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their support for eliminating the blanket ban is quite notable. Submissions in support of an individual assessment and/or expressing concern with the proposed three-year requirement came from private citizens, industry associations, unions, Members of Congress, state Department of Motor Vehicles administrators, and government agencies including the Department of Justice and the Equal Employment Opportunity Commission.

By the Association’s analysis, to date the Department of Transportation (DOT) received comments from nearly 300 individuals or organizations. Among this group of comments,

only 10 (about 3%) expressed opposition to the comments (195) expressed opposition to the

rule. Significantly, nearly two-thirds of

proposed

three-year

rule.

Based

on

the the

comments received to date, it is clear assessment of people with insulin-treated interstate commerce.

that the diabetes

general public supports who wish to obtain a CDL

an to

individual operate in

The Expert Medical Panel Letter

It has been the Association’s contention that the three-year rule is not based on the current medical practice of diabetes management. Therefore, it is important to note the inclusion of a letter that was submitted to the public docket by the four physicians who were selected by the Department of Transportation to serve on the Medical Advisory Panel as part of the agency’s 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”). In their comment, the physicians who served on the agency’s own Medical Advisory Panel outlined their objections to the three-year rule, noting that the “three year requirement is simply unsupported by the science of diabetes management and control.” The physicians wrote:

As members of the Expert Medical Panel, we specifically discussed the minimum period of insulin use for a commercial driver before being qualified to drive. As indicated on p. 43 of the Report, we agreed that a period of one month would be sufficient for a driver with type 2 diabetes who was converting to insulin use, and a period of two months would be sufficient for a person who is newly diagnosed with type 1 diabetes.

Medically Unnecessary Requirement Causes Undue Economic Hardship

The current blanket prohibition causes economic hardship by creating job loss once a commercial motor vehicle operator with diabetes commences insulin use. The Association has heard from its members about a common situation: a seasoned driver with type 2 diabetes who has established a livelihood driving a commercial vehicle in interstate commerce is advised to go on insulin by his or her physician. The driver then faces a choice: go on insulin and lose your job, or don’t go on insulin.

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