alcohol blood testing

7/30/2019 Alcohol Blood Testing

1/5

Understanding quantitative

blood alcohol testing

in drunk driving cases.

16

BIB

alcohol

Understanding quantitativeblood alcohol testing

in drunk driving cases.

Document hosted at

http://www.jdsupra.com/post/documentViewer.aspx?fid=70bcb94f-a98f-4bf8-bbeb-d433e


2/5

By Patrick T. Barone and Jeffery S. Crampton

Drunk driving cases involving blood draws are considerablymore complicated to litigate than are those involving breathtesting. While the attorney is confronted with a test resultthat is usually more reliable than with breath, the founda-

tional requirements are considerably more substantial. The testing proc-ess is not infallible, and understanding this process is critical if the de-fense attorney hopes to appropriately represent a blood draw client. Thisarticle will present an overview of the typical blood draw case, from theblood draw through the actual testing.

The Search WarrantMost blood is drawn after the client has refused to offer a breath

sample, and a court has authorized a warrant. Thus the warrant and affi-davit in support should be examined to determine if they are properlysupported by probable cause. What evidence is there to support the po-lice officers conclusion that your client was intoxicated? Under limitedcircumstances it may be appropriate to file a motion to quash the war-rant, such as when the warrant is based on insufficient probable cause.1

Keep in mind, however, that in the context of a drunk driving case, awarrant for blood may be supported entirely by the results of a prelimi-nary breath test.2

The Blood DrawThe next area of inquiry is the blood draw itself. Michigan law in-

dicates that only a licensed physician, or an individual operatingunder the delegation of a licensed physician, who is qualified to with-draw blood and is acting in a medical environment, may withdrawblood at a peace officers request to determine the amount of alcoholin a persons blood.3 However, the phrase qualified to draw blood israther broadly defined, and a person can be qualified simply by edu-cation, training, or experience.4

17

By Patrick T. Barone and Jeffery S. Cramptonrunk driving cases involving blood draws are considerablymore complicated to litigate than are those involving breathtesting. While the attorney is confronted with a test resultD that is usually more reliable than with breath, the founda-tional requirements are considerably more substantial. The testingproc-ss is not infallible, and understanding this process is critical if the de-

fense attorney hopes to appropriately represent a blood draw client. Thisarticle will present an overview of the typical blood draw case, fromtheblood draw through the actual testing.

Most blood is drawn after the client has refused to offer a breathsample, and a court has authorized a warrant. Thus the warrant andafi-davit in support should be examined to determine if they are properlysupported by probable cause. What evidence is there to support the po-lice oficer's conclusion that your client was intoxicated? Under limitedcircumstances it may be appropriate to file a motion to quash the war-rant, such as when the warrant is based on insuficient probablecause.'Keep in mind, however, that in the context of a drunk driving case, awarrant for blood may be supported entirely by the results of a prelimi-nary breathtest.2

The next area of inquiry is the blood draw itself. Michigan law in-dicates that only a licensed physician, or an individual operatingIT under the delegation of a licensed physician, who is qualified to with-draw blood and is acting in a medical environment, may withdrawblood at a peace officer's request to determine the amount of alcoholin a person's blood.3 However, the phrase "qualified to draw blood" is7 rather broadly defined, and a person can be qualified simply by edu-L,cation, training, or experience.4

17

Document hosted at



3/5

18

M

ICH

IGAN

BARJ

O

URNAL

o

AUGUS

T2003

BLO

O

D

ALCO

HO

LTESTIN

G As with breath testing, there are administrative rules that coverblood testing.5 These rules cover how the test results should be ex-pressed, the acceptable techniques for blood testing, the calibrationof the test equipment, and the collection and handling of the blood.

Additionally, the state police lab promulgates its own rules for blood

testing. These rules can be obtained by sending a Freedom of Infor-mation Act request to the state police laboratory in Lansing. All ofthe applicable rules should be reviewed to determine if there are anydefects that could affect the foundational requirements.

