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Accordingly, the Association supports most aspects of the proposed protocol including the very stringent assessment to determine if a person is medically qualified to drive a commercial motor vehicle, the specific requirements for monitoring and driving, and the ongoing need for intense medical monitoring. The proposed program, however, fails to achieve the goal of setting up a practicable protocol for individual assessment by unnecessarily including a requirement that applicants must have driven a commercial motor vehicle while using insulin for the three years immediately preceding an application.

In addition, the change from a blanket ban to an individual assessment should take the form of a rulemaking to change the driver qualification standards themselves, rather than through an exemption program. This is consistent with the legislative mandate by Congress on this issue. This also is warranted by the data in the FMCSA’s Report to Congress on this issue,1 and is necessary for consistency with our Nation’s civil rights laws.

A workable protocol based on current medical science would benefit people with diabetes through increased employment opportunities and benefit industry through an increased labor supply. It would be safe, and it would be fair.

The American Diabetes Association

The Association is a nationwide, nonprofit, voluntary health organization founded in 1940. It consists of people with diabetes, health professionals who treat people with diabetes, research scientists, and other concerned individuals. With over 400,000 general members, over 17,000 health professional members and over 3 million contributors, the Association is the largest non-governmental organization that deals with the treatment and impact of diabetes. The Association establishes, reviews, and maintains the most authoritative and widely followed clinical practice recommendations, guidelines, and standards for the treatment of diabetes.2 The Association also publishes the most authoritative professional

journals concerning diabetes research and treatment.3

The mission of the Association is to prevent and cure diabetes and to improve the lives of all people affected by diabetes. This mission requires supporting a system that provides rigorous safety standards to protect commercial drivers with diabetes and the public, while not unduly denying people with diabetes the same rights granted to other Americans.

1 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) (hereafter “Report to Congress”).

2 American Diabetes Association: Clinical Practice Recommendations 2001, Diabetes Care 24: Supp. I


3 The Association publishes five professional journals with widespread circulation: (1) Diabetes (original scientific research about diabetes); (2) Diabetes Care (original human studies about diabetes treatment); (3) Clinical Diabetes (information about state-of-the-art care for people with diabetes); (4) Diabetes Reviews (invited reviews on selected topics for research-oriented health professionals); and (5) Diabetes Spectrum (review and original articles on clinical diabetes management).


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