SafeLane Health conducted an independent survey to assess examiners opinions and understanding of the MRB’s recommendations. Here are the results:
Question 1: Drivers are required to report and stop driving after severe hypoglycemia based on this proposal.
The FMCSA proposal is focused on the periodic certification exam ONLY. It is silent on management of hypoglycemia in between exams.
Not clear that driver is stop driving and report if there is hypoglycemic event
But how are you going to know if they don’t self report? Drivers could easily hide this fact unless they were in an accident. And even then you might not know the medical facts and if they lead to the accident.
we relaying on drivers to sel report. if they are truthful then they are out of work not sure how many drivers can afford to be out of work. so I feel drivers will under report hypoglycemic events.
Just over half of the respondents agreed that drivers are required to report a severe hypoglycemic event, however, there are concerns that drivers won’t report the event because it is reliant upon the driver self reporting. Not all examiners interpreted MRB’s proposal the same way. More than 1/3 of the examiners said that drivers under this proposal drivers are not required to stop driving and report the event.
Question 2: How many severe hypoglycemic events are acceptable over time? Assuming there is a process to stop driving for 6 months after each episode of severe hypoglycemia, then in the worst case, this would tally to 2 events per year, or over 5 years, 10 events total. This compares with the prior limit of 2 in 5 years. If the proposal does not preclude driving after severe hypoglycemia, then the number of events could be far higher. The proposal as written will be sufficiently safe.
NO hypoglycemic episode is without risk. What is “severe hypoglycemia?” Is a crash necessary to limit certification? What about NIDDM drivers who are oral hypoglycemic agents? They are just as worrisome. A driver who is feeling unwell and not eating can get behind his oral agent, and this is LESS amenable to simple feeding.
Old recommendation of 2 in 5 years better.
I think 2 events in 5 years is much better and some would agrue 2 events in a lifetime is grounds for disqualification.
Nearly 3/4 of examiners disagreed that the current proposal is sufficiently safe. Based on comments it appears that there is disagreement about what is safe, but most examiners agree that this current recommendation is not safe.
Question 3: If a driver does not monitor the glucose but then does so for 1 month, the proposal allows driving. As behaviors so frequently revert, is this sufficient assurance of ongoing monitoring?
Just like the driver who loses weight to get his BMI below 35 or 33, or whatever the limit is – better habits are difficult to maintain. We do not know how to motivate stable behavioral change.
No it’s not sufficient assurance of ongoing monitoring.
Financially, this is more palatable. Would recommend a shorter certification period and recommend the company place the individual in their own non-regulated f/u program in addition if this is available.
Nearly 4 out of 5 examiners believed that glucose monitoring for 1 month is not sufficient. There is concern that drivers would do the minimal possible to maintain driving certification. The proposal should be changed for a longer monitoring period.
Question 4: The MRB recommendations include an outline of a questionnaire, but it does not specify what should be done with negative or varying responses (e.g., a question regarding not being on a stable regimen for the past 3 months; drivers who do not monitor the glucose at least every 4 hours while driving). There should be specificity.
There is no room for wiggling here. Our chiropractic brethren need specific guidance. Every 4 hr monitoring is not ideal; should be upon awakening, post-prandial, pre-prandial, and every 4 hrs if not eating.
Yes, there should be specificity in the questionnaire.
again this is ALL based on drivers self reporting. I feel this whole proposal is dangerous.
Examiners unanimously agreed that there needs to be more specific guidance with how to handle glucose testing variability.
Question 5: The presence and extent of complicating conditions that are allowable is unclear (e.g., neuropathy, nephropathy).
“Signs of target organ damage” is clear. However, to what extent does an examiner go fishing for evidence? Opening a can of worms.
More specificity in the degree or extent of complicating conditions should be included.
Most examiners agreed that additional clarification is needed regarding allowable complicating conditions.
Question 6: There is unclear guidance on whether to allow someone to drive with diabetic nephropathy, including requirements to stage the nephropathy as per prior Medical Expert Panel and MRB recommendations.
I’m good with extremes, but in stage 3 CKD, where is the line drawn?
This guidance is not good. It should be clarified. No GFR < 30
Examiners unanimously agreed that the guidance is not clear enough to certify someone with diabetic nephropathy, particularly in moderately severe cases.
The deletion of the requirement to see an endocrinologist quarterly is laudable, but there should be greater emphasis on the qualifications of the MD, DO, etc. e.g. primary care or FM or IM.
Who ultimately determines the ability to drive-an endocrinologist, intern, mid level?
All of this is subject to the driver’s compliance and honesty. Unfortunately, many drivers will do anything to keep their CDL. I do not believe insulin dependent individuals should be able to maintain a CDL.
Make the guidance as clear as possible where the evidence supports that guidance. Minimize ambiguity. The less open to interpretation the better. That way CME’s across the board will be more consistent in the application of the guidance.
If the FMCSA is indeed to promote safety, I strongly encourage banning insulin dependent drivers based on the research available.
SafeLane Health has compiled all of the relevant research concerning insulin-using diabetics and driver safety.
The following is the current Medical Review Board’s (MRB) recommendations:
The 2016 MRB report recommended that insulin treated diabetic drivers may be qualified to drive if:
- Provides an assessment form completed and signed by treating medical provider. (Must be MD, DO, PA or Nurse Practitioner)
- Has a complete ophthalmologic or optometric dilated eye exam at least every 2 years, documenting degree of retinopathy/macular edema if present.
Under this proposal, the driver may be qualified for a maximum of 1 year unless they have experienced:
- Severe hypoglycemia in the past 6 mo.
- Blood sugar
- Hypoglycemia without warning symptoms
- Uncontrolled diabetes (HbA1C > 10%)
- Stage 3 or 4 diabetic retinopathy (permanent disqualification)
- Signs of target organ damage (disqualified until matter is resolved by treatment if possible)
- Inadequate record of self-monitoring of blood glucose (driver should be disqualified until min. of 1 month adequate glucose records
- If the driver has had an episode of severe hypoglycemia, blood sugar < 60 mg/dl or hypoglycemia unawareness within previous 6 mo, driver should be medically disqualified for at least 6 mo.