Case law also indicates that the party seeking introduction mustshow (1) that the blood was timely taken, (2) from a particularidentified body, (3) by an authorized licensed physician, medicaltechnologist, or registered nurse designated by a licensed physician,(4) that the instruments used were sterile, (5) that the blood taken

was properly preserved or kept, (6) and labeled, and (7) if trans-ported or sent, the method and procedures used therein, (8) themethod and procedures used in conducting the test, and (9) thatthe identity of the person or persons under whose supervision the

tests were conducted is established.6The type of swab used to disinfect the draw site is also an im-

portant issue. The state police kit contains a non-alcohol swab,and it should be determined whether or not this swab was used.The kit also contains two grey-stoppered vials, and these containsodium fluoride, a preservative used to prevent coagulation andneo-generation of alcohol. It should also be determined whether ornot the proper vials were used, and the expiration date of the kit it-self. Some of this information can be obtained in the defendantsfirst discovery demand, but a thorough examination of these factsand issues usually requires an evidentiary hearing.7 If the casebeing defended is a felony, then the appropriate inquiry can takeplace at the preliminary examination, as long as defense counselhas made a timely request for the laboratory technicians appear-ance at the preliminary examination.8

Chain of EvidenceAs with all evidence collected by the authorities, the prosecutor

must show a proper chain of evidence. In other words, the pros-ecutor must show that the blood that was tested was the sameblood that left the defendants arm. In Michigan, the state policeprovide a blood draw kit, which is essentially a box containingeverything necessary for a proper blood draw. After the sample iscollected, the blood is usually sent by mail to the state police labora-tory for testing.

Look at the labeling of the specimen and make sure everythingwas coded and labeled correctly. It should also be noted that thevials contained in the blood draw kits are sealed with vacuum stop-pers. It would therefore be very easy to introduce ethanol throughthe stopper, and such tampering would not be visible from a simplevisual examination of the vials themselves. The administrative rulesrequire that the vials be sealed in a way that ensures their integ-rity, but unlike other states, police officers in Michigan will onlyseal the box containing the subjects blood. The vials themselves arenot sealed.

Integrity of the Blood SampleWhat was the condition of the blood when it reached the lab?

it possible for coagulation to have occurred? If so, then it is also posible that there was the neo-generation of alcohol through microbfermentation. When human blood decomposes, naturally occurri

microbes can change the sugars in the blood into alcohol. This is tsame type of fermentation that occurs in the manufacture of beveage alcohol. It is possible for the state police laboratory to dete

whether this has occurred by analyzing the level of glucose in tsubject sample, or to examine the ratio of ethanol to carbon dioxiin the headspace gas. This is not done in Michigan.

See if there is any indication of the condition of the sample aftit reached the lab, but before it is tested. Did the technician noany coagulation of the sample? This might occur with an expirkit, or if the person who drew the blood did not gently tip the vback and forth to mix the anti-coagulant with the sample. If thsample was coagulated, then was the sample centrifuged prior testing? If so, then this probably resulted in a false high result, bcause only the liquid portion of the blood was tested, rather th

whole blood complete with its cellular material. If neo-generationethanol is suspected, then glucose levels in the blood sample shoube tested by an independent lab to determine the ratio of ethanolcarbon dioxide.

If the blood was not tested by the state police lab, but instewas tested by a local hospital, then it is likely that serum rather thwhole blood testing was performed. The scientific literature sugests that this can cause a reading that is 11 percent to 20 percetoo high. If the sample is close to the per se limit, then this analy

Fast Facts: The administrative rules require that vials of

blood be sealed in a way that ensures theirintegrity, but unlike other states, police officersin Michigan will only seal the box containingthe subjects blood, not the vials.

When human blood decomposes, naturallyoccurring microbes can change the sugars inthe blood into alcohol.

The administrative rules regarding bloodtesting cover how the test results should beexpressed, the acceptable techniques forblood testing, the calibration of the testequipment, and the collection and handlingof the blood.

