Act in December of 1970, followed by amendments to the Federal Water Pollution Control Act; the Federal Insecticide, Fungicide, and Rodenticide Act; Radiation Authorities; the Drinking Water Act; "Superfund" (CERCLA); and the Resource Conservation and Recovery Act (RCRA). All compelled the Agency to be protective of public health. Implementing this Congressional directive was left to the Agency and, for our part, this meant meeting strict deadlines and establishing scientific foundations that defined protection and that could survive challenges from Congress and the scientific, private, public, and legal communities.
At a very young age, many of us at U.S. EPA inherited a great deal of responsibility. New areas of complexity seemed to develop on a daily basis. Looking back, a culture of committed, young professionals worked hard and achieved a great deal. We were inspired by the excitement and challenge of those times. Many of us have remained friends and colleagues until the present day. Some of us are still involved, as board members of the U.S. EPA Alumni Association.
What were some of the accomplishments of which you were most proud that came out of your work for U.S. EPA?
I am proud of many things, but I am most proud of my role in co-authoring the first guidelines to establish risk assessment and risk management as the basis for setting public policy to protect public health and having the opportunity to found and direct U.S. EPA's first health assessment offices, the Carcinogen Assessment Group, and the expanded Office of Health Environmental Assessment. In addition, I had the opportunity to found and direct the Agency's expansion of health topics to include reproductive risk assessment, mutagen risk assessment, and exposure assessment groups; these offices conducted all risk assessments for the Agency's program offices for many years.
I was fortunate to be a part of establishing the scholarship in this rapidly developing and complex field of health risk assessment. A small number of us founded the Society for Risk Analysis, a focal point for sharing scientific developments from all sectors, including engineering and the social sciences. I served as one of the early Presidents and, for 10 years, was Editor-in-Chief of the Society's flagship journal, Risk Analysis: An International Journal. In addition, as U.S. EPA's representative, I had the privilege of participating in the worldwide application of risk assessment first in Europe through the World Health Organization and subsequently through the Pan American Health Organization and other organizations.
After you left U.S. EPA, you have had several professional engagements. Can you summarize those for us?
After spending 14 years being a part of U.S. EPA's founding, I entered the private sector, initially as President and CEO of the first private health and environmental assessment consulting firm, Clement Associates. In addition to work for private clients, U.S. EPA contracted with me to oversee and direct the first risk assessments for all of its Superfund sites, as did the Agency for Toxic Substances and Disease Registry to direct and write the first Toxicity Profiles. Later, I founded my own company, Sciences International, and directed it for 13 years, during which we addressed a wide variety of interesting and challenging issues. Subsequently, Exponent asked me to serve as Vice President for Health Sciences, a post I served in for 10 years, then as Chief Science Officer. More recently, I am honored to accept the Exponent designation of Senior Fellow, a rare recognition by the Company. Presently, I continue my work in the field of health risk assessment. I know that the framework and process we created in the early years made it possible to identify gaps in knowledge and point to ways for improving the foundations for health risk assessment.
What are the emerging policy issues in the area of human health risk assessment?
Without a doubt, the need to sensibly apply the science we know to separate the important from the unimportant issues. Often, I feel that we lose sight of the fact that health risk assessment has achieved endorsement worldwide as the premier way to address the complexity of issues involved in defining public health protection. Also, the outcomes of risk assessment now have challenging new applications, e.g., in toxic tort litigation or world trade decisions.
In the policy area, one important emerging issue is the use of health risk assessment to "prove safety." Adopting ever-diminishing levels of possible protection to achieve this goal effectively creates a "zero tolerance" policy, the very policy that would have defeated U.S. EPA at its inception. I believe that little is gained by these controversial policies that create debate for years; under these approaches we can lose sight of what is important. For example, important EPA risk assessment documents may now take years to become final because of endless debates in areas of scientific uncertainty where societal impacts can be enormous but risk reduction uncertain and marginal. We accept risk in every other part of our society, so it is unrealistic to apply a zero-risk policy to our environmental decisions.
Secondly, I feel that it is most unfortunate that the sciences so essential to public health understanding are often caught in agendas that constrain even the most objective review and use of our public health documents. There is no question that science has become politicized. I contend that U.S. EPA would have been lost without access to all scientists of importance to our decisions, regardless of who had funded their work.
Finally, I see an increasing lack of understanding of the difference between science as applied to public health protection—to preempt and prevent disease—and the science of establishing causality. It is critical to use honest science, regardless of the setting, to avoid mistakes. Distortion of scientific foundations and fact to achieve economic or political gain is deplorable and should be rejected.
What do you enjoy most about your work in the field of human health risk assessment?
The endless challenges. Risk assessment demands that we honestly express what is known and unknown. Exploring the unknowns and narrowing our knowledge gaps are endlessly rewarding endeavors.
What do you find to be the most challenging aspect of your work?
It is very difficult to find a single answer to this question. Exploring new science will always be at the top of the list. The greatest non-scientific challenge is the fact that not all are in engaged in finding the truth. Trying to explain the known scientific facts in situations involving exploitation of scientific unknowns or distortion, whether in the courtroom or as a part of political debate, is challenging. The climate created by the spirit of the '60s was to seek the truth. We were all essentially on the same page; we shared common goals even as we debated the best methods of scientific approach. Today, goals often do not converge; science in the age of polarization is challenging.
What or who helped you succeed as a leader in the area of human health risk assessment?
I have been surrounded by thought leaders and gifted people throughout my career. The environmental movement attracted so many to the new U.S. EPA. One who contributed so much to my understanding was Dr. Roy Albert, the Deputy Director of the School of Environmental Medicine at NYU. He was blessed with an extraordinary intellect and excellent sense of balance. He was the outside Chair of our Carcinogen Assessment Group in the early years, a role that would not be possible in the bureaucracy today. And I must continue to give credit to U.S. EPA Administrator Ruckelshaus.
What advice would you give a young person today who is considering starting out in your field?
Follow your dreams. Work is never work if you feel passionate about what you are doing. Achieve the best education you can get and keep your options open. You may need to help create your own opportunity. Have confidence in your capabilities to achieve your goals and set high ones.
Dr. Anderson was interviewed by Gabrielle Sigel, Co-Chair, Environmental and Workplace Health and Safety Law Practice, Jenner & Block
CATEGORIES: Air, Cercla, Consumer Law and Environment, RCRA, Toxic Tort, Water
PEOPLE: Gabrielle Sigel
April 11, 2019 Jenner & Block's Insurance Coverage for Environmental Claims Webinar
On Tuesday, April 16th, from 12:00 - 1:00 pm CST, Jenner & Block is hosting an interactive webinar that will discuss how environmental claims can arise in many different contexts and how high costs can be avoided. One way to manage the cost of environmental claims associated with historical operations is to pursue coverage under historical (and often pre-pollution exclusion) occurrence-based commercial general liability insurance policies. Our panelists will discuss the nuances and pitfalls that can arise in environmental insurance litigation and creative strategies to maximize recovery. In addition, companies facing environmental risks in their current operations or transactions can also manage environmental risk through a variety of current insurance products. Our panelists will identify current options available to manage environmental risks going forward and provide insight into the costs and benefits of those insurance products.
Jenner & Block Partners Allison Torrence and Brian Scarbrough will be panelists, along with Richard Reich, Managing Director at Aon Risk Services Central, Inc. Jenner & Block Associate Alex Bandza will moderate the webinar.
Please click here to RSVP for this webinar.
CATEGORIES: Climate Change, Consumer Law and Environment, Real Estate and Environment, Sustainability, Toxic Tort
PEOPLE: Steven R. Englund, Allison A. Torrence, Steven M. Siros
April 3, 2019 New Jersey Puts PFAS Manufacturers in the Cross-Hairs
New Jersey continues to take an aggressive stance with respect to per- and polyfluoralkyl (PFAS) contamination. On March 25, 2019, the New Jersey Department of Environmental Protection (NJDEP) issued a "Statewide PFAS Directive Information Request and Notice to Insurers" to five major chemical companies notifying those companies that NJDEP believed them to be responsible for PFAS impacts to the air and waters of New Jersey. In addition to seeking recovery from these companies for past costs incurred by NJDEP to investigate and remediate PFAS impacts, the Directive also seeks to compel these companies to assume responsibility for ongoing remediation of drinking water systems throughout the state. The Directive further seeks information from these companies regarding historical PFAS manufacturing practices as well as information regarding these companies' ongoing efforts to manufacture PFAS replacement chemicals.
Although environmental organizations have been quick to praise the NJDEP Directive, in reality, the state agency may have overstepped its authority. NJDEP has been quick to point out that the Directive is not a final agency action, formal enforcement order, or other final legal determination and therefore cannot be appealed or contested. Notwithstanding NJDEP's efforts to insulate its Directive from immediate legal challenge, it will almost certainly draw strong industry challenges. For example, NJDEP's efforts to obtain information regarding PFAS replacement chemicals may run afoul of the Toxic Substances Control Act and its efforts to compel reimbursement of past claims and/or the takeover of ongoing remedial actions will certainly be the subject of court challenges.
Continuing its full court PFAS press, on April 1, 2019, New Jersey unveiled a proposed drinking water standard of 14 parts per trillion (ppt) for PFOA and 13 ppt for PFOS. These proposed drinking water levels are significantly lower than the current U.S. EPA health advisory level of 70 ppt for combined PFOS/PFOA.
CATEGORIES: Air, Climate Change, Consumer Law and Environment, Sustainability, Toxic Tort, TSCA, Water
April 2, 2019 Trends in Climate Change Litigation: Part 1
The term "climate change litigation" has become a shorthand for a wide range of different legal proceedings associated with addressing the environmental impacts of climate change. Plaintiffs in climate change lawsuits may include individuals, non-governmental organizations, private companies, state or local level governments, and even company shareholders who, through various legal theories, allege that they have been harmed or will suffer future harm as a direct result of the world's changing climate. The targets of climate change litigation have included individual public and private companies, government bodies, and even entire industry groups. While there appears to be no shortage of plaintiffs, defendants, or legal theories emerging in climate change litigation, one clear trend is that the number of these lawsuits has grown dramatically in recent years. By one count, more than fifty climate change suits have been filed in the United States every year since 2009, with over one hundred suits being filed in both 2016 and 2017.
In light of the growing trend of climate change litigation, Jenner & Block's Corporate Environmental Lawyer blog is starting a periodic blog update which will discuss the emerging trends and key cases in this litigation arena. In each update, our blog will focus on a sub-set of climate change cases and discuss recent decisions on the topic. In Part 1 of this series, we will be discussing Citizen-Initiated Litigation Against National Governments.
Citizen-Initiated Litigation Against National Governments.
Perhaps the most high-profile and well-publicized cases in the climate change litigation arena have been lawsuits brought by private citizens against their own national government. A common objective of these cases is to push governments to implement policies aimed at reducing greenhouse gas ("GHG") emissions through legal hooks such as international agreements, international treaties, or constitutional provisions. While the early focal point for these cases has been European countries, citizen-initiated litigation continues to spread across the globe, including the United States.
Several examples of this emerging type of litigation have included:
Urgenda Foundation v. The State of the Netherlands (2015): In the first internationally recognized climate change lawsuit asserted against a national government, a Dutch environmental group, the Urgenda Foundation, represented over 900 citizens in a lawsuit alleging that the Dutch government had failed to address the risks of climate change. Ruling in support of the citizen group, the Hague court determined that the Dutch government was required to protect the living environment from the dangers of climate change by reducing CO2 emissions a minimum of 25%—relative to 1990 levels—by the year 2020. This decision was later upheld by the Dutch court of appeals which recognized the plaintiffs' claims under the European Convention on Human Rights, an international convention to protect human rights in Europe.
Friends of the Irish Environment v. Ireland (2018): Following the success of the Urgenda litigation, an Irish advocacy group, Friends of the Irish Environment (FIE), filed suit in the Irish High Court in an attempt to compel the government to increase its GHG emissions reduction goals. Following the path laid out in Urgenda, the FIE plaintiffs asserted their claims under the theory that the Irish government was not fulfilling its objectives under the Paris Climate Agreement. This case was argued before the High Court on January 22, 2019, and is currently awaiting a decision.
Juliana v. United States, 217 F. Supp. 3d 1224 (2016): Launched by the U.S. advocacy group, Our Children's Trust, Juliana is a lawsuit filed by 21 young people (ages eight to nineteen) who assert that the United States is denying its youngest citizens their constitutional right to a safe and livable climate. Unlike the cases brought in Ireland or the Netherlands, the plaintiffs in Juliana have not taken the position that the United States is bound to reduce GHG emissions through any form of internal law or agreement. Instead, the plaintiffs' complaint asserts the legal theory that the United States Constitution provides its citizens a substantive due process right "to a climate system capable of sustaining human life." In conjunction with this argument, the plaintiffs have asserted a unique application of the centuries-old "Public Trust Doctrine," arguing that the climate itself is a natural resource that must be held in trust for the people. Juliana has gone through a complex legal history, including multiple attempts at dismissal from both the Obama and now Trump administrations. Currently, the case is being briefed in front of the 9th Circuit on interlocutory appeal.
CATEGORIES: Air, Cercla, Climate Change, Consumer Law and Environment, FIFRA, Greenhouse Gas, Hazmat, OSHA, RCRA, Real Estate and Environment, Sustainability, Toxic Tort, TSCA, Water
December 17, 2018 New OSHA Enforcement Policy Under General Duty Clause for Worksite Exposure to Air Contaminants
By Gabrielle Sigel
OSHA's Directorate of Enforcement Programs recently issued an enforcement memorandum to all OSHA Regional Administrators providing a new "Enforcement Policy for Respiratory Hazards Not Covered by OSHA Permissible Exposure Limits" ("Enforcement Policy"). OSHA's 2003 policy on the same topic is now superseded and archived.
The Enforcement Policy explains how and when OSHA will cite an employer for respiratory hazards from an air contaminant under the OSH Act's General Duty Clause ("GDC"). The GDC is the statutory requirement that an employer "furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm." 29 U.S.C. § 654(a)(1). By regulation, OSHA has stated that "An employer who is in compliance with any standard in this part shall be deemed to be in compliance with the requirement of section 5(a)(1) of the Act, but only to the extent of the condition, practice, means, method, operation, or process covered by the standard." 29 CFR 1910.5(f). There is an open question as to whether and when an employer is in violation of the law if either (a) OSHA has not set a regulatory exposure limit for a particular chemical; or (b) exposures are below OSHA's regulatory Permissible Exposure Limit ("PEL"), but above another organization's recommended occupational exposure limit ("OEL") for the same chemical. An OEL can be issued by, for example, an industry group, U.S. EPA, the National Institute for Occupational Safety and Health, or the American Conference of Governmental Industrial Hygienists.
OSHA's new Enforcement Policy states that a GDC violation for airborne chemical exposures cannot be alleged unless OSHA can meet the 4-element standard of proof imposed by the courts for any GDC violation:
The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed;
The hazard was recognized;
The hazard was causing or was likely to cause death or serious physical harm; and,
There was a feasible and useful method to correct the hazard.
The Enforcement Policy provides that exceeding an OEL is not sufficient evidence on its own to support a GDC citation; all four of the above GDC proof elements must be met. However, even if all four elements cannot be proven, OSHA still can issue a Hazard Alert Letter ("HAL") if exposures are above an OEL. The Enforcement Policy includes a sample HAL.
The Enforcement Policy also provides examples of the evidence that OSHA needs to prove a GDC violation for airborne exposures above an OEL. With respect to the first element—that employees were exposed—OSHA can rely on air sampling and other workplace-based evidence, including witness statements. However, in contrast to many OSHA requirements when there is a regulatory PEL, in GDC cases, OSHA will consider whether the exposed employee is wearing respiratory protection. Unlike the 2003 version of the policy, the 2018 Enforcement Policy specifically states that "if the exposed employees were wearing appropriate respiratory protection with no deficiencies in the respirator program, then the likelihood that OSHA could establish a respiratory hazard covered by the general duty clause would be low." However, OSHA does not preclude a GDC citation if respirators are used; the Enforcement Policy provides the exception for a respirator program only if that program has "no deficiencies."
With respect to element #2—hazard recognition—the Enforcement Policy states that this element is met if: (a) there is direct evidence of employer knowledge; or (b) if the employer should have known of the hazard. Direct evidence can include prior receipt of a HAL or information regarding the hazard in a Safety Data Sheet prepared by a chemical's manufacturer. Indirect evidence can include an OEL issued by an industry association, professional organization, or a non-OSHA government agency. With respect to GDC proof elements #3 and #4, OSHA states it likely will be required to present expert testimony to prove its case. However, that expert can rely on published studies and need not necessarily conduct a new study of the dangers of the hazard at that particular worksite.
The Enforcement Policy does not expressly address whether OSHA will pursue GDC violations for chemicals for which OSHA has issued a PEL. As written, the new Policy does not prohibit a GDC citation in those circumstances. The Enforcement Policy states that it applies when an air contaminant "is not covered" by an OSHA PEL, and does not include language restricting the policy to "those cases where an OSHA PEL has not been issued," as the old version of the policy had stated. (Emphases added.) In addition, the new Policy refers Regional Administrators to the Field Operations Manual ("FOM") for further guidance in preparing a GDC citation. The current FOM expressly states that a GDC citation may be issued when there are exposures above an OEL but below an OSHA PEL. FOM (8/02/2016) § III.D.2, Example 4‑25.
Therefore, under the Enforcement Policy, OSHA may assert that even employers with worksite air contaminant exposures below an OSHA PEL, as well as those using chemicals that do not have an issued OSHA PEL, are subject to a GDC citation, if there are unprotected worksite exposures above a recognized OEL.
CATEGORIES: Air, OSHA, Toxic Tort


