Blu-Ray Error

So I've been burning Blu-Rays since January 2010 with Encore without a problem. Nothing has changed in how I'm creating these discs. Always by exporting the media to "MPEG-2: Blu-Ray" settings from Premiere, and then importing them as timelines with their adjacent .wav files once I'm in Encore.
But lately, I'm completely unable to finish the burn. I've still been able to burn DVD's with this drive, so I can't imagine it's a hardware error, though I think it's trying to tell me otherwise. My closest attempt was recently, when the blu-ray burned 12GB out of 16GB. (approx).
Everytime it stops, it gives me a small pop-up window with this exact message, nothing more:
Blu-ray Error: "device error", Code: "3", Note: "
I've tried Googling this error code for more information as it looks like it gets truncated after "Note: " but have found nothing. Does anyone have any advice?
This is all in CS5 btw.
Thanks for your help in advance!

Thanks for the welcome Jeff. I hate to come in under these conditions.
I was figuring it was a device error up until it successfully burned a few DVD's for me. Obviously that doesn't rule it out since it still won't do Blu-Ray discs, but I think you're probably in the right area with your answer about firmware or OS conflicts. I am running this all on a Mac (should have clarified) and I wouldn't be surprised at all to find out that something in the latest batch of updates screwed this up. Rather than running backwards (I don't remember when the last batch was, and it'd take a day or so just filtering through my Time Machine files) I upgraded my copy of Toast to the Blu-Ray capable version 11.
It's going to take a day and a half to download it appears (or 4 hours...bu that feels like an eternity when I need answers). But hopefully this will give me a temporary solve.
Next (related) question: Where would you guess that the issue lies? OSX or CS5? If it's an issue with OSX who would be tapped to fix the problem, Adobe (by creating a patch/update themselves) or OSX, but fixing the error? Not sure since we're dealing in the realm of speculation anyway, but thought it was worth asking. Thanks for your help!

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