As with breath testing, there are administrative rules that coverblood testing.5 These rules cover how the test results should be ex- What was the condition of the blood when it reached the lab?pressed, the acceptable techniques for blood testing, thecalibration it possible for coagulation to have occurred? If so, then it is also poof the test equipment, and the collection and handling of theblood. sible that there was the neo-generation of alcohol through microbAdditionally, the state police lab promulgates its own rules forblood fermentation. When human blood decomposes, naturallyoccurringesting. These rules can be obtained by sending a Freedom ofInfor- microbes can change the sugars in the blood into alcohol. This itheation Act request to the state police laboratory in Lansing. All of same type of fermentation that occurs in the manufacture ofbever-he applicable rules should be reviewed to determine if there are any age alcohol. It is possible for the state police laboratory to detedefects that could afect the foundational requirements. whether this has occurred by analyzing the level of glucose in thCase law also indicates that the party seeking introduction must subject sample, or to examine the ratio of ethanol to carbondioxidehow (1) that the blood was timely taken, (2) from a particular in the headspace gas. This is not done inMichigan.dentified body, (3) by an authorized licensed physician, medical See if there is any indication of the condition of the sampleafterechnologist, or registered nurse designated by a licensed physician, it reached the lab, but before it is tested. Did the technician no(4) that the instruments used were sterile, (5) that the blood taken any coagulation of the sample? This might occur with an expirewas properly preserved or kept, (6) and labeled, and (7) if trans- kit, or if the person who drew the blood did not gently tip the vported or sent, the method and procedures used therein, (8) the back and forth to mix the anti-coagulant with the sample. If thmethod and procedures used in conducting the test, and (9) that sample was coagulated, then was the sample centrifuged prior the identity of the person or persons under whose supervision the testing? If so, then this probably resulted in a false high result, btests were conducted is established. cause only the liquid portion of the blood was tested, rather thaThe type of swab used to disinfect the draw site is also an im- whole blood complete with its cellular material. If neo-generationofortant issue. The state police kit contains a non-alcohol swab, ethanol is suspected, then glucose levels in the blood sampleshouldnd it should be determined whether or not this swab was used. be tested by an independent lab to determine the ratio of ethanotohe kit also contains two grey-stoppered vials, and these contain carbon dioxide.sodium fluoride, a preservative used to prevent coagulation and If the blood was not tested by the state police lab, but insteaneo-generation of alcohol. It should also be determined whether or was tested by a local hospital, then it is likely that serum ratherthanot the proper vials were used, and the expiration date of the kit it- whole blood testing was performed. The scientific literature suself. Some of this information can be obtained in the defendant's gests that this can cause a reading that is 11 percent to 20 percefirst discovery demand, but a thorough examination of these facts too high. If the sample is close to the per se limit, then thisanalysisnd issues usually requires an evidentiary hearing? If the casebeing defended is a felony, then the appropriate inquiry can takeplace at the preliminary examination, as long as defense counselhas made a timely request for the laboratory technician's appear-ance at the preliminary examination.8

As with all evidence collected by the authorities, theprosecutormust show a proper chain of evidence. In other words, the pros-Fast Facts:

ecutor must show that the blood that was tested was the sameblood that left the defendant's arm. In Michigan, the state police The administrative rules require that vials ofprovide a blood draw kit, which is essentially a box containing blood be sealed in a way that ensures theireverything necessary for a proper blood draw. After the sample is integrity, but unlike other states, police officerscollected, the blood is usually sent by mail to the state police labora- in Michigan will only seal the box containingtory for testing. the subject's blood, not the

vials.ook at the labeling of the specimen and make sureeverythingwas coded and labeled correctly. It should also be noted that the When human blood decomposes, naturallyvials contained in the blood draw kits are sealed with vacuum stop- occurring microbes can change the sugarsiners. It would therefore be very easy to introduce ethanol through the blood into alcohol.the stopper, and such tampering would not be visible from asimplevisual examination of the vials themselves. The administrative rules The administrative rules regarding bloodrequire that the vials be sealed in a way that ensures their integ- testing cover how the test results shouldbeity, but unlike other states, police oficers in Michigan will only expressed, the acceptable techniquesforeal the box containing the subject's blood. The vials themselves are blood testing, the calibration of thetestotsealed. equipment, and the collection and handlingof theblood.18

Document hosted at



4/5

19

can become crucial. Ifserum blood was tested,then it should be deter-mined whether or not ahematocrit, which meas-

ures the ratio of the vol-ume of packed red bloodcells to the volume of

whole blood was run onthe subjects blood. Thehematocrit ratio permitsa more accurate conver-sion of the test resultfrom the serum level tothe necessary whole blood level.

The Testing ProcedureAs indicated above, there are administrative rules that apply to

the testing procedure. The state police lab has also promulgatedrules that dictate how these tests are to be run. The state police labuses a process known as gas chromatography. Gas chromatography isessentially a function of time and temperature. In running the test,

the sample is first mixed with one of two inter-nal standards, either 1-propanol or t-butanol.Each sample is then tested separately by two dif-ferent chromatograms, and the lab reports thelower of the two results.