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Extinct plant species discovered in amber
image copyrightGeorge Poinar
image captionThe flowers were remarkably well-preserved
Biologists have described a new species of extinct plant, based on two fossil flowers that were trapped in chunks of amber for at least 15 million years.
Strychnos electri belongs to the genus whose tropical shrubs, trees and vines are famous for producing the deadly toxin strychnine.
The US researchers named it after the Greek word for amber ("elektron") - the fossilised resin of long-dead trees.
Their discovery appears in the journal Nature Plants.
The two flowers were among 500 fossils collected on a 1986 field trip by Professor George Poinar of Oregon State University.
Prof Poinar is a renowned entomologist and most of these specimens were insects. But after nearly 30 years working on the bugs, his eye settled on the flowers.
They were remarkably complete - unlike most plant fossils found in amber, which are usually just fragments.
In 2015, he sent high-resolution photos to Professor Lena Struwe at Rutgers University.
Probably poisonous
"These flowers looked like they had just fallen from a tree," said Prof Poinar. "I thought they might be Strychnos, and I sent them to Lena because I knew she was an expert in that genus."
Prof Struwe set about comparing the physical structure of the flowers to all 200 known Strychnos species, combing the collections of multiple museums and herbaria.
image captionNearly all plants in the Strychnos genus are toxic to some degree
"The characters mostly used to identify species of Strychnos are flower morphology, and that's what we luckily have for this fossil," said Prof Struwe.
"I looked at each specimen of New World species, photographed and measured it, and compared it to the photo George sent me. I asked myself, 'How do the hairs on the petals look?' 'Where are the hairs situated?' and so on."
Based on the age of the amber, which is difficult to ascertain with certainty, the team estimates the specimens could be anywhere from 15 to 45 million years old.
For the animals of the time, S. electri was probably not very good eating.
"Species of the genus Strychnos are almost all toxic in some way," said Prof Poinar.
"Each plant has its own alkaloids with varying effects. Some are more toxic than others, and it may be that they were successful because their poisons offered some defence against herbivores."
The most famous such alkaloid, strychnine, is a toxin that once formed the basis of many rat poisons - as well as being one of Norman Bates's murder weapons in the Alfred Hitchcock movie Psycho.
But these plants also fall within the "asterid" family, which includes more than 80,000 flowering plants including many of the ones humans eat, from potatoes and mint to sunflowers and coffee beans.
The new discovery is a crucial addition to the fossil record of this family, which is very poorly understood.
Ancient underwater plant 'could be world's first flower'
Oldest evidence of sex in flowering plants
Ancient plants back to life after 30,000 frozen years
Secrets of Antarctica's fossilised forests
Rare fossilised flower found, related to sunflowers

