Virginia Regulatory Town Hall
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Commission on the Virginia Alcohol Safety Action Program
 
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Commission on the Virginia Alcohol Safety Action Program
 
chapter
Ignition Interlock Regulations [24 VAC 35 ‑ 60]

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12/31/19  10:19 pm
Commenter: Cynthia Hites

Interlocks should measure only ethanol
 

An Interlock device is an alcohol group detector.  The hydroxl group in chemistry is comprised of lots of compounds called alcohols, one of which is C2H5OH. 
24VAC35-60-70 states the machines shall be “alcohol specific”.  24VAC35-60-20 defines alcohol as the compound C2H5OH, which means ignition interlocks shall measure only that one single compound, ethanol. 
Human breath contains a person’s personal biological waste, and VA has the right to measure only ONE compound. The government has no right to capture human breath and take measurement of that person’s sorbitol level, xylitol, or cortisol. It’s invasively examining private medical waste and falsely misconstruing any alcohol as ethanol. 

The instruments are being totally misused. They are alcohol specific, which just means they detect a big ole group of stuff.  
The NHTSA IID model specs define alcohol as ethanol. Not one of the daggon interlocks in America can meet the current NHTSA standards. An electrochemical fuel cell can’t distinguish ethanol. 
The NHTSA, VA code, and the US FDA all define “alcohol” as ethanol. 
So when a person is told to avoid “alcohol” in all products, that’s a reasonable demand.  They examine everything in their life that contains the compound C2H6O, and can then avoid it. 
But when you tell someone to avoid “alcohol” and you don’t use a definition, it means they have to avoid not just ethanol found in products, but you’re forcing them to avoid stuff they have no idea is an alcohol.
I mean, I had no idea what mannitol was and I’ve been studying alcohols for 3 years now. It’s a sugar alcohol. How in the world is someone supposed to know to avoid something that they don’t know is an alcohol? 
You can’t just order someone to avoid alcohol, then don’t define it. That’s why it has to be defined. It’s flat out trickery to try and use the meanings interchangeably, because instead of alcohol meaning “ethanol” alcohol is just referring to a huge group of compounds that literally no one can list. 
Look, it’s fraudulent to claim an electrochemical fuel cell only measures C2H6O, because that’s the definition ETHANOL specific, and fuel cells inherently measure lots of alcohols.
People aren’t getting false positives - they’re just getting positives for alcohols other than ethanol. It’s a dadgum ALCOHOL detector, no one can claim it just detects ethanol. That’s a lie. Science fiction. 
The RFP says ethanol specific. The interlock companies say yeah, we just measure one thing - alcohol.  That is true. The interlocks only measure one thing. Alcohol.  
Everyone’s been snowed. The lawmakers, the public. Everyone thinks this measures only ethanol. It’s sooo simple. The Interlock companies are using 2 different definitions of “alcohol” when they’re supposed to only be using one - ethyl alcohol.  They’re having their cake and eating it, too. 
This whole interlock thing is honest to goodness noble cause corruption. The means don’t justify the end. It’s not fair to use a preliminary detector for ethanol and just deem it conclusive. 
A lot of innocent people are being hurt, accused, stranded and humiliated for the sake of the greater good. 
However, one of the reasons I am so passionate about exposing this is because of my love of ASAP. 
My life was saved, in large part, due to the wonderful ASAP program. I had, very quickly, developed a serious and very destructive relationship with alcohol. I didn’t know a lot about it; I didn’t really start abusing alcohol until about a year before my DUI conviction. The ASAP curriculum was excellent, and I treated my ASAP classes like college courses. I learned about ethanol and what it does to our bodies and lives. I used the comprehensive information I was given to turn my life around completely. I abandoned all the bad influences, I cut everyone off socially, and I completely quit drinking. 
I credit the ASAP classes with helping me understand i needed to drastically change my entire life.  ASAP made me realize I wanted to live again. And I love everyone associated with it. Even Kim Barcliff.  She may be an opportunist, but she’s still a child of God. 
I quit drinking May 26, 2016 and to this date have not ingested ethanol. I quit drinkin and I’m very proud of it. After all I know now about ethanol, I wouldn’t 
touch it with a ten foot pole. I’ll never drink liquor again, and I give ASAP a lot of credit for educating me. 
So when, after my complete sobriety, I began having all these high alcohol readings on the interlock it was really confusing, embarrassing, and maddening.  
I may be quixotic and naive, but I’m not stupid. I was sober as a judge the entire    time all these high alcohol readings occurred. Can you imagine?! I’m lucky my family knows me - I was being accused of repeatedly attempting to start a vehicle with liquor in my system. That’s a devastating accusation for someone who is trying to turn their life around. 
To have a machine accuse me over and over was so dehumanizing.  And no one except Chris Morris even knew what the numbers meant. He was the one who educated me about fuel cells. He told me “I tell people to avoid anything that ends in -ol”, so I researched that info he gave me and dang if he wasn’t right. 
The Commission on VASAP is not corrupt. The directors and case managers aren’t twiddling their fingers, plotting how they can screw people out of $10 a month. No one is intentionally breaking laws or trying to cause harm. 
To the contrary.  Ignition interlock is indeed noble cause corruption, but I was a bit mistaken in thinking VASAP was the corrupt part of the equation. After much scrutiny, the application of the fuel cell is corrupt, but the people of VASAP aren’t the corruption, they’re “noble” part of the equation. 
I owe an apology to the Commission, especially Sheriff Wade. I’m so embarrassed if I ever implied anyone at VASAP was engaged in any intentional wrongdoing. I have a tremendous respect for Sheriff Wade and I’m so grateful to him for his 20 years of exceptional public service. I really like you, and appreciate what you’ve given to Virginia. I care very much about your opinion and I’m so thankful to you for your obvious lifelong dedication to bettering Virginia. You and the entire Commission are doing a great job helping keep our roads safe. 
Thank you, all members of the VASAP Commission and Staff. 
But the fact of the matter is interlocks measure don’t measure only ethanol. They can measure other alcohols. And that’s not fair, and it’s not right. And I’m not wrong. 

CommentID: 78760