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¾ Will “choose to erase hypoglycemic blood sugar measurements if they feel their employment would be threatened by [the records from their blood glucose monitor].”15

¾ “…with low blood sugar would often decide to drive anyway because of job demands.”

¾ Would actually attempt to check their blood glucose levels while driving

a commercial vehicle as opposed to pulling over at a rest stop and doing this procedure – which takes less than a minute to perform.

These generalizations assume the worst about people with insulin-treated diabetes.16

They

assume drivers with diabetes have no incentive to maintain safety for themselves and for others on the road. Such remarks also fail to take into account the explosion of advances in diabetes self-management techniques and tools over the last 15 years. The fact is that there are many people with insulin-treated diabetes who are more than capable of handling the responsibilities of commercial driving and other physically demanding occupations. For many people with insulin-treated diabetes, the only barriers they face on the job are those imposed by people and organizations that base their actions on stereotypes and misconceptions about diabetes management today.

Exemption Program Provides Limited Protections

The Association believes the change from a blanket ban to an individual assessment should take the form a change in the driver qualification standards themselves, rather than through an exemption program. This is consistent with the legislative mandate by Congress on this issue. It also is warranted by the data in the FMCSA’s Report to Congress on this issue, and is necessary for consistency with our Nation’s civil rights laws. The proposed protocol would have a dramatic impact both on potential commercial drivers and on thousands of people in professions beyond the commercial motor vehicle industry, and the Association strongly urges the Department of Transportation to change the driver qualification standards themselves.

Conclusion

15 Contrary to such assertions, standard blood glucose meters do not erase information, even if actions such as removing the battery are taken. Moreover, the proposed FMCSA protocol requires drivers to submit this information to their physicians on a quarterly basis.

16 Similarly, one comment assumes the worst about employers arguing that “It seems unlikely that . . . employers would let [insulin-treated drivers] take all the time necessary to check, recheck, and take corrective measures.” The Americans with Disabilities Act would require such easily accomplished accommodations. Moreover, the Association believes most employers would be quite willing to accommodate their employees’ needs. In fact, one comment submitted to the docket was from a company that was willing to pay a fine rather than terminate one of its drivers with insulin-treated diabetes because the company knew how valuable and capable the driver was.

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