Assessment of Cadmium levels in Chocolate

Assessment of Cadmium levels in Chocolate Research Proposal Assessment of Cadmium levels in chocolate commercialized in Lebanon Josiane Haddad 1- Background and significance Cadmium (Cd) as an element is a soft silver-white transition metal. It is not usually present in the environment as a pure metal, but is most often present in the form of oxides, sulfides, and carbonates. It does not have a taste or odor. Cadmium sulfate and cadmium chloride are quite soluble in water, whereas metal Cd, cadmium oxide and cadmium sulfide are almost insoluble (International Program on Chemical safety [IPCS], 2007). Cd is released from several sources in nature: mobilization of Cd from the Earths crust and mantle due to volcanic activity, mobilization of Cd impurities in extracted raw materials such as phosphate minerals and fossil fuels, release of Cd from products and processes resulting from the use, disposal, recycling, open burning or incineration, releases from municipal installations and release of Cd previously deposited in soils, sediments, landfills and waste or tailings piles (United Nations Environment Program [UNEP], 2010). It is a toxic metal to humans and classified as a carcinogen by the National Toxicology Program (Agency for Toxic Substances and Disease Registry [ATSDR], 2004]. In the human body, Cd is mainly stored in the liver and kidneys. Hence, an early effect indicator of Cd toxicity is increased excretion of proteins in urine, kidney proteinuria, which is the result of proximal tubular cell damage. Several other side effects occur depending on the duration and magnitude of exposure. Skeletal damage is another critical effect of chronic Cd exposure at high levels. Cd concentrations in most tissues increase with age since excretion is normally slow, and the biological half-life is very long (10 to 15 years) (Jin T., Lu J. Nordberg M., 1998) in the muscles, kidneys, liver and whole body. In exposed people with renal damage, urinary excretion of Cd increases and so the whole body half-life is shortened. The kidney burden resulting from cumulative exposure to Cd can be assessed by measuring Cd in urine (UNEP, 2010). Epidemiological and experimental studies have associated occupational Cd exposure with several types of cancers including lung, prostate, renal, liver, hematopoietic system, urinary bladder, pancreatic, testis and stomach cancers (Journal of Inorganic biochemistry, 2000; Joseph P. et al., 2001). Exposure to this toxic metal also severely affects the function of the nervous system (L’opez E. et al., 2003; Cao Y. et al., 2009), with symptoms including headache and vertigo, olfactory dysfunction, Parkinson-like symptoms, slowing of vasomotor functioning, peripheral neuropathy, decreased equilibrium, decreased ability to concentrate and learning disabilities (Cao Y. et al., 2009; Phil R.O. Parkes M., 1977). Presence of Cd was also detected in hair and higher concentrations of hair Cd were reported in children with mental retardation (Marlowe M., Errera J. Jacobs J., 1983) and learning difficulties or dyslexia (Phil R.O. Parkes M., 1977; Capel I. et al., 1981). There are several sources of human exposure to Cd including employment in metal industries, production of certain batteries, some electroplating processes and consumption of tobacco products (International Agency for Research on Cancer [IARC], 1993). However, food accounts for approximately 90% of the Cd intake in the general, non-smoking population since this metal is found in the soil. The quantity absorbed by crops in different locations is influenced by factors such as soil pH, salinity, crop species and varieties and the presence of other elements (e.g., zinc). Less than 10% of the total exposure occurs due to inhalation of Cd in ambient air or ingestion with drinking water (UNEP, 2010). Since Cd is dangerous to humans, a provisional tolerable weekly intake (PTWI) or provisional tolerable monthly intake (PTMI) had to be established. PTWI is an estimate of the amount of the chemical that can be ingested weekly over a lifetime without appreciable health risk (Food and Agriculture Organization [FAO] World Health Organization [WHO], 1988). The European Union recommends a PTWI of 2.5 ÃŽ ¼g/kg of body