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In summary, the many advances in diabetes supplies and self-management education in the last thirty years have contributed to a much healthier, dynamic population with diabetes. Unfortunately, because of the inclusion of the three-year rule (which will be discussed in more detail later), the proposed rule operates on the assumption that people with diabetes lack the ability to manage their disease and, consequently, to minimize the possibility of hypoglycemia. Any protocol for individual assessment would be a disservice to medical science, people with diabetes, and industry, if it did not reflect the latest advances in medical science and treatment for people with diabetes.

Previous Experiences Prove Drivers with Insulin-Treated Diabetes Are Safe

Commercial drivers with insulin-treated diabetes have proven that they can operate commercial motor vehicles safely. States have achieved great success in licensing commercial drivers who have insulin-treated diabetes for operation in intrastate commerce. Moreover, DOT’s waiver program for individuals with insulin-treated diabetes, which enabled applicants to qualify for operation in interstate commerce in the early to mid 1990’s, also provides strong support for overturning the “blanket-ban” in Part 391.

The Association canvassed all 50 states to determine the status of intrastate commercial driving programs for insulin-treated individuals. Approximately forty states allow some people with insulin-treated diabetes to operate commercial vehicles in intrastate commerce. These states have not reported any problems with drivers with insulin-treated diabetes. Contrary to the proposed federal regulation, in most states there is absolutely no requirement that the applicant for a waiver have a set amount of commercial driving experience while using insulin in order to qualify for a waiver. Nevertheless, the programs have produced safe drivers.

In fact, some states have noted that drivers with insulin-treated diabetes are sometimes safer than other commercial operators. For example, in Kansas, the Transportation Manager for the Kansas Corporation Commission wrote, “[We] are very satisfied with the [diabetes] waiver program... We are not aware of any accidents in which our waiver drivers have been involved. We believe these waiver drivers quite possibly are more careful than the average drivers.”4

Oregon reported that their commercial drivers with insulin-treated diabetes are safer than commercial drivers as a whole. The preventable accident rate per million miles traveled was 0.59 for commercial drivers with insulin-treated diabetes as opposed to 0.75 for all commercial drivers. Even more telling is the applicability of Oregon’s experience to interstate driving. Distances traveled within the state can match or exceed distances traveled in interstate commercial transport. For example, road mileage sometimes exceeds 550 miles, a distance is greater than a trip from Baltimore, Maryland to Detroit, Michigan, which includes travel in five states. Many large states such as Montana, Idaho, Oregon, Wyoming, New York and Pennsylvania also license qualified drivers with insulin-treated diabetes. Given the large size of these states, many of the trips drivers make are as strenuous, if not

4 The Secretary of Transportation in Kansas is E. Dean Carlson, the former Administrator of the FHWA during at least part of the federal diabetes waiver program.


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