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the national rate.”42 This FMCSA study examined data from individuals who were driving commercial vehicles in interstate commerce pursuant to the grandfather provision from the prior Federal Highway Administration waiver program, as well as drivers working in intrastate commerce pursuant to state waiver programs, and concluded that “the variety of evidence in this study reveals a compelling picture. Almost without exception, all results point to the driving safety of CMV operators with ITDM.”43 The 2000 Report to Congress also stated that FMCSA’s “most recent risk assessment showed that a reasonably large sample of individuals with ITDM are presently operating CMVs at a safety level not significantly different than a sample of non-diabetic drivers. Moreover . . . drivers with ITDM can operate CMVs at a level of safety that is consistent with the national norm for safety . . . it is possible to screen individuals with ITDM and have them safely operate CMVs.”44

The Association has not identified any studies that link increased efficacy of medication and therapy with risk and incidence of crashes in commercial motor vehicles, and re-emphasizes the conclusions and distinctions noted in our 2002 comments (attached as Exhibit B and incorporated in these comments).45 In those comments, we noted that reliance on certain studies (particularly the original findings of the Diabetes Control and Complications Trial (DCCT), the United Kingdom Prospective Diabetes Study (UKPDS) and a study published in the American Medical Association by Clarke et al.) was misplaced and outdated. Since the data was gathered for the DCCT and UKPDS, diabetes management has progressed such that these studies cannot be relied upon to restrict commercial driving of individuals with

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Further limiting the usefulness of these studies is the fact that their subjects were drawn from the general population of people with diabetes instead of a pool of professional CMV drivers operating under strict protocols; they were often conducted in a controlled environment (in which subjects knew from the outset that they were at no personal risk for continuing to drive under artificial conditions of hypoglycemia); and they do not assess the relative risk of insulin use and commercial driving (e.g., when compared with other medical conditions and the use of even over-the-counter medications). Accordingly, such studies cannot form the basis of further restrictions on this population of commercial drivers. In fact, many of the studies, including several by Daniel Cox and his team from the University of

42 Federal Motor Carrier Safety Administration, A Study of the Risk Associated with the Operation of Commercial Motor Vehicles by Drivers with Insulin-Treated Diabetes Mellitus (FMCSA-PPD-02-001) (2001).

43 Id. at 48. This report also discussed two Canadian studies conducted on a group of 1,307 truck drivers (some with medical conditions and some without) that concluded that “drivers with diabetes did not have significantly more severe accidents than those without the condition.” Id. at 14.

44 A Report to Congress on the Feasibility of a Program to Qualify Individuals with Insulin Treated Diabetes Mellitus to Operate Commercial Motor Vehicles in Interstate Commerce as Directed by the Transportation Equity Act for the 21st Century (July 2000) (available at Docket No. FMCSA-2001-9800).

45

Additional Comments of the American Diabetes Association, Docket No. FMCSA-2001-9800 (Feb. 4, 2002).

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