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Tip 50: When an "approved instrument" is calibrated at the factory, the manufacturer doesn't simply adjust the electronics in the instrument to one concentration of ethyl alcohol. The electronics in a new instrument must be tweaked (using a screwdriver pre-2000 and software post-2000) so that electrical signals coming from the detector and other circuitry are accurately and precisely read by the instrument's software to output values corresponding to ethyl alcohol values of m

This is a sample cross-examination of an Ontario CFS scientist on the procedure used to perform an initial factory calibration (or a subsequent re-calibration by the factory) of an individual Intoxilyzer 8000C. Purposes of this cross-examination: [respecting type approval by the Alcohol Test Committee and Minister of Justice] To confirm that when new instruments are being evaluated, various solutions are used between 50 and 400 mg/100mls. To confirm that when new instruments

Purpose of this sample cross-examination: To demonstrate that when the particular instrument was first placed into service, the tolerance verified by the independent authorized service centre for each of three test values was +/- 3 mg/100mls. To demonstrate that the initial verification matched the manufacturer's published specifications of accuracy +/- 3 mg/100mls. To demonstrate that when the particular instrument is subsequently being annually checked, by the police servic

Purpose: To further challenge the Crown's suggestion that the anomalous low cal. checks that occurred in this breath truck were not caused by a door opening from time to time in winter. To support the O'Connor application for production of contemporaneous documentation by the QT who obtained the group of low cal. checks. Documentation would shed light on possible causes of the low cal checks, any troubleshooting attempted, and the likelihood that their cause was a problem wit

Purpose: To cross-examine a CFS scientist on use of Guth 2100 wet-bath simulator under Canadian cold operating conditions To build a case for O'Connor production of contemporaneous documentation by the QTs who obtained the groups of low cal. checks in the breath truck in winter. During Direct Examination, the CFS expert had suggested in response to the Crown's request for the simplest explanation for anomalous low cal. checks, that the door being left open on the breath truck

Purpose: To obtain an admission from a CFS scientist that expectation of ATC Best Practices Recommendation is for annual inspection of wet-bath simulator to ensure it meets manufacturer's specifications To obtain an admission from a CFS scientist that manufacturer's specification for a Guth 2100 simulator is 34.00 +/- .05 degrees C, not just 34.0 +/- .2 degrees C. MR. BISS: Q. Now, can you just – sorry – can you just tell us a little bit more – we’ve been talking a lot abou

Purpose: To challenge the Crown's assertion that the AI will automatically shut down if anything is out of tolerance or ATC or manufacturer's specifications. Let's suppose the Crown's expert says this about the Intoxilyzer 8000C: "If the calibration check is outside the acceptable range, you’re not going to be able to proceed with testing." The expert is saying in other words, the instrument is smart enough to make sure that cal. checks are foolproof, and you can't proceed wi

Purpose: To remind the Court of the concept of "reliability" used by the SCC in St-Onge. To educate the Court as to the definitions of "accuracy", "precision", and "reliability" used by Brian Hodgson in his paper relied on by the SCC in St-Onge. To focus on drift in accuracy and precision over time from: the manufacturer's specifications, and/or the accuracy and precision of the 8000 that was evaluated, and/or this specific instrument when first placed into service, as compar