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Purpose: To remind the Court, "thing 1" in 258(1)(c) is unconstitutional under Charter 11(d) (R v St-Onge) but is saved by section 1. To remind the Court that 258(1)(c) is saved by section 1 because of Parliament's purpose which is weight consistent with scientific reliability. To demonstrate to the Court that the SCC in St-Onge relied on the paper by Brian Hodgson. To bring that paper before the Court and make it an exhibit. To ask the government scientist to concede the def

Purpose: To obtain admissions respecting the inadequacy of ATC / CFS recommendations in requiring "stability of metrological characteristics" over time. To obtain admissions that the Diagnostics test function only checks stability over a few seconds at best, not over weeks, months, or years following calibration by the manufacturer. To underline the concept of "over time" in Hodgson's definition of "reliability". #Hodgson #reliability #durability #metrologicalcharacteristics

Why is disclosure of information about the "calibration" of the approved instrument essential to any assessment of the reliability of a particular subject breath test result at time of use? Why does reliability depend on a recent calibration or re-calibration? Purpose: To introduce the concept of "calibration interval" To obtain admissions as to the importance of calibration interval in the international scientific literature To obtain an admission that neither the ATC/CFS no

Purpose: To separate the concepts of "calibration" from "control checks" To clarify that "calibration" is something that happens at the factory, not at time of use by a qualified technician To clarify that control tests at time of testing are simply a verification (to use the CFS scientist's words) that calibration hasn't changed over time (note Hodgson concept of "over time" in his paper referred to in St-Onge) #calibration #controltest #verification #overtime