Virginia Regulatory Town Hall
Agency
Commission on the Virginia Alcohol Safety Action Program
 
Board
Commission on the Virginia Alcohol Safety Action Program
 
chapter
Remote Alcohol Monitoring Devices [24 VAC 35 ‑ 70]
Action Promulgate new regulation governing remote alcohol monitoring devices
Stage NOIRA
Comment Period Ended on 8/19/2020
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Next Comment     Back to List of Comments
8/7/20  1:24 pm
Commenter: Cynthia Hites

SCRAM is a SCAM
 

Unfortunately, this alcohol ankle monitor is not ethanol specific. Electrochemical fuel cells detectcompounds with a functional -OH, such as isopropanol, methanol, menthol, xylit ol, inositol, propylene glycol, erythritol, ethanol, cholesterol, mannitol, cortisol, sorbitol, and many more.

SCRAM bracelets are not specific to the compound they’re expected to read,(C2H6O) and are an unethical abomination. SCRAM bracelets are nothing more than a clever scheme utilizing extremely unsophisticated, non-specific, antiquated technology, and will serve no purpose except to line the pockets of the stakeholders pushing this pseudoscience.  

You see, the problem is not the fuel cell in the bracelet. It’s that all the results it yields are being called “ethanol”.

SCRAM is only a PAT (preliminary alcohol test), and simply indicates a hydroxyl compound is present. It has NOTHING,  nothing, expressly to do with ethanol. To use this machine in this capacity is a complete misapplication of its capabilities. The Facebook page Virginia Ignition Interlock Forum explains the history of the fuel cell, and it’s normalization on usage on sober individuals.

Only a gas chromatograph mass spectrometer possess the capability of being able to distinguish C2O6H from any number of its chemical family.

It’s a HIPAA violation to obtain bodily waste and blanketly analyze it, knowingly misrepresenting any hydroxyl group compound as “ethanol” That’s against citizens’ rights.  If the device can detect compounds aside from ETHANOL, there is a huge ethics problem. 

Alcohol is defined as “ethanol” in 24vac35-60-20.

The SCRAM device is pseudoscience, unethical, unconstitutional, and frighteningly fallible. It’s not designed to detect ethanol.  It’s only designed to detect the hydroxyl group, and if used, is Governmental GASLIGHTING.

NO ON SCRAM

NO ON IGNITION INTERLOCK

NO ON ANKLE ALCOHOL MONITORING.  

thank you.

Cynthia Hites 

23 Sarfan Dr 

hot, va 23664

cehtes@gmail.com

CommentID: 84204