24 VAC 35-70 must include the definition of alcohol, and I believe it should align with the definition of the alcohol found in the NHTSA BAIID Model Specifications, and mirror the definition of alcohol found in 24VAC-35-60-20, as "ethanol, C2H5OH".

The SCRAM device is NOT specific to ethanol.  I believe the electrochemical fuel cell is being misapplied in these machines, as it is in ignition interlock. 

These devices can register any compound in the hydroxyl group, and have absolutely nothing to do, specifically, with consumed ethanol.

The sober human body can produce hydroxyl compounds, internally, as a byproduct of  various metabolic processes, and many of these hydroxyl-group biomarkers for disease are being discovered present in the bodies of those in early stages of certain cancers, such as lung cancer, esophageal cancer, and even breast cancer. 

Also, during ketosis, or diabetic ketoacidosis, a surge in acetone is experienced.  This acetone can reduce to isopropanol, which is detectable by an electrochemical fuel cell.

The results of the SCRAM machine cannot simply be interpreted as being C2H6O, but many other hydroxyl compounds must be considered.  The machine is supposed to measure consumed ethanol, but it is capable of measuring many, many compounds, that are misconstrued as liquor. This is a violation of civil rights, as HIPAA protects medical records, and the results of the SCRAM are not limited to ethanol, but can include private bodily data that is not related to liquor. 

These machines are good, in theory, but the scientific reality is they can measure many things.

I was unable to find the body of 24VAC35-70, as referenced extensively by Mr. Toby Taylor in a comment to this petition, submitted this same date, and wonder if device manufacturers, such as Smart Start, are given special, preliminary access to this regulatory information.  This document does not yet seem available for public consumption, and to that, I hereby also voice my strong objection. I hope you will be having a public hearing regarding these proposed regulations, as stated in the Virginia Register. 

The SCRAM devices are highly susceptible to false positive and I don't believe they should be in use in the Commonwealth of Virginia.  Thank you for your consideration.