scary or exciting, or by pricking themselves with a pointed object concealed somewhere on the body. in this way the results will not show a significant reaction to any of the relevant questions. use law enforcement agencies and intelligence agencies in the united states are by far the biggest users of polygraph technology. in the united states alone most federal law enforcement agencies either employ their own polygraph examiners or use the services of examiners employed in other agencies. in 1978 richard helms, the eighth director of central intelligence, stated: we discovered there were some eastern europeans who could defeat the polygraph at any time. americans are not very good at it, because we are raised to tell the truth and when we lie it is easy to tell we are lying. but we find a lot of europeans and asiatics can handle that polygraph without a blip, and you know they are lying and you have evidence that they are lying. susan mccarthy of salon said in 2000 that "the polygraph is an american phenomenon, with limited use in a few countries, such as canada, israel and japan." canada in canada, the 1987 decision of r v béland, the supreme court of canada rejected the use of polygraph results as evidence in court, finding that they were inadmissible. the polygraph is still used as a tool in the investigation of criminal acts and sometimes employed in the screening of employees for government organizations. in the province of ontario, the use of polygraphs by an employer is not permitted. a police force does have the authorization to use a polygraph in the course of the investigation of an offence. united states brochure of the defense security service (dss) about polygraph testing demonstrating the administration of the polygraph, the polygrapher making notes on the readouts. 1970s in 2018, wired magazine reported that an estimated 2.5 million polygraph tests were given each year in the united states, with the majority administered to paramedics, police officers, firefighters, and state troopers. the average cost to administer the test is more than $700 and is part of a $2 billion industry. in 2007, polygraph testimony was admitted by stipulation in 19 states, and was subject to the discretion of the trial judge in federal court. the use of polygraph in court testimony remains controversial, although it is used extensively in post-conviction supervision, particularly of sex offenders. in daubert v. merrell dow pharmaceuticals, inc. (1993), the old frye standard was lifted and all forensic evidence, including polygraph, had to meet the new daubert standard in which "underlying reasoning or methodology is scientifically valid and properly can be applied to the facts at issue." while polygraph tests are commonly used in police investigations in the us, no defendant or witness can be forced to undergo the test unless they are under the supervision of the courts. in united states v. scheffer (1998), the us supreme court left it up to individual jurisdictions whether polygraph results could be admitted as evidence in court cases. nevertheless, it is used extensively by prosecutors, defense attorneys, and law enforcement agencies. in the states of rhode island, massachusetts, maryland, new jersey, oregon, delaware and iowa it is illegal for any employer to order a polygraph either as conditions to gain employment, or if an employee has been suspected of wrongdoing. the employee polygraph protection act of 1988 (eppa) generally prevents employers from using lie detector tests, either for pre-employment screening or during the course of employment, with certain exemptions. as of 2013, about 70,000 job applicants are polygraphed by the federal government on an annual basis. in the united states, the state of new mexico admits polygraph testing in front of juries under certain circumstances. in 2010 the nsa produced a video explaining its polygraph process. the video, ten minutes long, is titled "the truth about the polygraph" and was posted to the website of the defense security service. jeff stein of the washington post said that the video portrays "various applicants, or actors playing them—it’s not clear—describing everything bad they had heard about the test, the implication being that none of it is true." antipolygraph.org argues that the nsa-produced video omits some information about the polygraph process; it produced a video responding to the nsa video. george maschke, the founder of the website, accused the nsa polygraph video of being "orwellian". the polygraph was invented in 1921 by john augustus larson, a medical student at the university of california, berkeley and a police officer of the berkeley police department in berkeley, california. the polygraph was on the encyclopædia britannica 2003 list of greatest inventions, described as inventions that "have had profound effects on human life for better or worse." in 2013, the us federal government had begun indicting individuals who stated that they were teaching methods on how to defeat a polygraph test. during one of those investigations, upwards of 30 federal agencies were involved in investigations of almost 5000 people who had various degrees of contact with those being prosecuted or who had purchased books or dvds on the topic of beating polygraph tests. india in 2008, an indian court adopted the brain electrical oscillation signature profiling test as evidence to convict a woman who was accused of murdering her fiancé. it was the first time that the result of polygraph was used as evidence in court. on may 5, 2010, the supreme court of india declared use of narcoanalysis, brain mapping and polygraph tests on suspects as illegal and against the constitution if consent is not obtained and forced. article 20(3) of the indian constitution states: "no person accused of any offence shall be compelled to be a witness against himself." polygraph tests are still legal if the defendant requests one. israel the supreme court of israel, in civil appeal 551/89 (menora insurance v. jacob sdovnik), ruled that the polygraph has not been recognized as a reliable device. in other decisions, polygraph results were ruled inadmissible in criminal trials. polygraph results are only admissible in civil trials if the person being tested agrees to it in advance. europe in a majority of european jurisdictions, polygraphs are generally considered to be unreliable for gathering evidence, and are usually not used by local law enforcement agencies. polygraph testing is