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more demanding, than some interstate trucking routes. Yet, none of these states report problems with drivers with insulin-treated diabetes.

The successful federal experience with commercial drivers with insulin-treated diabetes provides even more support for overturning the blanket-ban. In 1993, the Federal Highway Administration embarked on an effort to evaluate the safety of commercial drivers with insulin-treated diabetes. In 1996, the FHWA released the results of the waiver programs:

The data have shown that the driving performance of this group of waived drivers was and continues to be better than the driving performance of all CMV drivers collectively... (Federal Register, Monday, January 8, 1996)

At the conclusion of the program, the accident rate for drivers with diabetes in situations in which one vehicle was towed from the scene was 0.783. The national rate was 0.911. The accident rate for the group with diabetes was lower than the national rate and none of the accidents involving the drivers with diabetes was attributed to the driver’s diabetes.

The FHWA subsequently granted grandfather rights to the drivers allowing them to continue to operate across state lines. Before the FHWA took this action, the agency received hundreds of positive comments regarding the diabetes program. A letter from the New Jersey Department of Transportation in support of grandfathering the drivers summarize the success of the program:

Our experience with these drivers is that, with high awareness of their unique circumstances, they are both especially careful as drivers and notably responsive to the requirements placed on them.

The experiences of the states demonstrates that people with insulin-treated diabetes can be safe operators of commercial vehicles, and should not unduly be denied economic opportunities.

A Strong, Workable Protocol Supports Safety

The Association does not believe that people with diabetes should be automatically deemed fit for the rigors that accompany operating a commercial motor vehicle. Rather, the Association supports a stringent federal protocol that ensures that those people who drive commercial vehicles are medically fit, that they adhere to a rigorous protocol to monitor their disease while operating a commercial motor vehicle, and that they follow tough accountability measures to ensure compliance. The Association believes, with one notable

exception that will be described later, that the proposed protocol is medically sound. establishing very strict eligibility criteria, the Administration is ensuring a high-threshold safe and serious candidates.

By for

The Association supports the medical screening criteria in the proposed protocol to the extent that it is based on medical science. Among other criteria, the protocol would automatically disqualify any candidate who has had a recurrence of hypoglycemic reactions resulting in impaired cognitive functions or loss of consciousness, any candidate who has


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