weight (European Union [EU], 2014). The PTMI for Cd recommended by the FAO/WHO Expert Committee on Food Additives (ECFA) is 25 ÃŽ ¼g/kg of body weight (FAO WHO, 2014). In 2010, the Consumer Product Safety Commission (CPSC) recommended that the acceptable daily intake level of 0.1 à °Ã‚ Ã…“†¡g kg−1 body weight per day for chronic exposure (Mead N., 2010). Studies in several European countries have demonstrated high levels of Cd in agricultural topsoil due to the use of Cd in fertilizers and atmospheric deposition. Over the last 100 years, the increase in soil Cd concentration in Austria, Denmark, Finland, Greece, Ireland and the United Kingdom was estimated to be 7 to 43 percent (UNEP, 2010). Hence, the risk is in continuous increase and further investigation on the quality of the crops and food consumed has to be pursued. Out of the possible crops carrying Cd, cocoa, the seed of the Theobroma cacao tree (Watson R., Preedy V. Zibadi S., 2013; Lee F., 1983), is one of the most consumed by all age groups worldwide, especially by children. The large consumption of cocoa and chocolate products derived from cocoa is due to its pleasant flavor and the feeling of well-being that it gives (Watson R., Preedy V. Zibadi S., 2013). Several studies revealed the benefits of chocolate consumption due to the high levels of flavonoids and antioxidants present in cocoa based foods (Grivetti L. Shapiro H., 2009; Crozier S. al., 2011; Buitrago-Lopez A. et al., 2011). They are an important source of minerals such as Ca, P, Fe, Mg, Cu, Zn, K, and Mn (Grivetti L. Shapiro H., 2009; Peixoto R., Oliveira E. Cadore S., 2012; Pedro N., Oliveira E. Cadore S., 2006). In addition, they may prevent harmful effects caused by free radicals in the human body, contributing to the reduction of cardiovascular disease and cancer risk (Fernandez-Murga L. et al., 2011; Yao H., 2011). However, the presence of potentially toxic elements has also been reported (Rehman S. Husnain M., 2013; Yanus R. et al., 2014), particularly lead and Cd (Dahiya S. et al., 2005; Jalbani N. et al., 2009). Previous studies have been performed to test the presence of Cd in chocolate samples in several countries and the results revealed the presence of this heavy metal with a large margin of variation. In turkey 20-30 ppb were observed, in India 1 to 2730 ppb were reported, in Malaysia 280 to 420 ppb and in Pakistan 4.3 to 190 ppb were observed (Dahiya S. et al., 2005; da Silva A. et al., 2006; Dos Santos A. et al., 2005; Guldas M. et al., 2008; Lee P. and Low T., 1985; Leggli C.et al., 2011). In Oakland, California, the non-profit organization As You Sow (AYS) tested Cd levels in 42 products, 26 of which contained lead and/or Cd level above what the state of California considers safe. The organization sent legal notices in the context of holding more heavy metals than allowed under the Golden State’s Proposition 65 toxic chemical warning law to 16 manufacturers including Hershey’s, See’s, Mars, Godiva, Ghirardelli, Lindt, Green and Black’s, Kroger, Whole Food s, Trader Joe’s, Earth Circle Organics, Moonstruck, Theo, and Vosges (AYS, 2015; The Washington Post, 2015). In this study, given that some of the brands commercialized worldwide are found in Lebanon, cocoa and chocolate derivatives will be tested for their Cd content. Specific Aim Various brands of chocolate, whether local or imported brands, are largely consumed in Lebanon. The main ingredients in chocolate consist of cocoa, milk and fats, each of which is a potential source of Cd. No study has been conducted till now to assess the quantity of toxic metals present in the products on the market. Hence, a study to determine Cd levels is important for chocolate consumers and manufacturers. The aim of this study is to assess Cd levels in chocolate samples mostly consumed by the Lebanese population and compare those levels to the values issued by global health organizations. Research design and methods Sample collection Different brands of dark chocolate, milk chocolate and cocoa powder are collected from different stores according to the most sold brand. The shelf life of most milk chocolate samples is one year, and 2 years for dark chocolate. Samples will be labeled and stored at a temperature between 15 and 17à ¢Ã‚ Ã‚ °C. Samples will be kept wrapped in foil and placed inside a Ziploc plastic bag so that they do not absorb the odors and moisture from the refrigerator (Subarmanian P., 1998). Microwave digestion In order to detect heavy metals in cocoa, the samples have to be digested since the matrices are organic. According to the Environmental Protection Agency (EPA), microwave digestion can be followed on chocolate samples where up to 0.5g are digested in 5mL of concentrated nitric acid and up to 2mL hydrogen peroxide (Onianwa P.C. et al. 1999; Mounicou S. et al., 2002), which can also be substituted by nitric acid and hydrofluoric acid (Gà ¼ldaÃ…Å ¸ M., Adnan F.D., Biricik F.B., 2008). The digestion is run in PTFE vessels at approximately 180 ±5à ¢Ã‚ Ã‚ °C for 15 minutes (Environmental Protection Agency [EPA], 2004). The time and temperature are subject to variation in order to find the most convenient parameters for the samples tested. Wet digestion method can also be applied in the digestion of chocolate samples. The two methods are comparable in results (Jalbani N. et al., 2009). However, wet digestion requires a greater use of chemicals and causes a greater risk of contamination (Jalbani N. et al., 2009). As the samples will be used to assess both lead (Pb) and Cd, each sample is spiked with an internal standard of Pb and Cd prior to digestion (FDA, 2014). Obtained samples after digestion are reconstituted to 25mL with ultrapure distilled water in volumetric flasks then placed in vials and stored in the refrigerator (EPA, 2004; Jalbani N. et al., 2009). Atomic absorption analysis For quantitation, stock Cd and lead standard solutions of 1000mg/L each are diluted to different concentrations and a standard addition method is followed to prepare a calibration curve. Diluted Cd and lead stock standards with 1% nitric acid will be placed in nitric acid rinsed volumetric flask and stored in plastic bottles (Teflon ® FEP or HDPE bottles recommended). Both elements can be combined in the same solution (Food and Drug Administration [FDA], 2010). The heavy metal is detected by Graphite Furnace Atomic Absorption Spectroscopy (GFAAS). Electrodeless discharge lamps for Cd and Pb are operated, alternatively. Cd will be detected at a wavelength of 228.8 nm (FDA, 2010). Pure argon (99.999%) is used as the purge and protective gas. Different chemical modifiers will be tried to find the most convenient one such as ammonium phosphate, magnesium nitrate, phosphoric acid or others. Statistical analysis Statistical analysis will be done in two different stages. First, the mean Cd concentration of each brand of chocolate will be calculated and proportion differences for independent samples will be tested by comparing the calculated mean values to the permitted ones by Global Health Organizations. If significant differences are observed, a second step of analysis will be performed in which the studied brands are subcategorized forming a contingency table. The differences can be identified by a χ ² test thus allowing the formation of an ANOVA study to check in depth for the differences within the categories and between them. Using these methods, the most diverging categories from the norm will be identified. Expected results This study will most likely reveal the presence of Cd in chocolate samples as it has been the case in other similar studies. Some samples might have values higher than the tolerable intake specified by global health organizations. Potential problems Cd is toxic at low doses (FAO WHO, 1988; Mead N., 2010; EU, 2014; FAO WHO, 2014) and may be found in low doses in some samples as shown in previous studies (Dahiya S. et al., 2005; da Silva A. et al., 2006; Dos Santos A. et al., 2005; Guldas M. et al., 2008; Lee P. and Low T., 1985; Leggli C. et al., 2011). Accordingly, the selection of an appropriate chemical modifier for AAS analysis is very important. Several trials will be attempted in order to select the optimal type. In addition, the order and receipt of chemicals will be time consuming. Time frame Completion of the proposed aim requires duration of 3 to 4 months in order to allow for the collection of samples, sample digestion, graphite furnace analysis, evaluation and statistical analysis of the results obtained.

