• Stephen Biss

Use of Wet-bath Simulator in Winter Cold Temperatures


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 in winter could cause repeated cal. checks below 90. The purpose of this cross-examination was to suggest that if this was the case, then QTs of this police service are not using the simulator in accordance with manufacturer's recommendations for minimum ambient operating temperatures.

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