• Stephen Biss

Which thermometer do you mean?

Tip 17: When you write your Stinchcombe letter, which #duisimulator thermometer do you mean? What do you mean by "THE SIMULATOR THERMOMETER"? When the Crown responds, are they giving you information about the specific thermometer for which you requested the information? Are you asking for the identity, traceability, and maintenance record for:

1. the digital display that the QT supposedly looked at during the subject tests?

2. the 8000C display connected to the RS232 interface connected to the 2100 that the QT accepted or over-wrote during the subject tests?

3. the yellow NIST mercury thermometer that the QT supposedly looked at to verify the digital temperature?

a) during the subject tests?

b) at start of shift?

4. any of the above:

a) when the solution change QT changed the solution and ran an Esc Esc C sequence in accordance with the Training Aid?

b) when any QT ran a regular verification of the digital 2100 thermometer in accordance with a local SOP (see earlier Tip on SOPs)? or

c) when semi-annual or annual inspection of the simulator and simulator thermometer system took place?

You need disclosure of all of the apparatus used by the local police service and its specific use by each of these QTs performing different roles. If different police officers use different methods of verifying the temperature of the alcohol standards and perhaps change their methodology depending on their task, there will be serious problems with the reliability of the disclosure and serious problems with reliability of the evidentiary breath testing system for that police service. You need to know the appartatus and the protocols followed respecting the components of the apparatus. Cross-examination cannot be focused if you, the Crown, the Court, the expert, and the QT(s) are talking about different pieces of apparatus when the words "simulator thermometer" are used.

#thermometer #tip

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