The preceding article described how simple it is to perform the calibration procedure on the Alcomonitor CC. The procedure requires no skill from the operator; the operator just presses a button.
CFR Part 40.233 (b) (5) states… as the user of an EBT… “You must ensure that inspection, maintenance, and calibration of the EBT are performed by its manufacturer or a maintenance representative certified either by the manufacturer or by a state health agency or other appropriate state agency.” Intoximeters uses the term Factory Authorized Calibration Technician, or FACT, for the certification they issue to BATs who are properly trained and authorized to calibrate an EBT.
When the Part 40 regulations came out a few of us were skeptical that DOT would really require a BAT to be certified as a Factory Authorized Calibration Technician in order to press the calibration button on the Alcomonitor CC. DOT responded to our question by saying there are no exceptions to the regulation requiring certification to perform the calibration procedure, even when the procedure is as simple as pressing a button.
The reality is that our training to certify a BAT as a Calibration Technician on the Alcomonitor CC includes much, much more than which button to press. The training covers calibration theory, the Quality Assurance Plan requirements, and the difference between Calibration Adjustments and Accuracy Checks. We know from our years of training experience that without the knowledge of the difference between an Accuracy Check and a Calibration Adjustment there is a good chance the BAT won’t press the correct buttons on the Alcomonitor CC to perform those procedures, regardless of how skillfully they press the button.