Count the Thermometers
Tip 10: How many #duisimulator thermometers are there in this image?
Do you see:
1. The digital display (dark because the 2100 is turned off)?
2. The RS232 cable interface?
3. The yellow NIST traceable mercury thermometer?
Which thermometer did the QT use to verify the temperature of the simulator at the time of the subject tests? Which thermometer did another QT use to verify the temperature of the simulator at the time of solution change? Which thermometer did another QT use to verify the temperature of the simulator at the time of annual or semi-annual inspection? They had a choice of 3 or more. Did they follow the protocol for that kind of thermometer or did they confuse them?
Do you know the protocol for each kind of thermometer? Do you know what to look for respecting unreliability in each of these 3 thermometer systems?
Find a way to work with your local Crown's Office, local Criminal Lawyers Association, and local police service to get a professional photographer into the breath room to take images like this one of the local apparatus. Co-operative efforts by Crown and defence in this regard, to obtain good close-up images once per year, are far less disruptive than a view ordered under Criminal Code section 652. Co-operative efforts to ensure everyone in the Court system has good access to images of the apparatus (approved instruments, simulators, simulator thermometers, and breath room layout) is far less disruptive to Court scheduling than every defence counsel seeking a section 24(1) remedy.
The image below taken at Halton Police Service, by a professional photographer retained by the defence, was extremely useful to the defence for cross-examination.
Take an online course on the Use of Wet-bath Simulators in Canada.