Once the sample is diluted, it is then heatedto produce a vapor. The vapor is then passedthrough a glass column. The vapor is then timedand measured as it passes out of (elutes out) theother end of the column. The chromatograph it-self produces a chromatogram, which is a read-out that looks something like an EKG. The peakmeasurement or curve on the chromatograph isthen compared with a calibration curve, and the

amount of blood alcohol is determined by reading where this samplepeak passes over or meets the calibration curve. Defense counselshould make every effort to obtain through discovery both the sub-

ject defendants chromatogram as well as the calibration curve. These

can then be evaluated by the defense expert.There are many other areas of this procedure that are susceptible

to defense challenge. The first is the method by which the gas chro-matograph is calibrated. The glass columns are replaceable, and

As with all evidence collected by

the authorities, the prosecutor

must show a proper chain

of evidence. In other words,

the prosecutor must show that theblood that was tested was

the same blood that left the

defendants arm.

As with all evidence collectedbyan become crucial. If the sample is first mixed with one of two inter-serum blood was tested, the authorities, theprosecutor nal standards, either 1-propanol or t-butanol.then it should be deter- Each sample is then tested separately by two dif-must show a properchainined whether or not a ferent chromatograms, and the lab reports thehematocrit, which meas- of evidence. In otherwords,

lower of the two results.?tiures the ratio of the vol- Once the sample is diluted, it is then heatedthe prosecutor must show thattheme of packed red blood to produce a vapor. The vapor is then passedcells to the volume of blood that was testedwas through a glass column. The vapor is then timedwhole blood was run on and measured as it passes out of (elutes out)thehe same blood that leftthehe subject's blood. The other end of the column. The chromatograph it-hematocrit ratio permits 1-1V defendant'sarm. self produces a chromatogram, which is a read-a more accurate "conver- out that looks something like an EKG. Thepeaksion" of the test result measurement or curve on the chromatograph isfrom the serum level to then compared with a calibration curve, andthehe necessary whole bloodlevel. amount of blood alcohol is determined by reading where this samplepeak passes over or meets the calibration curve. Defense counselshould make every effort to obtain through discovery both thesub-As indicated above, there are administrative rules that apply to ject defendant's chromatogram as well as the calibration curve.Thesethe testing procedure. The state police lab has also promulgated can then be evaluated by the defenseexpert.rules that dictate how these tests are to be run. The state police lab There are many other areas of this procedure that aresusceptibleuses a process known as gas chromatography. Gas chromatography is to defense challenge. The first is the method by which the gaschro-ssentially a function of time and temperature. In running the test, matograph is calibrated. The glass columns are replaceable, and

19

Document hosted at



5/5

20

M

ICH

IGAN

BARJ

O

URNAL

o

AUGUS

T2003

BLO

O

D

ALCO

HO

LTESTIN

G after a period of time become fatigued (fail to produce appropriateresults with known solutions). When a new glass column is insertedfor the first time it must be calibrated, and this requires adjustingthe temperature of the machine.

In other words, the temperature of the chromatograph is ad-

justed to make sure that the column measures a known sampleappropriately. These adjustments are based on running a knownsample containing methanol, ethanol, isopropanol, and acetone,and observing how the column responds at various temperatures.These adjustments are made despite the fact that the now-rescinded

written methods or techniques promulgated by the state policepursuant to the administrative rules9 provided for a column tem-perature of 100 degrees Celsius. This is a salient point because, asindicated above, the analysis is based in part on temperature. Thus,in questioning the person who calibrates the machine, defensecounsel should inquire into the maintenance of the chromato-graph used, particularly as it pertains to the last time the glass col-umn was replaced, what temperature this new column was cali-

brated at when replaced, and at what temperature the subjectsample was analyzed.

Close attention should also be given to the manner in whichthe calibration curve is produced. A common method is to takesamples of known alcohol solutions and run them through thechromatograph, thus producing the calibration curve. The rulespromulgated by the Michigan State Police provide for a seven-point calibration curve. These calibration samples are usually pre-pared in the laboratory and are therefore subject to human error.During cross-examination defense counsel should assess whetherthe laboratory equipment used was properly cleaned both beforeand after testing, and whether it was free from any contaminantssuch as acetone and alcohol.

Additionally, defense counsel should inquire into the method bywhich the ethyl alcohol used to make the calibration samples isstored and handled, and also inquire as to the training and experi-ence of all laboratory personnel involved anywhere in the process.

