Testing requires scrupulous attention to detail. The expert must maintain impeccable records of his procedures at every point. Memory fails. The expert should write, draw, photograph, videotape or otherwise record all steps of the testing process.

Testing is often a prerequisite to expert testimony. Occasionally, destructive testing must be undertaken.

Steps to follow during destructive testing:

• Consult with attorney and client prior to testing.


• If an opposing party is known, the party should be given notice. This simple step will avoid many potential problems and objections later on.


• If the matter is subject to court or administrative procedures, review and observe rules of the forum.


• Obtain a court or administrative order before destructive tests are undertaken.


• Maintain meticulous documentation. Show precisely what was done, how it was done, and what the findings were. Record the process with photographs or videotape.


• Make sound recordings when appropriate, particularly if results are observed or the process is audible and can be heard.


• Follow the scientific method of preservation: marking, labeling and evaluating to preserve the residue from the test.
• If the process is lengthy, time-lapse photography is an alternative method of recording.

Helpful guidelines for situations where destructive testing is necessary:

• Use documentation.


• Obtain written authorization.


• Use photos or video to record the events.


• Arrange for witnesses to be present.

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