Advantages and disadvantages of the doctrine of precedent Essay

Discuss the advantages and disadvantages of the doctrine of precedent and how judges may make new law. Include 1 case where judges have made new law. The doctrine of precedent is an important feature of judge-made law (common law). This doctrine means that similar disputes should be decided by reference to the same legal principles, and that lower courts are bound to follow the decisions of higher courts within the same court hierarchy. There are both advantages and disadvantages of the doctrine of precedent and the way in which judges may make new law. An advantage of judge made law is that decisions are based on principle – meaning that judges are not making up the law as they go. The doctrine of precedent provides for consistency in the application of the law, which therefore promotes justice and fairness (as the courts will decide ‘like’ cases in the same way). There is also some degree of certainty, as the outcome of cases can be predicted based on previous decisions. The advantage of precedent is that it allows for the law to grow to meet new situations, and to be flexible to meet changing needs – which therefore provides for the efficient operation of the legal system. On the other hand, judge-made law is slow to evolve. The courts are not free to make law in the same sense as parliament. Unlike parliament, judges cannot make law as an immediate response to a community demand or when a general need is perceived. A disadvantage of precedent is that rigidity and inflexibility may develop where judges are reluctant to depart out-of-date or inappropriate precedents. Uncertainty can also arise where there is more than one precedent that may apply to a particular set of circumstances. Change may be slow and irregular because change can only occur when a complainant has a significant case that is subject to an appeal. Given the cost of litigation, not all complainants may be prepared to persist with a legal action under these circumstances. Also, the law develops retrospectively meaning that a problem must exist before the court will consider the circumstances – it does not operate to avoid possible conflicts. Landmark decisions (from which new principles develop) are few and far between. They usually arise from cases on appeal heard in the highest courts. An example of an Australian case where judges have made new law is Grant v. Australian Knitting Mills [1936] AC 85. This case involved similar  circumstances to the landmark case of Donoghue v Stevenson, [1932] AC 562. In this case the plaintiff, Dr. Grant, bought some woollen underwear from a store. The underwear had been manufactured by the Australian Knitting Mills Ltd. Dr. Grant suffered dermatitis as a result of wearing the woollen underwear. It was later discovered that the condition was caused by the excessive use of chemicals in the process used to make the underwear. According to the doctrine of precedent, the court would have applied the rule of law stated in Donoghue v. Stevenson to the case of Grant v. Australian Knitting Mills. Like Mrs. Donoghue, Dr. Grant was deemed to be a ‘neighbour’. He was a person who was closely and directly affected by the act of the manufacturer and the manufacturer ought to have had him in mind as being affected when preparing the underwear. The manufacturer had a duty to take reasonable care to avoid acts that they could reasonably foresee would be likely to injure consumers such as Dr. Grant. Dr. Grant was successful in his claim for damages. This was the first Australian case to adopt the legal principle of negligence. In summary, judges make laws by comparing similar situations and following sets of principles to determine outcomes. This is known as the doctrine of precedent and it creates common law – which has both advantages and disadvantages.

Short Article Reveals the Undeniable Facts About History Essay Topics and How It Can Affect You

Short Article Reveals the Undeniable Facts About History Essay Topics and How It Can Affect You A Startling Fact about History Essay Topics Uncovered It is an impossible task to compose a fantastic history paper if you write about something you find boring and don't care about whatsoever. Children rights ought to be defended more intensively. Find out more about the very first decade of film production to discover what themes were most common. There are several social problems in the life span of modern United States citizens. The most frequently encountered paper writing service that the vast majority of our clients require is essay writing. A superb paper topic ought to be interesting and ought to incorporate an original idea or position try to prevent cliche topics which will likely bore your reader. When you inform us about all of the paper information, we'll begin searching for an acceptable writer for your paper. Popular themes for academic papers can be seen on our site too. The second criterion is also crucial. What follows is an extensive collection of the most intriguing research topics to have you started. The last write-up needs to be concise with firm language. Below you'll find some of the best American history research topic suggestions for your paper. The multiple topics could possibly be found, for instance, in the dissertation abstracts international database. Choosing one