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(12)

The TEA-21 Report to Congress discusses occupational and health risks and

challenges for individuals with ITDM who operate CMVs.

Are

occupational

and

health

risks

and

challenges

the

TEA-21

Report

to

there additional Congress did not

discuss? Are there additional attributes of this occupation, particularly difficult for such drivers to manage their condition?

which may make it Are these attributes

characteristic of certain segments of restricted to operating only in certain short-haul, but not long haul)?

the industry? Should individuals with ITDM be segments of the industry (e.g., driving locally or

There is nothing specifically about commercial driving that is deleterious to the health

individuals

with

diabetes.

There

is

no

medical

basis

for

restricting

commercial

driving

of to

local or short-haul operation for drivers with insulin-treated diabetes. Medically qualified commercial drivers with insulin-treated diabetes are able to perform all aspects of their jobs

while simultaneously managing their developed by their physicians. As we

diabetes noted in

according to the treatment regiment our previous comments, the science of

diabetes management eating and medication drivers with ITDM do hypoglycemia.48

has advanced to such a point that individuals have flexibility in their schedules and are not tied to one particular regimen. Commercial not require operational restrictions in order to avoid debilitating

(13)

What are the potential operational stressors and physical impacts associated

with CMV driving that may adversely impact a CMV operator with ITDM? provide references or available peer-reviewed research data.

Please

There are certain operational stressors and physical impacts associated with CMV driving that affect all drivers, regardless of whether the individual has diabetes. As we noted in previous comments:

An individual with insulin-treated diabetes who is otherwise qualified does not have those same operational limits [as does an individual with a vision impairment]. Under the proposed protocol, such a driver will only be behind the wheel when his or her blood glucose level is within a safe range. There is no difference between that individual’s physical abilities – including how that individual perceives the road and other vehicles – and any other commercial driver. Except for the monitoring and maintenance requirements in the proposed protocol . . . the operation of a commercial vehicle for an individual with insulin-treated diabetes is no different than for anyone else.49

The Association does not feel there are any factors that justify limiting or restricting commercial vehicle operation by physically qualified individuals with insulin-treated diabetes

48 NTSB states in their comments that there must be “strict operational limits to ensure regular meals,” an assertion that demonstrates a lack of understanding about of the science and medicine of current diabetes management. See Comments of the National Transportation Safety Board, Docket No. FMCSA-2005-23151- 48 (June 9, 2006) With the advent of different types of insulin, it is no longer true that all individuals with diabetes must eat at a certain time in order to prevent hypoglycemia.

49

Comments of the American Diabetes Association, Docket No. FMCSA-2001-9800 (Oct. 1, 2001).

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