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the National Registry medical examiner. Requiring that a diabetes physician first evaluate an individual with insulin-treated diabetes ensures that only those medically qualified individuals – those who meet the revised diabetes standard – are permitted to operate commercial vehicles. This new system will guarantee that individuals with insulin-treated diabetes are individually assessed – a goal of the current Diabetes Exemption Program that has become frustrated by the burdensome administrative requirements.

(6) Each medical examiner has discretion to set the expiration date on a driver’s medical certificate so that it is valid for any period up to 24 months, based on the examiner’s determination of how often a driver needs to be re-examined, such as for a specific health condition (e.g. hypertension). What should the Federal standard maximum period of medical certification be for drivers with ITDM?

The Association feels that the standard maximum period of medical certification for drivers with insulin-treated diabetes should be equal to other drivers who do not have diabetes. Insulin-treated drivers should be able to hold a medical certificate for up to 24 months, unless their diabetes physician identifies a diabetes-specific issue or the medical examiner identifies some other specific health condition affecting commercial driving that requires more frequent consultation. This would be consistent with the current Diabetes Exemption Program, which allows individuals to be granted exemptions for a two-year period.

(7) What changes in health condition of drivers with ITDM (e.g., hypoglycemia-induced incidents) should be reported? What changes in crash/incident data (e.g., each crash) should be reported? Who should be responsible for such reports? To whom should these reports be submitted?

The Association believes that in addition to any reporting requirements applicable to all drivers, any case of severe hypoglycemia (as defined in the revised standards), any motor vehicle accident caused by diabetes, or any significant change in diabetes health status (e.g., incapacitating retinopathy or neuropathy) should be reported. An individual who is involved in a motor vehicle accident should make every attempt to have his or her blood glucose checked and recorded.

Under the current Diabetes Exemption Program, exemption recipients are required to report “all episodes of severe hypoglycemia, significant complications, or inability to manage diabetes” as well as to report “any involvement in an accident or any other adverse event whether or not they are related to an episode of hypoglycemia.” The onus for reporting these things falls squarely on the person granted the exemption rather than the physician, although the physician should learn of these events during the annual evaluation and may include them on reports to FMCSA. Taking the determination of driver qualification out of an exemption program would not change this reporting requirement, as both the individual and his or her physician would be required to report any disqualifying events. This should be done under the same scheme applied to other drivers who have health problems that arise during the two-year certification period.

The Association proposes requiring physician or self-reporting of any incident related to diabetes to the state licensing authority, but eliminating the need to report any involvement in an accident or other adverse event to FMCSA. As required by the FMCSRs, individuals

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