redpajama_set_name: RedPajamaCommonCrawl


Improving office productivity is a must for any business. No matter the kind of work your company does, a boost in productivity goes a long way in increasing the financial bottom line. Microsoft SharePoint assists with this.
What Programs Do Graphic Designers Use?
The best graphic designers can pull from a host of different program tools in order to create the perfect, original work of art for their client. Whether creating a logo, working on an ad campaign or producing content for the opening of commercial, graphic designers need both knowledge and skill in an assortment of programs. If you're interested in becoming a graphic designer, here are just some of the most common programs you need to become fluent in.


Our Wealth Coaching process, The Advanced Wealth Optimization System™, is our unique approach designed to help individuals and families make wise choices regarding their wealth.
Your choices revolve around what we call The Planning Horizon, which marks the line between issues above the horizon and issues below the horizon. Issues above the horizon are focused on your individual Mission, Vision, Values, and Goals. Issues below the horizon are focused on the Strategies, Tactics, and Tools necessary to implement your plan. We differentiate our firm from others in that we have tremendous capacity for working "Above the Horizon Line" to enable you to make wise choices regarding your wealth and your life.
We begin our Wealth Coaching process by first listening. We spend time discussing philosophy, lifestyle and your goals for the future. We analyze the situation and quantify spending, saving and income goals. In addition, we collect information in order to understand risk tolerance and risk capacity. Once we understand your mission, vision, values and goals, we prepare a financial plan that determines the required rate of return in the investments we need to meet your objectives.
Through Wealth Coaching, we work with you to establish your financial objectives as well as your lifestyle, family, charitable giving and legacy objectives. Wealth Coaching is much more than just the assets and investments. It is about finding the possibilities, having the regular guidance, and creating accountability for getting things done.