of our suggested topics will let you start writing a thriving research paper. You have to be exceedingly thorough about choosing the topic from the huge array of topics. Selecting the most suitable essay topic can at times be rather hard. If you would like to compose the essay yourself, we believe it would be best to pick a universal subject or issue. Take into consideration this issue of the history essay you've already written before. If you would like to write a superior history essay you'd better opt for a topic that is familiar to you. Because it's a well-known subject, you'll need to be really creative to produce your essay unique. The way to the perfect essay is via WritePaperFor.Me. Nowadays it's very hard to locate a trustworthy essay writing service. Writing an excellent persuasive essay is not a simple task, however, it's achievable. History Essay Topics Options You'll locate a whole lot of health studies that show the advantages and risk of marijuana usage. It's often hard to locate objective information to present an unbiased treatment of the topic. When you decide on a research topic, make certain it is one which you understand and have a firm grasp on. Remain realistic and select a topic you're able to research. Our life is about words. One of the most important things about world history is that it's particularly full of topics, subjects, and questions. Alternatively, you will concentrate on the problem of smallpox epidemics and their part in the history of America. Among the troubles with h istory generally is that individuals consider it dull and boring. Most Noticeable History Essay Topics The area of architecture is everywhere. In so far as it's the sole kind of history that has the ability to take global aspects into consideration, global history is apparently the most dependable tool for understanding our globalized world as it is. The beauty business is massive. The attractiveness of current affairs is it shows you which you don't just dwell in a world that's a cocoon. So How About History Essay Topics? You thought that war may be coming. In reality, you might want to learn even more regarding the period of time prevents you originally begun to investigate. Any student on the planet at the present time can testify to the simple fact that from time to time teachers have a tendency to stress the demand for the student to be up to speed when it has to do with current troubles. In reality, there's so much history that unless your teacher has given you an es tablished topic it's often hard to limit your choices. There are a few things that you might have to to understand prior to that though. Write a list of ideas you've got or a list of things you're interested in. Regardless of what you say, someone is going to be offended by it. Almost everything can be an issue of History when focused in some specific ways. Where to Find History Essay Topics When prior brainstorming is finished, you can begin drafting your essay. Planning is critical in any sort of home task, from building a powerpoint presentation to supplying American Government homework help to your friend.

The Innovation Of Cancer Treatment - 1940 Words

Cancer, since the beginning of history, has plagued humanity and claimed countless lives. For thousands of years, doctors could do little more than watch with horror as their patients succumbed to the often fatal condition. There is still no definite cure for cancer. However, while one might say that treatment is still in its infancy today, therapies have evolved dramatically over the last century. The innovation of chemotherapy marked a turning point in cancer treatment. Dr. Sidney Farber, a pediatric pathologist, is regarded as the father of modern chemotherapy due to his success in inducing remission in leukemia patients through the use of chemical agents. Through Dr. Farber’s innovation, chemotherapy strengthened the relationship†¦show more content†¦Today, while there is no cure for cancer, various treatments are available depending on the type and severity of the disease. Generally, tumors are surgically removed. This treatment is most often combined with other therapies such as radiation and chemotherapy (Types of Treatment). The earliest records of cancer date back to ancient times to an account on the Edwin Smith papyrus, an ancient Egyptian textbook on surgery and medicine. The writer described a woman with several tumors on her breasts along with the doctor’s futile attempts at curing her. For their conclusion, the Egyptian writer simply stated that â€Å"there is no treatment† (Bushak). Even though cancer has existed since ancient times, its basic genetic background was not discovered until 1902. Theodor Boveri, a zoologist, found that a specific type of mutated chromosomes could result in cells with an unlimited ability to divide. These types of mutations were likely the result of exposure to what are now known as carcinogens, or cancer causing substances. Carcinogens include pathogens, radiation, chemicals, and numerous other environmental factors. In 1902, even though a more complete understanding of cancer was available, the only available treatment options for patients was the remo val of surface tumors. Due to the metastatic nature of the majority of these tumors, purely surgical treatment was largely ineffective. In non-tumorous cancers, there

