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and has demonstrated willingness to properly monitor and manage his/her diabetes.”18 Patient education is critical to any system for certifying insulin-treated commercial drivers and health care professionals applying a revised diabetes standard should be required to address both the long term complications of diabetes and the patient’s likelihood of experiencing severe hypoglycemia.

It is important to meet all legitimate safety concerns, but to do so by implementing a more effective and efficient system of qualifying insulin-treated drivers. Such a system requires the vital expertise of doctors knowledgeable about diabetes. Accordingly, FMCSA should require physicians experienced in chronic disease management of diabetes to conduct the medical examination of insulin-treated commercial drivers with regard to diabetes-specific issues (with a member of the soon-to-be-developed National Registry of Certified Medical Examiners conducting the rest of the examination, as discussed more fully below).

In order for individuals with insulin-treated diabetes to operate CMVs without an exemption, the diabetes physicians certifying insulin-treated drivers must have medically current and

appropriate diabetes suggests transferring

guidelines many of the

to

follow

concerning

CMV

operation.

The

Association

safety and medical screening, operating, monitoring, and

accountability

provisions

in

the

current

Diabetes

Exemption

Program

to

guidelines

to

be

used by such physicians unnecessary and should

in their review. However, some of these provisions are outdated be revisited during the development of physician guidelines:

or

1. Blood glucose monitors. It is not necessary for the physician to certify the make and model of the individual’s blood glucose monitoring device, as long as the meter has a memory and the physician is able to retrieve recent glucose measurements to be used to evaluate the individual’s diabetes health.19

2. Physician administrative requirements. It is overly burdensome and medically unnecessary to require that the physician evaluating the applicant provide all information on letterhead or with a notarized signature.20

3.

Quarterly

reports. It is

physician

to FMCSA that

hemoglobin

(A1C)

are

in

unnecessary to require quarterly reporting from the the individual’s blood glucose levels and glycosylated an adequate range. Rather, the physician should be

18

Qualification of Drivers; Exemption Applications; Diabetes, 68 Fed. Reg. 52441, 52444 (Sept. 3, 2003).

19 The 2003 Federal Register notice announcing the Diabetes Exemption Program states that individuals who have been issued an exemption must submit certain information from their endocrinologist, including “the make and model of the glucose monitoring device with memory.” See id. at 52442.

20 FMCSA’s application materials state that the endocrinologist must attach a copy of his/her “office letterhead with signature, date, medical license number, and state of issue.” “Exemption Application, Diabetes Standard” available at http://www.fmcsa.dot.gov/documents/safetyprograms/Diabetes/diabetes-exemption-package.pdf (last visited April 28, 2006). At least one applicant was required to have his endocrinologist’s information notarized before submitting it to FMCSA. See Comments of the American Diabetes Association, Docket No. FMCSA-2005-20721 (June 6, 2005) (describing the problems experienced by one applicant to include “requiring that he provide the serial number to his blood glucose meter on his endocrinologist’s letterhead and that every page of information sent be notarized.”).

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