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charged with determining an individual schedule for follow up visits and reporting any problems that would make the individual unable to continue to drive safely during the licensing period.

4.

Employment information.

It is not necessary to collect information about the

applicant’s employer (as required on the current exemption application) since, as a result of SAFETEA-LU, prior commercial driving experience is not required to be

eligible for an exemption.

  • 5.

    Driving record. The requirement that the individual’s driving record contain no involvement in an accident in which the applicant contributed to the cause of the accident is unrelated to that individual’s ability to operate a CMV while using insulin, unless diabetes contributed to the accident, and should be eliminated from physician guidelines except to the extent diabetes is implicated or that such incidents are considered for all drivers.

  • 6.

    Blood glucose range. The Association is concerned that FMCSA has misapplied criteria about blood glucose range in the current exemption program. The current exemption application states that “a CMV driver should not have large fluctuations in blood glucose levels. Drivers should maintain blood glucose levels between 100 to 400 mg/dl prior to and while driving a CMV.”21 This operational criterion was established to ensure that individuals who have received an exemption would not drive if their blood glucose was too low or too high while driving. Instead, FMCSA has included this range in its application materials, implying that an individual must always keep his or her blood glucose within this range in order to be qualified for an exemption. There is no legitimate medical reason to automatically disqualify individuals whose blood glucose logs show some readings below 100 mg/dl or above 400 mg/dl. This criteria should be eliminated from the current application and not be included in any new diabetes standard and/or guidelines. Rather, significant fluctuations in blood glucose should be considered by the diabetes physician when evaluating whether the individual is medically qualified to operate a CMV.

The effect of CMV operation on the health of drivers with diabetes

The Association notes that federal transportation law requires that FMCSA prescribe regulations on commercial motor vehicle safety. At a minimum, the regulations shall ensure

that “the physical makes it

operation of commercial motor vehicles does not have a deleterious effect on the

condition

of

the

operators.”22

There

is

nothing

about

commercial

driving

that

a

dangerous

or

inadvisable

occupation

for

someone

with

insulin-treated

diabetes

as long as the while driving –

individual is able to and an assessment

maintain of this is

his or her blood glucose within a safe range already needed to determine if the individual

21 “Exemption Application, Diabetes Standard” available at: http://www.fmcsa.dot.gov/documents/safetyprograms/Diabetes/diabetes-exemption-package.pdf (last visited April 28, 2006).

22

49 U.S.C. § 31136(a)(4).

8

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