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Appeal expected
Islesboro's request for delay in ferry rate increase denied
By Stephanie Grinnell | May 17, 2018
Source: maine.gov The Lincolnville ferry terminal, where the Islesboro ferry departs the mainland.
In a letter released May 17, Maine Department of Transportation Chief Counsel Jim Billings denied a request on behalf of Islesboro to delay implementation of a ferry rate increase.
The higher rates became effective May 21.
The new tariff structure approved by Maine DOT, which oversees the ferry service on Penobscot Bay, is a flat rate for all islands served. On Islesboro, according to residents and officials, the new rates represent a 118-percent increase for a vehicle and driver to travel between the island and the mainland.
The ferry service also operates between the mainland and Vinalhaven, North Haven, Swans Island, Frenchboro and Matinicus. According to a comparison of the old and new rates, the new rates are significantly decreased for Matinicus, even considering a new $15 reservation fee — Matinicus was the only island without a reservation charge under the previous rate structure. Islesboro rates in every category increased.
Since the new rates were released in mid-April, Islesboro residents have been vocal in their opposition to the fees, which they argue are not equitable and were approved without public input.
Attorney Mary Costigan with Bernstein Shur, on behalf of Islesboro, on May 11 requested Maine DOT hold off on the new rates.
"As explained below, the town and its residents will suffer irreparable injury if the proposed tariff goes into effect on May 21, 2018, as planned ... " she wrote.
Costigan's letter goes on to argue Maine DOT violated the Administrative Procedure Act because it failed "to request comments from the public concerning the changes from the proposed rule if a rule that the agency intends to adopt is substantially different from the proposed rule.
" ... The rate structure that was adopted by the Department does not at all resemble the proposed structure. Rather, it is a flat rate structure that was not provided to the public for comment prior to adoption as required by the APA," Costigan wrote.
Initially, Maine DOT proposed charging different rates based on residency, which drew objections from several island communities. Based on the negative public reaction, Maine DOT came out with new flat-rate fees in mid-April, reportedly taking islanders by surprise.
Jan Davidson said her husband has commuted to work on Islesboro for 15 years. She said they hope to move to the island when she retires but said "the most paranoid pessimist would not have included in their retirement planning a 120-percent fare increase, levied without warning, on a commuter island." Davidson said affordable access to the mainland is important to complete "all the chores of a normal life."
Costigan also cautioned of negative impacts on Islesboro with the higher rates.
"This rate structure will have a debilitating impact on the island community that will force many residents to move off the island, could cause the schools to close and could ultimately cause Islesboro to cease being a year-round community," Costigan said.
In a letter responding to Costigan, Maine DOT's Billings said the primary reason for denying the stay is that "there's not been a showing of irreparable harm where rates for service are the issue. This is a classic case for money damages rather than injunctive relief; if you are successful on appeal anyone who has overpaid for a ticket could be refunded any difference in fare."
He continued by stating that the new rates should be implemented in a timely manner, adding, "Any stay or change in the rates at this point affects every other type of rate, the other islands, the citizens of Maine, and other users of the overall ferry system."
Billings said the process was followed with appropriate public input and consideration by DOT.
"That decision is final agency action. It would be completely inappropriate to now engage in closed door meetings with interested parties, while representatives from other islands are excluded, in order to come up with a new rate that Islesboro deems a 'fair and equitable solution.'"
In a previous interview, Islesboro Selectman Gabe Pendleton said selectmen are considering alternatives.
"Every option is on the table," he said in a phone interview May 4. "[Selectmen] are certainly having broad conversations. We're trying to make a good decision for the town."
Pendleton said a legal challenge to the new rate structure is likely, a sentiment echoed in the letter sent to Maine DOT requesting the stay.
On May 21, the date the rates became effective, an email distributed by Islesboro's Town Office stated an appeal would be filed that day. The email urged residents to keep receipts so they could be reimbursed the difference if the appeal is won.
"Please save the receipts from any ticket purchased at the new unreasonable price as we will be asking the court to force the state to refund the difference between the new and old rate if we are successful," the email reads.
Posted by: Maggy Willcox | May 26, 2018 18:39
Thank you, Stephanie. Another thorough, well done article.
Stephanie Grinnell
Stephanie is editor of The Republican Journal in Belfast. She previously served as editor of Camden Herald following its return in April 2012.
Stephanie also was editor of VillageSoup's Capital Weekly in Augusta and has nearly a decade of experience in the newspaper business ranging from southern and central Maine to Waldo County.
Outside the office, she enjoys reading, cooking and gardening.
Stephanie lives in Washington with her husband Jeff, four children, a dog named Chewbacca, a rabbit and chickens.
Recent Stories by Stephanie Grinnell
Schools must change practices under new 'food-shaming' law
Belfast manager sets record straight on tents for homeless
Planning Board hears first Nordic presentation
Thorndike town news
BEP accepts jurisdiction over Nordic state applications


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Newsom issues new lockdown
Last week Gov. Gavin Newsom issued another lockdown in the state, citing the numbers of hospital beds being utilized are increasing in numbers too large for facilities to keep up.
Newsom said that by the end of December, hospitals will be filled with those who have tested positive at the beginning of the month.
"We are implementing a stay-at-home order for three weeks," Newsom said. "Regions where the ICU capacity is falling below 15%."
Newsome stated that once again churches, hair salons, nail salons, tattoo parlors and massage facilities should be shut down.
"In addition, all gatherings with people outside your household would also be included in those restrictions along with indoor and outdoor playgrounds," Director of Kern County Public Health Matt Constantine said.
However, the governor is recommending that everyone continue with some type of outdoor activity to maintain health.
Constantine also said that outdoor dining would be included in the lockdown and retail stores would be reduced from 25 to 20% capacity.
Superintendent of the Wasco Union Elementary School District Kelly Richers sent a letter to all teachers and parents that the district will continue with distance learning for general education for the third quarter.
Richers also said that on-site instruction will continue for certain at-risk students such as special education, homeless and English learning students.
If possible after the third quarter ends, the district will return to in-person instruction depending on the Kern County Public Health Department and the state's recommendation.
Richers informed everyone that the district will not switch from distance learning to in-person learning during a quarter. It may be possible only at the end of the quarter.
Ex-enforcement officer charged
Santa returns to Wasco with parade, tree lighting
Hanner remembered as more than a pilot
Shafter woman found guilty of murder
Chamber award recipients announced


