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Unfortunately, the proposed protocol would do nothing to alleviate the economic hardship created by this situation. Few such drivers will have employers that have intrastate driving opportunities available – even if the employer were willing to assign the driver to those operations for three years. Thus, the three-year rule ensures that people in this situation will face job loss.

As a result, the medically unnecessary three-year requirement will make the availability of an individual assessment meaningless. The Association believes that a better alternative exists in the recommendations of the physicians on the Expert Medical Panel: a one or two month period where an individual would adjust to insulin use. A one or two month adjustment period would be medically sound and would give those commercial operators who can pass the rest of the strict criteria in the proposed protocol the opportunity to continue to earn a livelihood. Failure to provide a reasonable, medically sound adjustment period would only unnecessarily promulgate economic hardship and disruption.

Opposition to the Proposed Exemption Program is Not Based on Current Medical Management of Diabetes

The Association notes that while there was very little opposition in the public docket to the basic concept of moving from the existing blanket-ban to an individual assessment, those comments opposing individual assessment of drivers with insulin-treated diabetes are filled with inaccuracies and outdated information.

Opposition to the proposed exemption program has two facets: concerns with the studies used or not used by FMCSA, and cynical generalizations about people with diabetes. This opposition bases its opinions on fear and conjecture and ignores scientific advances and data collected by the FMCSA.

DCCT, UKPDS, and Clarke Study Misapplied

The risk attendant to allowing individuals who use insulin to drive commercial vehicles is specifically related to the risk of hypoglycemia occurring during the act of driving with a resultant motor vehicle accident. The reality is that hypoglycemia in patients with insulin- treated diabetes is rare, predictable, and preventable. Opposition to allowing individual assessment of commercial drivers who use insulin is based on limited data from two studies initiated in the early 1980’s, the Diabetes Control and Complications Trial (DCCT) and United Kingdom Prospective Diabetes Study (UKPDS), and a misapplication of the Clarke et al. study from the Journal of the American Medical Association.2

2 Clarke W, Cox D, Gonder-Frederick L, Kovatchev B: Hypoglycemia and the Decision to Drive a Motor Vehicle by Persons with Diabetes. Journal of the American Medical Association 282:750-54 (1999).

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