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There are two broad issues that health care providers should consider in determining the ability of an insulin-treated individual to safely operate a commercial motor vehicle: whether the individual has long-term complications of diabetes severe enough to adversely affect driving, and whether the individual is prone to severe hypoglycemia. Evidence of long-term complications that may indicate an individual is not medically qualified for commercial driving include (but are not limited to) severe diabetic peripheral neuropathy with an inability to feel the position of the foot on the pedals, and diabetic retinopathy with documented visual impairment (which would disqualify the individual from CMV operation under separate

vision standards). The second issue – physician knowledgeable about diabetes current exemption program, including a

severe looking review

hypoglycemia – is best at a number of factors of blood glucose logs

predicted by a included in the and history of

hypoglycemia.17 Association would been educated in

Further, the current Diabetes Exemption Program requires, and the expect any new system to include, a requirement that the individual “has diabetes and its management, thoroughly informed of and understands

the procedures which procedures should be

must be followed

followed to monitor and manage his /her diabetes if complications arise” and that the individual “has

and what the ability

17 The comments of the National Transportation Safety Board (NTSB) state that “drivers may not take appropriate action even when they recognize the symptoms of hypoglycemia . . . and it is the very driver who does not recognize such events who presents the greatest risk to public safety.” Comments of the National Transportation Safety Board, Docket No. FMCSA-2005-23151 (June 9, 2006). NTSB misses the mark. Both the current Diabetes Exemption Program and the physician-based system the Association proposes require an extensive individual assessment of a driver’s diabetes health and ability to safely operate a commercial motor vehicle. Not only does the exemption program disqualify individuals with hypoglycemic unawareness, but the medical screening protocols that physicians use in evaluating insulin-treated drivers require a thorough review of daily blood glucose logs. Reviewing logs allows a physician to see if the individual has experienced a low blood glucose level that he or she did not detect.

Similarly, NTSB’s reliance on two accidents involving persons with diabetes (one fatal aviation accident and one tour bus operator accident) is misplaced. Beyond the fact that neither accident was shown to have been caused by hypoglycemia or other diabetes-related complications, both instances involved individuals who had failed to divulge their diabetes to federal regulators and therefore the operators had neither been screened before being licensed nor were they operating under any medically-appropriate diabetes protocols (such as frequent blood glucose monitoring or diabetes management education).

The 2000 Report to Congress addresses the issue of identifying those individuals who are at risk for severe hypoglycemia, stating:

The medical research, however, has shown that not all ITDM individuals are at significant risk for the incapacitation caused by hypoglycemia. Thus, to develop a program that meets the safety standard required, protocols are needed to screen and identify individuals at risk for severe hypoglycemia. The research reviewed indicates that screening can be conducted by examining an ITDM individual’s medical history for evidence of hypoglycemia episodes . . . a feasible program for qualifying ITDM individuals to operate CMVs should include protocols for screening on the history of severe hypoglycemia and hypoglycemia unawareness.

A 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) at 63. The Association expects that this aspect of the exemption program would be transferred to a new diabetes standard and/or physician guidelines.

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