The Reality Of Alleged Police Misconduct - 2036 Words

Patrick, Mattiocco Mr. Bordner Period 4 24 April, 2017 The Reality of Alleged Police Misconduct The idea of police brutality being a major problem in the United States has many people wondering if the police are there on the streets to protect the citizens, or to abuse them. Police brutality in the United States is not the problem. â€Å"Brutality Isn’t the Problem, It’s People Who â€Å"Disrespect Our Authority† (Grigg). Many individuals in the United States have the idea that it is all right to override a police officer’s authority that’s given to them to use to enforce the laws in a justified way properly. An important rule that the people fail to recognize is the fact that when a cop tells you to do something, then better do it to avoid†¦show more content†¦If police officers do not contain a situation when it is small, then it will become much harder to control later. Numerous cases of police brutality would mostly involve videos that act as evidence to testify against police officers who get accused of brutality. Many videos that show the acts of police brutality are twisted to make it seem as the police are unconstitutional and unfit to uphold the law. Police can prove that the acts of cruelty that they get accused of is invalid. Treatments between police officers and the citizens are not much different. People who dislike they are targeting police, and yet when police officers try to defend themselves from people attempting to inflict harm towards them, they get accused of being brutal towards a person who shows acts of threats directed towards police officers. The idea of racial profiling in America does over is exaggerated since there are many individuals across the United States believe that the police will target them due to the color of their skin. 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Ruthless Essay Topics for Catcher in the Rye Strategies Exploited

Ruthless Essay Topics for Catcher in the Rye Strategies Exploited Over the duration of his journey, there's a subtle, yet important, pattern. Before you begin, it's important to make the outline. Among the elements that you must watch out for is the themes. Think about the color of the hat also. Facts, Fiction and Essay Topics for Catcher in the Rye Like Holden, teenagers experience uncomfortable feelings when their beloved individuals disappear, and with no assistance from adults, teenagers will certainly commit reactions they regret afterwards. Imagine that you're studying in Holden's school and you would like to persuade him that people around aren't phony. Sometime later, Holden decides to employ a prostitute. He can't see a way to regain his childhood innocence. He is lonely, because he has no place to go, he does not have any ways of connecting to his friends, and he has forgotten about morals. He is also lonely because he has lost his connection to all of his friends. The Hidden Gem of Essay Topics for Catcher in the Rye In any event, the comprehension of the novel isn't decreased. The entire novel is written in the very first individual. Use the comprehensive character analyses to create connections between these themes and the folks in Holden's world. With Love and Squalor, won't be surprised by the simple fact that his very first novel is fully of children. In the following article, we're going to supply you tips about how to compose your own essay on this superb novel. In summary, the book is pretty challenging for the children to read, although it's written about the teenager's life. Sooner or later, the attentive reader sees the major hero's growth for a personality. The author has achieved the aim of this novel. Want to Know More About Essay Topics for Catcher in the Rye? Every essay is going to have a topic, but you have to tell the audience the purpose of your specific essay. Frequently, the subject of an essay can be displayed in the shape of a question. The significance of the topic for an essay cannot be underestimated since it determines the general caliber of the paper. Many college students would say that writing is almost never simple, especially when you must produce creative and intriguing topic ideas. Go just for a topic that you could comfortably analyze. That is the reason why it is advisable to select an intriguing topic. Nevertheless, it is possible to still find a topic which you're passionate about and hence cover easily. Login or make an account to view. Consequently, it's used often utilized in education for a material for essays. In such a situation, examples arrive in handy. Reading is what will be able to help you develop your abilities. You have to practice, improve your skills, and adhere to some basic things to do to compose a great text. Where to Find Essay Topics for Catcher in the Rye Mr. Spencer has a far superior understanding of the way the world functions as a result of his age. Biological change from child to adult is the kind of death that Holden is attempting to resist and it is frustrating for him to need to manage this. With ties to the previous person on the planet crumbling, Holden begins to finally question his stance on life and have to d ecide whether he will try and salvage the previous relationship or completely isolate himself. Holden really isn't the very first and won't be the previous teenager to feel angst.