Alcohols inherent volatility can also cause the calibration samples tobe incorrect if the absolute ethanol used to prepare them is storedimproperly.

Once the calibration curve is produced, its soundness is evalu-ated by running a second set of controls, also produced in the labo-ratory. A negative control of deionized water is also run through thetwo chromatographs. Finally, once the calibration curve is calcu-lated and tested, a known human blood control is analyzed. It is

only after this final calibration and testing procedure is completethat an unknown blood sample can and should be tested.One might argue that the entire calibration procedure turns

on the accuracy of the human blood sample, and therefore, de-fense counsel should include in their discovery demand a requestfor the lot number and accompanying literature for the humanblood control used in testing their clients case. The literatureindicates that the human blood used in these controls is first

washed using a solution containing sodium fluoride, with so-dium azide added as a preservative. The use of washed blood is

itself suspect as alcohol reacts differently in this solution than human whole blood.

There is also a certain amount of error inherent in these puchased samples, and this may be as high as 20 percent. The literture will indicate exactly what this error is for the lot number use

As indicated above, due to the volatility of ethanol, additional errmay occur based on the way the sample is stored.

It appears that the error inherent in the human blood contris in addition to the error inherent in the chromatogram itseThe methods and techniques promulgated by the Michigan StaPolice require that the blood testing be performed on two separachromatograms, and provide for and allow a difference betwethem of up to 0.02 percent. This is essentially a recognition the state police that the machines can be no more than .02 pecent accurate.

Conclusion

When representing a defendant where blood alcohol testinginvolved, it is important to first preserve the blood samples. Morover, it is critical to understand how blood testing is conducted the state police laboratory, and the inherent limitations in the labratorys testing procedure. Only after this information is understocan the practitioner be prepared to file motions to exclude tblood evidence, or, failing that, effectively cross-examine the labortory experts in effort to produce reasonable doubt as to the reliabity of the test results. o

Patrick T. Barone is a sole practitioner devoting his law practice exclusivelydrunk driving defense. He is a general member of the National College fDUI defense, a member of the National Association for Criminal Defense A

torneys and the Criminal Law Section of the State Bar of Michigan. His offis located in Bloomfield Hills, and he appears in courts throughout the state. Hcan be reached at (248) 647-5220, or at http://www.mid3.net.

Jeffery S. Crampton is a litigator with Koernke & Crampton, PC in GraRapids. He concentrates his practice on white-collar criminal defense adrunk driving defense. He is a member of the National Association of Crimnal Defense Lawyers, and the Criminal Defense Attorneys of Michigan organzation. He is the past president of the James Madison College Alumni Assocition. He can be reached at (616) 458-7900, or at http://www.mid3.net.

Footnotes

1. The search warrant statute is found at MCL 780.651 et seq. For a discuss

regarding the sufficiency of a search warrant see, People v Moten, 233 Mich 1(1925); People v Sobczak-Obetts, 463 Mich 687 (2001).