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VOLLEYBALL FALLS IN THREE TO UTAH VALLEY
Utah Valley (3-4) 25 25 25 3
Sacramento State (4-4) 13 14 22 0
K: FRITZLER, Katie - 10
B: 4 Players (#3, #11, #13, #16) - 3
D: NORRIS, Kalani - 9
SA: FRITZLER, Katie - 3
K: Janelle Currey - 8
B: 2 Players (#3, #7) - 2
SA: Ashley Newcomb - 1
FRESNO, Calif. -- Sacramento State was limited to a season-low .079 hitting percentage as Utah Valley swept past the Hornets, 25-13, 25-14, 25-22, in the second round of the Fresno State Volleyball Classic Saturday morning at the Save Mart Center.
In a match that began at 10 a.m., Sacramento State was playing less than 12 hours after last night's dramatic 3-2 victory over Fresno State. Perhaps that led to the Hornets' sluggish play as the team posted season lows in hitting percentage, kills (29), assists (28), aces (1), digs (31) and team blocks (4.0).
With the loss, the Hornets (4-4 overall) dropped to 1-1 at the two-day tournament, and will wrap up tourney play this evening against UC Davis at 5 p.m. The rivalry match against the Aggies is always one of the biggest of the season, and will count towards the Causeway Cup, the annual all-sports competition between the two schools.
With the victory, Utah Valley, which lost in five sets to UC Davis last night, improved to 3-4 with the victory.
After the Wolverines won the first and second sets handily, Sacramento State took a 21-19 lead in the third frame after a kill from middle blocker Ashley Newcomb. However, Utah Valley would finish the set on a 6-1 run and complete the victory.
For the first time all season, no Sacramento State player finished with double figures in kills, as outside hitter Janelle Currey posted a team-high eight. Outside hitter Jessie Genger was limited to a season-low five kills, and both Newcomb and rightside hitter Kayla Beal had four kills. Libero Sydney Kordic had 13 digs.
For Utah Valley, Katie Fritzler led all players with 10 kills while also posting a .444 hitting percentage (10-2-18), and Brookelyn Hall had four kills and a .667 hitting percentage.


BUZZARDS BAY, Mass – Friday night, the Buccaneer women's lacrosse team opened their 2019 campaign at home against UMass-Dartmouth at Clean Harbors Stadium. Though the Buccaneers took a 1-0 lead four minutes in to the game when 2018 MASCAC Rookie of the Year, Casey Sullivan (Sagamore Beach, Mass) scored her first of the season, the game finished in favor of the Corsairs, 12-4.
The Buccaneers were led by sophomore attacker Casey Sullivan who scored three goals on three shots on goal. Senior captain, Erica Overstreet (Bridgewater, Mass) scored the only other goal for the Bucs and added an assist on one Sullivan goal. As a whole, the team took 28 total shots, 14 on target. Freshman attacker, Alyssa Blumenthal (Braintree, Mass) collected a game and team high eight ground balls for Maritime. Attacker Anna Deely (Marstons Mills, Mass) led the team and was tied for game high with two caused turnovers and won a game high nine draw controls. Freshman goalie, Laura Kleber (Westport, Mass) made 10 saves on 22 shot in her collegiate debut.
The Corsairs received four goals, the game high, from attacker Sam Muir (Sturbridge, Mass). Muir took an astounding 13 total shots, nine of which were on target and also collected eight ground balls, tied for the game high. Dartmouth freshman attacker Hannah Niemi (Fairhaven, Mass) and senior attacker Brooke Scahill (Gales Ferry, Conn) each added three goals of their own. Scahill also assisted on three other goals while also winning seven draw controls. Head Coach, Olivia Coakley played two goalies, splitting the time between senior captain Kaitlyn Burchill (Bridgewater, Mass) and junior Bridget Harrington (Florence, Mass) who each played a half. Burchill made six saves on eight shots, Harrington only saw five shots and saved three.
The Bucs opened the scoring four minutes in to the game on Sullivan's first goal of the afternoon. Casey added another with 17 minutes left in the half which game the Bucs a 2-1 lead halfway through the first half. The goal that was scored by Dartmouth came between Sullivan's two scores when Scahill scored her first of the season. Muir scored her first 30 seconds after Sullivan's second to tie the game back up at two apiece. The Buccaneers did not find the back of the net the remainder of the first half but, the Corsairs would net three more, courtesy of Scahill, Muir and Brooke Martel (Haverhill, Mass). At the break, the Bucs trailed 5-2.
In the second half, the Buccaneers once against controlled the game for the first five minutes. Sullivan scored her third, Overstreet scored her first and the Bucs were back within one with a lot of time left on the clock. But, the Dartmouth defense stood strong and kept their hosts from scoring again but netted seven second half goals of their own, including Niemi's three scores. When all was said and done, the Corsairs sailed back to Dartmouth with a 12-4 season opening win.
Next up for the Buccaneers is the Maritime Classic, hosted by Massachusetts Maritime, Friday, March 8th through Sunday, March 10th. The Buccaneers will open the 2019 edition of the tournament with a Friday night faceoff with Maine Maritime Academy at 7pm.


