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Virginia, themselves caution against using the results of their studies to limit or restrict commercial driving by individuals with insulin-treated diabetes.

After exhaustive study, the conclusion has been – correctly – reached that safe commercial driving and insulin-treated diabetes are not exclusive. The Association urges FMCSA not to revisit this conclusion, but rather, to refine the process of individually assessing and certifying medically qualified insulin-treated drivers by developing a system that retains the safety of the current system but that provides for a practical method to achieve individual assessment.

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How many individuals with ITDM are likely to enter the motor carrier

occupation if the current medical standards are changed to allow them to drive in interstate commerce?

The Association does not have empirical data to answer this question, but believes that despite the progress made in recent years with the inception of the Diabetes Exemption Program, current regulations discourage many qualified individuals with insulin-treated diabetes from pursuing a career operating commercial motor vehicles. The Association has received inquiries from hundreds of individuals regarding commercial driving, the vast majority of whom are affected by the physical qualification rules regarding insulin-treated diabetes. As stated above, the Diabetes Exemption Program has allowed an extremely small number of individuals with insulin-treated diabetes to drive CMVs but comes with the consequence of many months waiting for a decision by FMCSA – time most drivers cannot afford to spend out of work, without pay or health insurance coverage. It is the Association’s experience, gained from speaking with many drivers facing the need to obtain an exemption because of insulin use, that a large number of qualified individuals do not even apply for exemptions because of the problems associated with, and the uncertainty that accompanies, the current burdensome process.

The number of people with diabetes is growing at an alarming rate. There are now more than 21 million people with diabetes in the United States,46 the vast majority of whom have type 2 diabetes. Diabetes affects all parts of the population, including commercial drivers. FMCSA has already seen a large increase in the number of individuals applying for a diabetes exemption since passage of SAFETEA-LU last summer, numbers which have overwhelmed the agency’s resources and ability to process exemption applications in a timely manner.47 Thus, unless significant additional resources are provided to FMCSA, the current exemption program does not have the means to fulfill its own requirements. Moreover, for the reasons set out in this comment, an exemption program is not the best method of assessing individuals with ITDM for safe commercial driving.

46

See Centers for Disease Control and Prevention, National Diabetes Fact Sheet (Oct. 2005).

47 See Qualification of Drivers; Eligibility Criteria and Applications; Diabetes Exemption, 70 Fed. Reg. 67777 (Nov. 8, 2005) (stating that “in the 2003 Notice, FMCSA estimated that approximately 700 applications for exemption would be filed annually . . . The number of applications actually filed has been substantially less. However, with the changes made in the exemption program by this revised Notice, the number of applications could increase substantially, and may approximate, at least initially, the level estimated in 2003.”).

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