DISCOVERY QUESTIONS CONCERNING ALCOHOL ANALYSIS

QUESTIONS FOR THE PHLEBOTOMIST:

What was the date and time of specimen collection?

How was the specimen collected: vein or capillary?

From what part of the body was the specimen collected? What antiseptic was used for site preparation?

Were any intravenous fluids being administered and at what site?

What was patient's condition: unconscious, combative, impaired speech or motor activity, odor, etc.?

Was preservative used?

Did anyone witness the blood drawing?

Who assumed custody of the specimen?

Was the analysis performed in the hospital or sent to a referral laboratory?

If performed in hospital, at what time was the report received?

Who sent out trace custody and procedures for processing.

Was the specimen collected for a police officer?

Did the police officer provide a container for the blood?

Was a second specimen tested at the hospital?

Obtain the emergency department records for verification of any or all of above.

If the test was performed on urine, is it a random specimen or time collection after voiding.

QUESTIONS FOR THE LABORATORY:

When was specimen received?

How was the specimen contained?

Was a preservative used in the specimen?

How was the specimen identified within the laboratory?

How was chain of custody maintained?

How was the specimen processed on the way to the analyst?

What was the nature of the specimen: blood, serum, plasma, urine?

What was the method of analysis?

What equipment was used for the analysis? Specify manufacturer and model.

Provide an operational manual for the equipment.

If a manual is not available, why not?

Is there a written protocol for analysis?

How and when was last time the method was standardized before this test?

What reagent blanks, standards and controls were used?

Does the analytical device produce a printout of the results of the analysis and related controls and standards? If so, provide a copy of the day's run containing the analysis in question.

If the results were recorded manually, produce the results and identify the person who recorded the results.

Is there a quality control record for the day the analysis was run?

Is there a daily quality control log?

Is there a record of other analyses of this type performed on the date this specimen was analyzed?

What is the acceptable variation above the mean of the standards? As specified by the manufacturer, what is the standard deviation of the method at the lowest limit of reliable detection?

Has the laboratory verified variation about the mean at the lowest level of detection thought to the reliable?

Was the analysis repeated?

What variation between analyses is acceptable?

If more than one analysis was performed, which result was reported? High, low or average?

At what threshold is the test considered negative?

What factors are known to influence the specificity of the test procedure?

Who actually performed the analysis?

What is the training and experience of the analyst?

Was the analytical run reviewed by a supervisor prior to reporting? Who? What background?

Are there publications available which document the reliability of the method use? Produce citations.

Were the results rounded off?

What is the stability in storage and transport of the substance being measured?

What is the basis for the opinion?

Does the deponent consider himself qualified to have an opinion concerning the health significance of the results reported?

What is that opinion?

Explain the qualifications which permit an opinion to be offered.

Is residual specimen available?

How has the residual specimen been stored?

Was more than one analysis for alcohol performed on the same patient during a 24 hour period?

Was an extramural quality control being used?

How often are checks performed?

What is the record of past results?

Is the technician and/or laboratory certified by any regulatory agency and/or professional society.

What time and to whom were the results reported?

                                                              | Toxic Substance Litigation Register | Discovery | FAQ About Drugs & Alcohol | Judicial Opinions | E-Mail Dr. Comstock | Publications |