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Docket No. FMCSA-2005-23151

Comments of the American Diabetes Association

The American Diabetes Association (“Association”) submits these comments in response to the March 17, 2006 Advance Notice of Proposed Rulemaking by the Federal Motor Carrier Safety Administration (FMCSA) regarding its proposal to amend the medical qualifications standards contained in Part 391 of the Federal Motor Carrier Safety Regulations (FMCSRs) to allow the operation of commercial motor vehicles in interstate commerce by drivers with insulin-treated diabetes mellitus. The Association offers these comments on the thirteen areas identified by FMCSA for information and response.

The American Diabetes Association

The Association is a nationwide, nonprofit, voluntary health organization founded in 1940. It consists of people with diabetes, health professionals who treat people with diabetes, research scientists, and other concerned individuals. With over 400,000 general members, over 17,000 health professional members and over 3 million contributors, the Association is the largest non-governmental organization that deals with the treatment and impact of diabetes. The Association establishes, reviews, and maintains the most authoritative and widely followed clinical practice recommendations, guidelines, and standards for the treatment of diabetes.1 The Association also publishes the most authoritative professional journals concerning diabetes research and treatment.2

The mission of the Association is to prevent and cure diabetes and to improve the lives of all people affected by diabetes. This mission requires supporting a system that provides rigorous safety standards to protect commercial drivers with diabetes and the public, while not unduly denying people with diabetes the same rights granted to other Americans.


The Association has long advocated for FMCSA to adopt a program whereby each person with insulin-treated diabetes is afforded an individual assessment of his or her ability to be a commercial driver. Starting with the establishment of the Diabetes Exemption Program in 2003, important strides have been made to ensure that individuals with insulin-treated


American Diabetes Association: Clinical Practice Recommendations 2006, Diabetes Care 29: Supp. 1 (2006).

2 The Association publishes four professional journals with widespread circulation: (1) Diabetes (original scientific research about diabetes); (2) Diabetes Care (original human studies about diabetes treatment); (3) Clinical Diabetes (information about state-of-the-art care for people with diabetes); and (4) Diabetes Spectrum (review and original articles on clinical diabetes management).

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