no one could obtain an exemption unless he or she has a glycosylated hemoglobin (A1C) in the range of 7% to 10%.26
An A1C test tells a person what his or her average blood glucose (sugar) level is over the past 2-3 months. It is a useful indicator of diabetes management when used in conjunction with other assessment tools, such as a review of daily blood glucose logs, but cannot be used standing alone to assess an individual’s ability or inability to drive safely. Individuals with an A1C at the low end (below 7%) have very well managed diabetes. These levels are often seen in people with mild diabetes or in people who take very good control of their diabetes, and do not in themselves predict hypoglycemia. High A1C indicates a relatively high blood glucose, the main symptoms of which – excess thirst and urination – do not impair driving.
In fact, FMCSA’s Expert Medical Panel considered whether potential drivers should be required to have a certain A1C level, and specifically rejected this idea. In their letter to Administrator Sandberg and posted on the public docket, FMCSA’s experts said that “a set A1C range doesn’t best identify those people who can be the safest drivers.”27 The group further stated that:
The new minimum level of 7% that has been established is affirmatively harmful to individuals with diabetes. As endocrinologists, our goal is for our patients to have A1Cs below 7% in order to prevent or delay the devastating long-term complications of diabetes . . . the goal for the individual patient is an A1C as close to normal for people without diabetes (<6%) as possible, without significant hypoglycemia . . . It is our expert opinion that, in part because of the many new diabetes management tools that are available, some people can be brought very close to normal levels of blood glucose without significant risk of hypoglycemia. Certainly, most people can reach a goal of <7% without this complication. Such people would make excellent, safe commercial drivers and we can indeed identify these people using other screening criteria in the diabetes exemption program . . . We cannot over- emphasize that requiring A1C >7% goes contrary to everything we have been trying to accomplish over the last couple of decades. This is simply the wrong message for our patients and the wrong message to increase safety on our roads.28
26 See Qualification of Drivers; Eligibility Criteria and Applications; Diabetes Exemption, 70 Fed. Reg. 67777, 67780 (Nov. 8, 2005) (stating that “FMCSA has determined that the appropriate measure of HgA1C to demonstrate stable control of diabetes while using insulin is in the range of 7% and 10%” and “FMCSA will now require submission with the application of only one HgA1C result within the range of ≥7% and ≤10% to meet the minimum period of insulin use requirements.”).
27 Letter from Michael Brennan, George Grunberger, Edward Horton and Christopher Saudek, members of the Expert Medical Advisory Panel, to Annette Sandberg, Administrator, Federal Motor Carrier Safety Administration (Dec. 20, 2005) (available at docket no. FMCSA-2001-9800).