2. See e.g., People v Tracy, 435 Mich 853 (1990).

3. MCL 257.625a(6)(c).

4. MCL 333.16215.

5. Administrative Rule 325.2671 et. seq.

6. People v Cords, 75 Mich App 415, 254 NW2d 911 (1977).

7. See, e.g., People v Krulikowski, 60 Mich App 28, 230 NW2d 190 (1975), MC764.15 and MCL 257.625a.

8. MCL 600.2167a.

9. Administrative Rule 325.2672(3).

after a period of time become fatigued (fail to produce appropriate itself suspect as alcohol reacts differently in this solution thanresults with known solutions). When a new glass column is inserted human whole blood.for the first time it must be calibrated, and this requires adjusting There is also a certain amount of error inherent in these puthe temperature of the machine. chased samples, and this may be as high as 20 percent. Thelitera-In other words, the temperature of the chromatograph is ad- ture will indicate exactly what this error is for the lot number usejusted to make sure that the column measures a known sample As indicated above, due to the volatility of ethanol, additional errappropriately. These adjustments are based on running a known may occur based on the way the sample is stored.sample containing methanol, ethanol, isopropanol, and acetone, It appears that the error inherent in the human blood contrand observing how the column responds at varioustemperatures. is in addition to the error inherent in the chromatogram itseThese adjustments are made despite the fact that the now-rescinded The methods and techniques promulgated by the Michigan Stawritten methods or techniques promulgated by the state police Police require that the blood testing be performed on two separapursuant to the administrative rules9 provided for a column tem- chromatograms, and provide for and allow a difference betweperature of 100 degrees Celsius. This is a salient point because, as them of up to 0.02 percent. This is essentially a recognition indicated above, the analysis is based in part on temperature. Thus, the state police that the machines can be no more than .02 pein questioning the person who calibrates the machine, defense cent accurate.counsel should inquire into the maintenance of the chromato-graph used, particularly as it pertains to the last time the glass col-umn was replaced, what temperature this new column was cali- When representing a defendant where blood alcohol testingbrated at when replaced, and at what temperature the subject involved, it is important to first preserve the blood samples. Morsample wasanalyzed. over, it is critical to understand how blood testing is conducted Close attention should also be given to the manner in which the state police laboratory, and the inherent limitations in thelabo-he calibration curve is produced. A common method is to take ratory's testing procedure. Only after this information isunderstoodamples of known alcohol solutions and run them through the can the practitioner be prepared to file motions to exclude thchromatograph, thus producing the calibration curve. The rules blood evidence, or failing that, efectively cross-examine the laborpromulgated by the Michigan State Police provide for a seven- tory experts in efort to produce reasonable doubt as to thereliabil-oint calibration curve. These calibration samples are usually pre- ity of the test results.dtbared in the laboratory and are therefore subject to human error.During cross-examination defense counsel should assess whether Patrick T. Barone is a sole practitioner devoting his law practice exclusivelythe laboratory equipment used was properly cleaned both before drunk driving defnse. He is a general member of the National Collegeand after testing, and whether it was free from anycontaminants DUI defnse, a member of the Ntional Association fr Criminal Defnse Asuch as acetone andalcohol. torneys and the Criminal Law Section of the State Bar of Mchigan. Hs offAdditionally, defense counsel should inquire into the methodby is located in Bloomfeld Hll, and he appears in courts throughout the state.which the ethyl alcohol used to make the calibration samples is can be reached at (248) 647-5220, or athttp://www.mid3.net.stored and handled, and also inquire as to the training andexperi-nce of all laboratory personnel involved anywhere in theprocess. Jefry S. Crampton is a litigator with Kernke er Crampton, PC in GraAlcohol's inherent volatility can also cause the calibrationsamples to Rapids. He concentrates his practice on white-collar criminal defnse abe incorrect if the absolute ethanol used to prepare them isstored drunk driving defnse. H is a member of the Ntional Association of Crimimproperly. nal Defnse Lawyers, and the Criminal Defnse Attorneys ofMchigan organOnce the calibration curve is produced, its soundness is evalu- zation. He is the past president of the Jmes Madison College Alumni AssocL db d f 1 1 d d: h lb tion. He can be reached at (616) 458-7900, or at http://www midi. netAate by runnig a sewn set o contro s, a so pro ucein t e a o-ratory. A negative control of deionized water is alsorun through thetwo chromatographs. Finally, once the calibration curve is calcu-U lated and tested, a known human blood control is analyzed. It is 1. The search warrant statute is found at MCL 780.651 et seq. For a discussi0 only after this final calibration and testing procedure is complete regarding the sufficiency of a search warrant see, People v Moten, 233 Mich 1R that an unknown blood sample can and should be tested. (1925); People v Sobczak-Obetts, 463 Mich 687 (2001).

A One might argue that the entire calibration procedure turns 2. See e.g., People v Tracy 435 Mich 853 (1990).B on the accuracy of the human blood sample, and therefore, de- 3. MCL 257625a(6)(e).N fense counsel should include in their discovery demand a request 4. MCL 333.16215.A 5. Administrative Rule 325.2671 et. seq.Gfor the lot number and accompanying literature forthe human 6. People v Cords, 75 Mich App 415, 254 NW2d 911 (1977).blood control used in testing their client's case. The literature 7. See, e.g., People v Krulikowski, 60 Mich App 28, 230 NW2d 190 (1975), MH indicates that the human blood used in these controls is first 764.15 and MCL 257625a.I washed using a solution containing sodium fuoride, with so- 8. MCL 600.2167a.dium azide added as a preservative. The use of washed blood is 9. Administrative Rule 325.2672(3).20

Document hosted at


alcohol blood testing

Documents