widely seen in europe to violate the right to remain silent.: 62ff in england and wales a polygraph test can be taken, but the results cannot be used in a court of law to prove a case. however, the offender management act 2007 put in place an option to use polygraph tests to monitor serious sex offenders on parole in england and wales; these tests became compulsory in 2014 for high risk sexual offenders currently on parole in england and wales. the supreme court of poland declared on january 29, 2015, that the use of polygraph in interrogation of suspects is forbidden by the polish code of criminal procedure. its use might be allowed though if the suspect has been already accused of a crime and if the interrogated person consents of the use of a polygraph. even then, the use of polygraph can never be used as a substitute of actual evidence. as of 2017, the justice ministry and supreme court of both of the netherlands and germany had rejected use of polygraphs.: 62ff belgium is currently the european country with the most prevalent use of polygraph testing by police, with about 300 polygraphs carried out each year in the course of police investigations. the results are not considered viable evidence in bench trials, but have been used in jury trials.: 62ff in lithuania, "polygraphs have been in use since 1992", with law enforcement utilizing the event knowledge test (a "modification" of the concealed information test) in criminal investigations. australia lie detector evidence is currently inadmissible in new south wales courts under the lie detectors act 1983. under the same act, it is also illegal to use lie detectors for the purpose of granting employment, insurance, financial accommodation, and several other purposes for which lie detectors may be used in other jurisdictions. armenia in armenia, government administered polygraphs are legal, at least for use in national security investigations. the national security service (nss), armenia's primary intelligence service, requires polygraph examinations of all new applicants. security clearances in 1995, harold james nicholson, a cia employee later convicted of spying for russia, had undergone his periodic five-year reinvestigation, in which he showed a strong probability of deception on questions regarding relationships with a foreign intelligence unit. this polygraph test later led to an investigation which resulted in his eventual arrest and conviction. in most cases, however, polygraphs are more of a tool to "scare straight" those who would consider espionage. jonathan pollard was advised by his israeli handlers that he was to resign his job from american intelligence if he was ever told he was subject to a polygraph test. likewise, john anthony walker was advised by his handlers not to engage in espionage until he had been promoted to the highest position for which a polygraph test was not required, to refuse promotion to higher positions for which polygraph tests were required, and to retire when promotion was mandated. in 1983, cia employee edward lee howard was dismissed when, during a polygraph screening, he truthfully answered a series of questions admitting to minor crimes such as petty theft and drug abuse. in retaliation for his perceived unjust punishment for minor offenses, he later sold his knowledge of cia operations to the soviet union. polygraph tests may not deter espionage. from 1945 to the present, at least six americans have committed espionage while successfully passing polygraph tests. notable cases of two men who created a false negative result with the polygraphs were larry wu-tai chin, who spied for china, and aldrich ames, who was given two polygraph examinations while with the cia, the first in 1986 and the second in 1991, while spying for the soviet union/russia. the cia reported that he passed both examinations after experiencing initial indications of deception. according to a senate investigation, an fbi review of the first examination concluded that the indications of deception were never resolved. ana belen montes, a cuban spy, passed a counterintelligence scope polygraph test administered by dia in 1994. despite these errors, in august 2008, the us defense intelligence agency (dia) announced that it would subject each of its 5,700 prospective and current employees to polygraph testing at least once annually. this expansion of polygraph screening at dia occurred while dia polygraph managers ignored documented technical problems discovered in the lafayette computerized polygraph system. the dia uses computerized lafayette polygraph systems for routine counterintelligence testing. the impact of the technical flaws within the lafayette system on the analysis of recorded physiology and on the final polygraph test evaluation is currently unknown. in 2012, a mcclatchy investigation found that the national reconnaissance office was possibly breaching ethical and legal boundaries by encouraging its polygraph examiners to extract personal and private information from us department of defense personnel during polygraph tests that purported to be limited in scope to counterintelligence matters. allegations of abusive polygraph practices were brought forward by former nro polygraph examiners. alternative tests most polygraph researchers have focused more on the exam's predictive value on a subject's guilt. however, there have been no empirical theories established to explain how a polygraph measures deception. a 2010 study indicated that functional magnetic resonance imaging (fmri) may benefit in explaining the psychological correlations of polygraph exams. it could also explain which parts of the brain are active when subjects use artificial memories. most brain activity occurs in both sides of the prefrontal cortex, which is linked to response inhibition. this indicates that deception may involve inhibition of truthful responses. some researchers believe that reaction time (rt) based tests may replace polygraphs in concealed information detection. rt based tests differ from polygraphs in stimulus presentation duration, and can be conducted without physiological recording as subject response time is measured via computer. however, researchers have found limitations to these tests as subjects voluntarily control their reaction time, deception can still occur within the response deadline, and the test itself lacks physiological recording. history earlier societies utilized elaborate methods of lie detection which mainly involved torture.