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control that all diabetes health authorities recommend. FMCSA should not continue to use this medically unjustified criterion in any form or for any purpose and should revise its public documents and application materials to remove any reference to what is an acceptable A1C


Further, no such range should be included in












(4) Should FMCSA allow medical examiners to assume responsibility for making an individual determination of the ITDM driver’s ability to manage this health condition, or should the agency require the physician responsible for treating the driver’s ITDM to certify the driver meets the revised diabetes standard?

As discussed above in response to question 2, the Association believes that a physician knowledgeable in diabetes should be involved in the decision as to whether an individual with insulin-treated diabetes is medically qualified to operate a CMV. Endocrinologists and other physicians who regularly care for patients with diabetes have specialized knowledge of the disease and treatment regimens. The input of these physicians is essential to assess an individual’s diabetes management and determine whether CMV operation is safe and practicable in accordance with the revised standard and accompanying diabetes guidelines.

FMCSA has indicated its plan to establish a National Registry of Certified Medical Examiners (hereafter “National Registry”), a group of medical individuals who will undergo specific training and certification on the licensing of interstate commercial drivers.34 Under FMCSA’s proposal, all individuals seeking DOT certification will need to be examined by a medical examiner on the agency’s registry. The Association supports FMCSA’s plan to improve the certification process by allowing only trained individuals to make determinations regarding fitness to drive. Individuals with diabetes should be required to undergo the same process (requiring certification by a medical examiner on the National Registry), with the exception that the diabetes patient should first be certified by a physician experienced in chronic disease management of diabetes.

(5) Should the agency revise the medical certificate to be issued by the medical examiner to a driver with ITDM to include certification from the “treating physician” in addition to the medical examiner?

The Association supports a two-step certification process whereby a diabetes physician certifies that the individual with insulin-treated diabetes meets the revised diabetes standard, and the National Registry medical examiner completes the certification process with regard to all other aspects not related to diabetes. Under this scenario, the individual with insulin-treated diabetes will first see a diabetes physician to receive a sign off on whether he or she meets the diabetes standard and will bring this part of the certification to

34 See National Registry of Certified Medical Examiners, 71 Fed. Reg. 28912 (May 18, 2006) (stating “the program would be comprised, in part, of a training and testing program that would result in a public registry of certified medical examiners who are authorized to conduct medical examinations of interstate commercial motor vehicle drivers and determine their physical qualifications to operate in interstate commerce . . . Once the program is implemented, FMCSA would accept only medical examinations conducted by medical examiners

listed on the Registry.


certification test, and procedures accreditation standards.”).


program maintain

would require training using the quality of the program

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