In Belcher v. Ohio State Racing Comm., 10th Dist. No. 03AP-786, 2004 Ohio 1278, the appellant (a trainer) challenged the toxicology report as being inadmissible hearsay because Dr. Sams had no personal knowledge as to what occurred during testing, did not qualify as custodian of records, and indicated he only "assumed" appropriate procedures were followed. This court rejected that argument, explaining: Administrative agencies are not strictly bound by rules of evidence. Even if the hearsay rule were strictly applied, Dr. Sams' testimony would qualify as an exception under Evid.R. 803(6), because he testified as to a report kept in the course of regularly conducted business, and appellant failed to present substantial credible evidence that the laboratory procedures utilized, and the results obtained, were not trustworthy. As a result, Dr. Sams was qualified to testify regarding the business record and did not need to have personally performed the lab work. Id. at P12.