text:
Competition regulator chews over £7.1bn acquisition of Morrisons
The UK's competition watchdog has formally opened an investigation into whether the acquisition of supermarket chain Morrisons by US private equity firm Clayton, Dubilier & Rice (CD&R) will reduce choice for supermarket customers in the country.
The Competition and Markets Authority (CMA) said it has launched a merger inquiry and is inviting comments from interested parties. It has set a deadline of March 24 for a preliminary decision.
CD&R, which has former Tesco boss Terry Leahy as a senior adviser, won an auction for Morrisons in October by bidding a penny a share more than a consortium led by Softbank-owned Fortress Investment Group. Its offer of 287p per share values Morrisons at £7.1 billion.
easyJet chief declares end in sight for air travel testing
The boss of easyJet has flagged the airline's view that testing for Covid across its network "should soon become a thing of the past" as it reported a jump in bookings following this week's move by the Scottish and UK Governments to removing travel restrictions for fully vaccinated people arriving in the country.
But the budget airline warned that Omicron would continue to have an impact on short-term performance in the second quarter.
Developer embraces Scottish renewable prospects
The regeneration and property development division of Hargreaves Services has underlined opportunities in Scotland for its renewable energy land assets after posting a rise in profits for the six months to the end of November.
Headquartered in County Durham, the group posted an increase of more than ninefold in pre-tax profits to £10.4m across its services business, land portfolio, and HRMS joint venture in Germany. This was despite an anticipated decline in revenues to £76.1m.
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the EARTH ABIDES project
A site for George R. Stewart: Author of the classic EARTH ABIDES
The Life And Truth of George R. Stewart: A Literary Biography of the Author of Earth Abides
The George R. Stewart Collection at the University of Nevada, Reno
The Stewart Papers at the Bancroft Library, UC Berkeley, I
The Stewart papers at the Bancroft Library – II
Michael Ward's George R. Stewart pages
Of FIRE and Flu
Posted on November 2, 2017 by rangerdon
George R. Stewart was always interested in how humans react to ecological events, because he saw those reactions as defining human character. Two of his best novels, FIRE and EARTH ABIDES, focus on such events – FIRE, on a great forest fire (and fire ecology); EARTH ABIDES,on a planet-wide disease epidemic which nearly ends the human species.
This last month California experienced fire, and some Californians had a lesson about disease. There were massive and destructive fires, and a literary discussion of an epidemic which references Stewart's EARTH ABIDES.
Build a home in the woods and, sooner or later, fire will come. Defensible space is a great help; but in suburbia's tiny lots, there can be none. The fires of 2017 burned through the house-stacked neighborhoods so quickly that – as in the recent Oakland Hills fire – many people died trying to flee. Entire neighborhoods were burned to cinders. And it was lesson about the fragility of stuff – one video shows a classic, restored '57 Chevy wagon, burned into eternity.
Anyone familiar with George R. Stewart's work has probably read FIRE. The novel of fire ecology, history, and fictionalized fire drama is one of his best – it, STORM, and EARTH ABIDES are probably his greatest ecological novels. STORM ends with a reference to California history. FIRE, with a beautiful passage about the role of fire in the ecosystem.
FIRE opens with a lightening strike in a mythical national forest set just to the north of the Tahoe National Forest. Stewart's forest is so well-developed – thanks to the help of his brilliant son, Jack, map-maker and geologist, and a colleague, a famous impressionist painter — that for years readers of the book would drive into that area, looking for the fictional National Forest. In the same way, his story is developed. It centers around people who seemed non-fictional – a young woman in a fire lookout, an old Ranger, and a young Forest Superintendent, and all those who fight the blaze – so the people read true, like the forest, and their drama brings us into the power of a California forest fire like the ones of this autumn of 2017. By choosing rangers as key characters, Stewart is able to integrate the human drama with ecological science. And, in his usual way, he also includes myth, broad science, place-naming, and history.
Walt Disney later filmed the novel for television, as "A Fire Called Jeremiah." It's somewhat Disneyfied, but follows the novels ecological and human themes closely. Today, it seems somewhat old-fashioned and crude; but it shared Stewart's dramatic presentation of fire ecology with millions of Disney TV viewers.
The TV film, like Disney's TV version of Stewart's STORM, is not available today. When I asked old family friend, Disney Legend Bob Broughton, about the chances of getting a copy, he said, "Don, the film is in The Vault. And if it's in The Vault, Walt himself can't get to it." Needing to view the films for my George R. Stewart biography, I went on a quest – and actually found a copy in a university library (which shall be nameless); the university kindly set up their old Bell and Howell 16mm projector, and, after decades, I again saw Stewart's work come to life. There's now a clip online, probably pirated, but you can watch it here. (Paramount also made a version of the film – changed so much it bears no resemblance to the book. Here's a clip, again probably pirated, so view at your own discretion.)
Fire appears in several George R. Stewart novels. In EAST OF THE GIANTS, a cleansing fire provides closure to the chapters of the novel set on a Mexican rancho. In FIRE, of course, a massive fire is the protagonist of the work. And in Stewart's EARTH ABIDES, a fire ends the story of Ish, and moves the story of The Tribe into some unknown, post-novel, new territory.
EARTH ABIDES's protagonist is a disease, a kind of super measles which wipes out most humans. In these days of AIDS, Ebola, and the other plagues, the story has as great an impact on readers as it did in the days it was published or in the intervening near-70 years.
Stewart himself was the victim of a plague – the Spanish Flu Epidemic of 1918. AIDS is a killer, with 38, 000,000 victims. But the flu killed many more – perhaps 100,000,000 worldwide. Stewart should have been safe – he was young, in excellent health, and isolated in World War I training camp where he was preparing to go overseas in the Ambulance Corps. But the flu, ironically, hit the young and healthy with more fatal force than it hit the elderly or those in poor shape. GRS got the flu. He recovered enough to hitchhike halfway home from the East Coast to Pasadena. But for the rest of his life, his lungs were always weak.
Much of EARTH ABIDES is set in the Berkeley hills and the UC Berkeley campus. So it is appropriate that Pat Joseph's fine recent article, "In Flew Enza," in the California Alumni Association magazine, CALIFORNIA, describes the effects of the 1918 flu on the UC campus. Murphy ends the article with a reference to Stewart's novel, setting it in the context of Stewart's experience with the flu. Since Murphy has kindly allowed this post to link to the article, I encourage you all to read it. Here's the link
As Murphy writes, Stewart always found hope, an optimism, even in the greatest of events called disasters by humans. Whether he wrote about the benefits of fire to the ecosystem, or indomitable will to persevere after disease had wiped out most humans, Stewart always gives us hope.
This entry was posted in American History, American literature, California Literature, California wildfires, Ecological novel, environmentalism., George R. Stewart, Lake Tahoe area, Literature, Novels into movies, plagues, Reviews of George R. Stewart's Work, Uncategorized, Walt Disney and tagged 1918 flu and UC Berkeley, 1918 flu epidemic, AIDS, California Magazine, Earth Abides, film, George R. Stewart Fire and Storm, history, literature, movies, science, University of California Berkeley, Walt Disney TV movies Fire and Storm by rangerdon. Bookmark the permalink.
2 thoughts on "Of FIRE and Flu"
Marilyn Armstrong on November 4, 2017 at 9:58 am said:
Reblogged this on SERENDIPITY and commented:
My reblog function gave up months ago … and now that they have eliminated "Press It" which actually (more or less) worked … well ..
Garry Armstrong on November 4, 2017 at 10:10 am said:
I recall (hazily) the Paramount film….last seen a few years ago.


Recent pivotal breast cancer data presented at the 2018 San Antonio Breast Cancer Symposium (SABCS), particularly with immunotherapy, are just the start of promising directions for researchers, said Howard A. "Skip" Burris, MD.
An updated biomarker analysis from the phase III IMpassion130 trial—data from which were initially presented at the 2018 ESMO Congress—showed that progression-free and overall survival (OS) improvements with the combination of atezolizumab (Tecentriq) and nab-paclitaxel (Abraxane) in patients with metastatic triple-negative breast cancer (TNBC) or inoperable locally advanced TNBC were exclusive to those patients with PD-L1 expression ≥1% on immune cells.
Other biomarkers, which included PD-L1 expression on tumor cells, intratumoral CD8-positive T cells, stromal tumor-infiltrating lymphocytes, and BRCA1/2 mutation status, also confirmed the importance of PD-L1 expression on immune cells in predicting clinical benefit derived from the atezolizumab combination.
Based on the initial IMpassion130 findings, the FDA granted a priority review designation to a supplemental biologics license application for the frontline atezolizumab combination for patients with unresectable locally advanced or metastatic PD-L1–positive TNBC. The initial data showed that there was a 38% reduction win the risk of progression or death with atezolizumab plus nab-paclitaxel versus nab-paclitaxel alone in this patient population. Under the Prescription Drug User Fee Act, the FDA is scheduled to decide on the application by March 12, 2019.
"The data are changing so quickly, it's difficult to keep up, and folks are certainly interested in seeing how the disease-specific experts are applying this information in their practices," said Burris.
Looking ahead, Burris said the breast cancer community should expect a focus on molecular profiling as well as upfront testing with PARP and CDK4/6 inhibitors.
In an interview during the 2019 OncLive® State of the Science Summit™ on Breast Cancer, Burris, chief medical officer of Sarah Cannon Research Institute, and president-elect of ASCO, highlighted some of the exciting updates from the 2018 SABCS and what can be expected in the breast cancer field in the year ahead.
OncLive: Reflecting on the recent breast cancer advances, how are these pivotal data informing treatment decisions?
Burris: The data coming out of SABCS and the conversations [at the State of the Science Summit™] were different than prior years, because we have exciting affirmation in all the various subtypes, as well as the various stages of breast cancer. We have promising and almost practice-changing data in HER2-positive breast cancer, TNBC, and in the realm of the estrogen receptor (ER)–positive breast cancer. It was fascinating to see, in one of the presentations at SABCS this year, a wonderful case-based discussion where Dr Cliff Hudis of ASCO moderated and Dr Hal Burstein of Dana-Farber Cancer Institute and Dr Dan Hayes of University of Michigan—all breast cancer experts—debated the strategy.
I thought what was interesting was how crowded the room was and how thirsty the audience was for how people were going to apply the new knowledge going forward. [It covered] what to do with molecular profiling, how to do the prognostic assays, and where they might incorporate the treatment.
What practice-changing data in HER2/TNBC did you find were most exciting?
In the HER2-positive breast cancer treatment paradigm, we have, for many years, really liked T-DM1. The antibody-drug conjugate has been well tolerated, active, and a lot of the data in the adjuvant and neoadjuvant settings have been accruing. It's been hard to sort out when that might emerge.
With the 2018 SABCS, the KATHERINE data, and seeing T-DM1 so positive over trastuzumab (Herceptin) in the [adjuvant] population was a great win. It makes sense to give additional chemotherapy in that setting, and it makes sense to continue trastuzumab-based therapy. That is the idea behind T-DM1: this "smart bomb," better-tolerated approach of having chemotherapy linked to an active monoclonal antibody, so that is absolutely going to be something that will be quickly adopted, incorporated, and yield even greater outcomes.
On the TNBC front, we had some wins with positive trials with PARP inhibitors in the metastatic setting. We had some wins with positive trials with antibody-drug conjugates. There are a few new ones coming along and, if the immunotherapy store was going to make sense in breast cancer, most people thought it would be in TNBC. The IMpassion130 data, with atezolizumab in combination with nab-paclitaxel were presented—[the findings were originally shown] at the 2018 ESMO Congress, there are a lot of data there.