Criminal Procedure for British Columbia - myassignmenthelp.com

Question: Discuss about theCriminal Procedure for British Columbia. Answer: According to the facts the legal profession privileges has defines the protection of the communication between the solicitor and their clients who make promised to never disclosed any information regarding to the works. The privilege helps to protects the legal principle for the individual person for their ability to access the justice system by disclosing every information. In Canada Solicitorclient privilege define as a common law evidentiary principle which always makes it recognizable as a substantive rule which always get protected through the constitution (Garland, 2014). According to Justice Lamer the solicitorclient privilege always explain the confidentiality of communication under some circumstances where communication can be disclosed without the client's consent. Without the permission of the law the legitimate exercise of a right make the appearance through the interference of another persons right where the communication with the solicitor should be confidential and must not make any conflict with the confidentiality. The law provides the authority under some condition and when it has been provided to someone it holds the rights of interference with confidentiality. The decision which has been taken must make the choice of means of exercising and the authority make the determination with the decision for not interfering with confidentiality (Murphy, 2015). According to the test on communication of privilege it defines a rule of evidence which helps to protects from disclosure in court documents or communications made for the dominant purpose of litigation: Two factual determinations must be made to assess whether litigation privilege attaches to a document and it arises several queries like was litigation in reasonable prospect at the time the document was produced or what was the dominant purpose for its production? The test has been found in the case of Dos Santos v. Sun Life Assurance Co. of Canada, 2005. In the case of Physicians of British Columbia v. British Columbia (Information and Privacy Commissioner), 2002, the BC Court of Appeal introduced the term dominant purpose which describe the elements requires that litigation be in reasonable contemplation: If litigation was not in reasonable prospect, then the Documents were not produced for the dominant purpose of litigation. Thus, the reasonable contemplation of litigation requir ement should likely be considered first and, if satisfied, the dominant purpose requirement evaluated. When evaluating a claim of privilege one must consider the circumstances and intent when the document was created. The proper time to consider whether the test is met is when the particular documents that are in issue, namely the reports that accompanied the witness statements and photographs, were created like in the case of Sauv v. ICBC, 2010 (Murphy, 2015). A spouse could only be compelled to testify for the prosecution, as an exception to the general rule, if the accused person was charged with certain offences like involving danger or the threat of danger to the spouse, violence, cruelty or threats against the spouses child or violent or sexual offences against any child less than 14 years of age. The OLD sections 4(2) or 4(4) of the Canada Evidence Act define such legislations. According to the common law spouses cannot assert spousal privilege. In the case of R v Nguyen it has been testify that according to the common law spouses did not enjoy the protections of the spousal incompetency rules. However in the case of R vs. Hall it has been found that the rule has been again judged on spousal incompetency about their privilege. according to the fact of the case the Canada Evidence Act has been describe that spouses can and will be compelled to testify against their marriage partners, and that they will need to actively assert a right to spousal privilege if they wish to protect conversations occurring during their marriage. It effectively gives the testifying spouse a choice whether or not to disclose incriminating communications (Garland, 2014). The informer privilege is important because it provided the protection for the enforcement of the law. It is way of the duty of all citizens to apply in enforcing the law. The discharge of this duty carries with it the risk of retribution from those involved in crime (King, 2014). Informer privilege is a class privilege where the relevant relationship is established between the confiding party and the party in whom the confidence is placed, privilege presumptively cloaks in confidentiality matters properly within its scope without regard to the particulars of the situation. According to the Sections 37, 38 and 39 of the Canada Evidence Act legislates the regime for objecting to the disclosure of information. Then an application should be made for further disclosure from defense counsel, where a court might otherwise compel its production. The duty on the part of the Crown to provide disclosure to an accused person. The Crown counsels discretion with respect to both the timing of disclosure and the withholding of information for valid purposes, including the protection of police informers, cabinet confidences and national security, international relations and national defense information (King, 2014). The only exception to informer privilege is innocence at stake. Reference de Vries, J. (2014). Privilege and Limitations: The Impact of Raising the Discoverability of Claims on Solicitor-Client Privilege. Dos Santos v. Sun Life Assurance Co. of Canada, 2005 BCCA 4 Garland, N. (2014). Criminal evidence. McGraw-Hill Higher Education. King, C. (2014). Belief evidence and informer privilege: revisited in Strasbourg. The International Journal of Evidence Proof, 18(4), 340-352. Murphy, G. (2015). Solicitorclient privilege. Physicians of British Columbia v. British Columbia (Information and Privacy Commissioner), 2002 BCCA 665 Sauv v. ICBC, 2010 BCSC 763