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The Association strongly disagrees with those who dismiss the experience of intrastate

operators

as

irrelevant

to

interstate

commercial

operations.

Distances

traveled

within

Oregon, for example, can match or exceed distances transport. Road mileage sometimes exceeds 500 miles, as a trip from Baltimore, Maryland to Detroit, Michigan,

traveled in interstate commercial a distance which is about the same which includes travel in five states.

Oregon reported that commercial drivers as

their commercial drivers with insulin-treated diabetes are safer than a whole. The preventable accident rate per million miles traveled was

0.59 for commercial drivers with insulin-treated diabetes commercial drivers. In fact, many other large states also drivers with insulin-treated diabetes, but none of these commercial drivers with insulin-treated diabetes.14

as opposed to 0.75 for all license qualified commercial states report problems with

Cynical Views of People with Diabetes

The experience of the states, combined with the federal waiver programs in both commercial motor vehicles and aviation, demonstrates that fears about people with insulin- treated diabetes are rooted in misconceptions and outdated medical science. The Association has made it a priority to fight misinformation about diabetes and discriminatory views of people with diabetes, and, as such, is concerned about the cynical generalizations about people with diabetes found in several comments in the public docket.

The negative assertions regarding insulin-treated commercial drivers are wholly based on conjecture. According to these few comments, people with insulin-treated diabetes who are, or would be, commercial drivers:

¾ Cannot comply with the “rigors...and inherent danger of interstate driving.”

¾ Are unable to adjust their food and insulin intake to account for unexpected exertion.

¾ Lack the ability to “determine which foods are appropriate for their dietary needs, or accurate serving amounts.”

¾ “…will do their best to hide any [hypoglycemic] episodes.”

14 The current system also perpetuates geographic discrimination by prohibiting drivers in many parts of the East Coast from doing even short haul driving which, because of the size of states and the proximity of major cities to nearby states, often encompasses travel through several jurisdictions. For example, a half-hour trip in the Metropolitan Washington, DC area can include travel in three jurisdictions.

9

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