text:
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text:
Q: Player glitches through left side of horizontal moving block EDIT: I rewrote a minimal reproducible example in p5.js, so you can see what's happening here:

let keyInput = []
let player
let block

function setup() {
  createCanvas(600, 600)

  player = new Player(0, height/2)
  block = new Block(200, height-100, 100, 1000)
}

function draw() {
  background(220);

  player.draw()
  block.draw()

  player.moveX()
  block.checkCollisionsX()
  player.moveY()
  block.checkCollisionsY()
}

function keyPressed() {
  keyInput[keyCode] = true;
}

function keyReleased() {
  keyInput[keyCode] = false;
}

function rectCollide(x1, y1, w1, h1, x2, y2, w2, h2) {
    return x1 + w1 > x2 && x1 < x2 + w2 && y1 + h1 > y2 && y1 < y2 + h2;
}

//BLOCK CONSTRUCTOR
class Block {
  constructor(x, y, w, h) {
    this.x = x;
    this.y = y;
    this.w = w;
    this.h = h;

    this.movingSpeed = 3;
    this.start = 200
    this.stop = 400
  }
  draw() {
    fill(255)
    rect(this.x, this.y, this.w, this.h)
    this.x += this.movingSpeed;
    if (this.x > this.stop) {
        this.movingSpeed = -this.movingSpeed;
    }
    if (this.x < this.start) {
        this.movingSpeed = abs(this.movingSpeed);
    }
  }
  checkCollisionsX() {
    if (rectCollide(player.pos.x, player.pos.y, player.width, player.height, this.x, this.y, this.w, this.h)) {
        if (player.vel.x < 0) { // If the player moved left and collided with the right side of block
            player.pos.x = this.x + this.w;
        } else { // If the player moved right and collided with the left side of block
            player.pos.x = this.x - player.width;
        }
        player.vel.x = 0;
    }
  }
  checkCollisionsY() {
    if (rectCollide(player.pos.x, player.pos.y, player.width, player.height, this.x, this.y, this.w, this.h)) {
        if (player.vel.y < 0) {
            player.pos.y = this.y + this.h;
            player.vel.y *= -yRebound; // Not -1 because collisions are not perfectly elastic
        } else {
            //player.pos.x += movingSpeed; //Keep player on platform while platform is moving
            player.jumps = player.numJumps;
            player.pos.y = this.y - player.height;
            player.vel.y = 0;
            player.acc.y = 0;
        }
    }
  }
}

//PLAYER CONSTRUCTOR
class Player {
  constructor(x, y) {
    this.width = 50
    this.height = 100

    // all 3 chars for pretty code
    this.pos = new p5.Vector(x, y);
    this.vel = new p5.Vector(0, 0);
    this.acc = new p5.Vector(0, 0);

    this.accSpeed = 0.05;
    this.gravity = 0.5;
    this.maxVel = 10;
    this.jumpForce = 15;
    this.friction = 0.15;
    this.numJumps = 1;
    this.jumps = this.numJumps;

    this.isGrounded = false;
    this.canMove = true;

    this.dir = "DOWN"
  }
  draw() {
    fill(255, 0, 0)
    rect(this.pos.x, this.pos.y, this.width, this.height)
  }
  moveX() {
    //MOVE X
    if (keyInput[LEFT_ARROW] && this.vel.x > -this.maxVel && this.canMove) {
        this.acc.x = -this.accSpeed;
    } else if (keyInput[RIGHT_ARROW] && this.vel.x < this.maxVel && this.canMove) {
        this.acc.x = this.accSpeed;
    } else if (abs(this.vel.x) > 0.2) {
        this.acc.x = (this.vel.x < 0) ? this.friction : -this.friction;
    } else {
        this.vel.x = 0;
        this.acc.x = 0;
    }
    this.vel.x += this.acc.x; // vel += acc
    this.pos.x += this.vel.x; // pos += vel
  }
  moveY() {
    //MOVE Y
    if (keyInput[UP_ARROW] && this.jumps > 0 && this.canMove) {
      this.jumps--;
      this.vel.y = -this.jumpForce;
    }
    this.acc.y += this.gravity;
    this.vel.y += this.acc.y;
    this.pos.y += this.vel.y;
    this.acc.y = 0; // Reset acceleration

    if (this.pos.y >= height - this.height) {
      this.pos.y = height-this.height
      this.jumps = this.numJumps;
    }
  }
}
<!DOCTYPE html>
<html lang="en">
  <head>
    <script src="https://cdnjs.cloudflare.com/ajax/libs/p5.js/1.4.1/p5.js"></script>
    <script src="https://cdnjs.cloudflare.com/ajax/libs/p5.js/1.4.1/addons/p5.sound.min.js"></script>
    <link rel="stylesheet" type="text/css" href="style.css">
    <meta charset="utf-8" />

  </head>
  <body>
    <main>
    </main>
  </body>
</html>

I'm making a 2D platformer game, and all block collisions work correctly except for the left side of a horizontally moving block. Here's what the block looks like (ignore the lag):

Here's the code that makes up the moving block:
        if (type.equals("moving-horizontal-2x1")) {
            image(img2x1, pos.x, pos.y, 200, 100);
            pos.x += movingSpeed;
            if (pos.x > stop) {
                movingSpeed = -movingSpeed;
            }
            if (pos.x < start) {
                movingSpeed = abs(movingSpeed);
            }
        }

When the player collides with the block, it works for all sides except the left side on the X axis, as shown by the image below.

This video shows what happens when the player collides with the moving block: https://www.youtube.com/watch?v=ewVSYd5h4rg
As you can see, the player gets moved to the other side of the block. I don't know why this is happening, since the collision detection/resolution code is the same as the other static blocks. Why does only one side work?
Here is my collision detection code for the X axis:
            if (rectCollide(player.pos.x, player.pos.y, player.width, player.height, pos.x, pos.y, width, height)) {
                if (player.vel.x < 0) { // If the player moved left and collided with the right side of block
                    player.pos.x = pos.x + width;
                } else { // If the player moved right and collided with the left side of block (this is the broken side)
                    player.pos.x = pos.x - player.width;
                }
                player.vel.x = 0;
            }

I've tried fixing this issue by incrementing the player's x pos when it collides with the left side, by doing something like player.pos.x += movingSpeed, but this still doesn't work.
I believe the bug has something to do with how I draw the moving block, since the collision detection/resolution code works perfectly fine with all other static blocks.
Thanks for any help!

