Tuesday, May 16, 2017 12:48:49 AM
It is time for them to
1. be done with internal testing,
2. start behaving like officers and a company that will be bringing a product to commercialization within the next 6 months, not like two year olds with a penny stock toy, (time to act like a big boy now, Kal:~(
3. submit their application and QAP (quality assurance plan) to the NHTSA and Canadian government to become an approved device (All the testing they have been doing is what is needed to provide their QAP.)
(Read the links below to find out similar regulations related to alcohol breath testing devices they'll have to go through in order to become registered as an EBT (evidential breath testing) device)
4. simultaneously submit their product for independent reveiw and verification to the NHSTA and Canadian government so they'll be able to stand up in court
(Here is an overview of IV&V, Independent Verification and Validation process used by HHS, https://www.hhs.gov/ocio/eplc/EPLC%20Archive%20Documents/14%20-%20IVV/eplc_ivv_practices_guide.pdf)
Here's what the NHTSA requires a device to do in order to become registered as an Evidentiary device.
https://www.nrc.gov/reading-rm/doc-collections/cfr/part026/part026-0091.html
5. remove and/or replace Kal Mahli with someone who has built and run a successful multi-national commercialized technology company, preferrably in breath testing technology, OR,
6. start receiving buyout offers from companies that can commercailize this multi-nationally
- either way, I'm fine with Rav and the rest of the team 'Executing' the directives set through the person or company discovered in number 5 or 6 above.
So yes, you're right, it's time.
The NHTSA follows these guidelines that come from the FMCSA--
https://www.fmcsa.dot.gov/regulations/drug-alcohol-testing/implementation-guidelines-alcohol-and-drug-regulations-chapter-7
This next link demonstrates a company that shares some of the independent verifications their company went through to become an alcohol breath testing device. Miind you, this is NOT a company on the 'Approved evidential breath testing devices' list. See that list below.
https://www.testsymptomsathome.com/wyc01_gen_validation.asp?PortalID=UND&CatID=UND&TypeID=UND&MatchType=ORG&CustType=CUS&RawTerm=0HHT1UND2UND3UND4ORG5CUS6GOO7D038H00+UND+&utm_medium=organic&utm_source=WWW.GOOGLE.COM&utm_term=UND&utm_content=undefined&utm_campaign=UND:UND&referral=https://www.google.com/
Here's the approved devices list.
https://www.transportation.gov/odapc/approved-evidential-breath-testing-devices
Here are more Federal regulations concerning EBT's
https://books.google.com/books?id=VpFSasxRjfEC&pg=PA583&lpg=PA583&dq=how+to+become+an+ebt+certified+device&source=bl&ots=0wip8PmMIP&sig=XGrt-xVDI9ouUOxySIrxpBNXu2Y&hl=en&sa=X&ved=0ahUKEwjVu_7Ood7TAhWE4IMKHcUhA14Q6AEIXjAJ#v=onepage&q=how%20to%20become%20an%20ebt%20certified%20device&f=false
https://www.law.cornell.edu/cfr/text/49/40.233
https://books.google.com/books?id=I1AfksZlVPIC&pg=PA685&lpg=PA685&dq=ebt+qap+application&source=bl&ots=M2gkiEmguM&sig=VXakt0vhsihti-HZlXHGcPBZjGc&hl=en&sa=X&ved=0ahUKEwjB_4mXqN7TAhXhzIMKHQgfAfkQ6AEIPDAD#v=onepage&q=ebt%20qap%20application&f=false
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