A: The problem occurs when you are slowly moving away from the block, but the block is faster than you. The player's direction of movement therefore says nothing about whether he is to the left or to the right of the obstacle. Don't check the player's velocity, check the player's position relative to the obstacles position:
Replace
if (player.vel.x < 0)

with
if (player.pos.x > this.x)

redpajama_set_name: RedPajamaStackExchange


Another delegate summed it up this way: "the desire and commitment to succeed comes from within and not without. That is what generates sustainability." In other words, when communities, organizations or teams are empowered to manage their own pace of change, they are not being told what to do and they have options that are culturally appropriate and accessible, that is when they get onto the road to sustainability.
Another interesting organizational perspective was the growing realization that achieving any desired organizational change that will be sustainable involves more than strengthening the skills and competencies of individuals within the organization. What is perhaps more important is the effect of the right policy environment, effective systems and practices, as well as informal practices, beliefs, values and attitudes that must be understood and integrated into organizational capacity building efforts. Of course, building knowledge, skills, and attitudes can have a positive effect on an organization, but to achieve and sustain change those individuals need an appropriate work climate and the proper mix of incentives and opportunities in which to apply the acquired knowledge and skills.
In one of the break-out sessions, several speakers found fault and some even expressed their frustration with the common approaches that rely on training workshops or providing information through the dissemination of materials and tools as the prima facie basis for capacity building. They suggested that such approaches are more likely to succeed and contribute to organizational sustainability if they are combined with tailored individualized assistance and coaching. Such a multi-faceted approach may be resource-intensive, thereby limiting the number of organizations that can be reached but knowledge or tool transfer alone is insufficient to foster long term sustainability of any organization.
Ummuro Adano is a Senior Technical Advisor, Capacity Building, for the AIDSTAR-Two Project. He attended the Regional HIV Capacity Building Partners Summit in Nairobi, Kenya, March 16-18.
Principle of sustainability in general is the concept of empowerment model. It is to replace the idea of giving Fish with skill of fishing. We should produce local facilitators In any intervention we need to involve locals We should focus to use local available resources Local should change their attitude of accepting expatriate idea blindly. They need to see if it fits to the local norms and context. Expatriate must realize that their experience are differ from country to country.


text:
GBH
By Ted Lewis
Afterword by Derek Raymond
Category: Crime Mysteries | Noir Mysteries | Suspense & Thriller
About GBH
The lost masterwork of British crime icon Ted Lewis—author of Get Carter—is an unnerving tale of paranoia and madness in the heart of the late 1970s London criminal underworld.
In London, George Fowler heads a lucrative criminal syndicate that specializes in illegal pornography. Fowler is king, with a beautiful woman at his side and a swanky penthouse office, but his world is in jeopardy. Someone is undermining his empire from within, and Fowler becomes increasingly ruthless in his pursuit of the unknown traitor, trusting an ever smaller set of advisers.
Juxtaposed with the terror and violence of Fowler's last days in London is the flash-forward narrative of his hideout bunker in a tiny English beach town, where he skulks during the off-season, trying to salvage his fallen empire. Just as it seems possible for Fowler to rise again, another trigger may cause his total, irreparable unraveling.
Also by Ted Lewis
See all books by Ted Lewis
Published by Soho Crime
Feb 23, 2016 | 352 Pages | 5 x 7-1/2 | ISBN 9781616956462
Apr 21, 2015 | 352 Pages | ISBN 9781616955519
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What You Break
Reed Farrel Coleman
The Cocktail Waitress
The Cold Six Thousand
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The Real Cool Killers
Getting Off: A Novel of Sex and Violence
Jill Emerson and Lawrence Block
The Glass Key
A Rage in Harlem
The Simple Art of Murder
Red Harvest
The Dain Curse
Deadman's Bluff
James Swain
T.C. Boyle and T. Coraghessan Boyle
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Sinner Man
Nineteen Seventy-Four
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Praise for GBH
A Washington Post Notable Fiction Book of 2015
"GBH is a novel as direct as it is stunning . . . I reckon he knew a good deal of what he was writing about from very close—perhaps dangerously so. That leaps out of the work immediately."
—Derek Raymond, from the Afterword
"A pulp-fiction triumph worthy of Jim Thompson or James Ellroy. I can't remember the last time I turned pages so eagerly… his work cuts to the bone, both literally and metaphysically."
—John Powers, NPR's Fresh Air
"One of the most coldly brilliant crime novels you will ever read . . . a mesmerizing story of power, love, hubris and betrayal—but, above all, the portrait of what one might call a tragic villain . . . Complicated in plot, propulsive in its narrative pace, beautifully structured, it is a book you'll want to read."
—Michael Dirda, The Washington Post
"GBH shows Lewis stayed true to his unnerving vision and voice to the end, even while pushing it into farther-out places. This hitherto-obscure book's resurrection should further enhance the Lewis legend."
—Tom Nolan, The Wall Street Journal
"Ted Lewis wrote brilliantly about ruthless men clinging to their humanity with mordant wit and misguided but powerful senses of honor. That these quintessentially British novels are finally available in the US is real cause for celebration."
—Scott Phillips, New York Times bestselling author of The Ice Harvest
"Lewis is major."
—Max Allan Collins, bestselling author of Road to Perdition
"Ted Lewis is one of the most influential crime novelists Britain has ever produced, and his shadow falls on all noir fiction, whether on page or screen."
—Stuart Neville, author of The Ghosts of Belfast
"A must-read for all noir fans."
"His final novel and masterpiece . . . You won't find many nice guys upon these pages."
—Dayton Daily-News
"Lewis remains a sharp social anatomist of the hopelessness and soul-sucking dinginess of his era. Starting with [Get Carter], Lewis sketched the horror of a Britain where home was the kitchen sink, the sodden bar towel, the decrepit industrial landscape."
—Barnes & Noble Review
"Lewis gives new meaning to suspense with this masterly tale of a man's downfall and the bloody trail he leaves behind."
—Publishers Weekly, Starred Review
"Lewis is universally recognized as the author of the book on which the classic movie Get Carter was based, but he was more than a one-book author. Seize the opportunity to read this prime example of Brit Grit that present-day practitioners such as J.J. Connelly and Jake Arnott have imitated but never bettered."
—Library Journal, Starred Review
"That bleak tale [Get Carter] of revenge became an influential crime-fiction classic, and deservedly so—but for some fans, his swan song [GBH] was an even bigger literary achievement."
—Booklist, Starred Review
"The dark storyline is punctuated by Lewis's bleak narrative and crackling dialogue, the plot full of foreboding, the climax an orgy of violence. And when you finally put the book down, you'll need a breather. They simply don't get any better than that."
—Jim Napier, Reviewing the Evidence
"While [Get Carter] will likely always be the most noted of Ted Lewis's nine novels, GBH, the final book Lewis published, is his masterwork."
—The Life Sentence
"It is like a sip of Absinthe on a three-day empty stomach, a book that will chill you and ricochet your thought process at least temporarily, if not permanently."
—Bookreporter.com
"Lewis' masterpiece."
"An impeccable sociologist of the gutter."
More from Ted Lewis and book picks sent right to your inbox


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