?We strongly support the overall Joint Task Force recommendations to the
Department of Transportation (FMCSA division) to adopt a new guideline for
screening and treatment of commercial drivers with possible sleep apnea.
However, based on six years of experience in this specific area, we suggest the
FMCSA change the two weeks out-of-service requirement (for treatment to take
effect) to a 24 to 48 hour period. This suggestion is based on two key realities:
1) Economics: There is a severe shortage of qualified truckers in the US, and
having an employee out of work for two weeks is considered to be cost prohibitive
by most employers. Commercial drivers also feel that two weeks out-of-service is
simply not financially possible, when many of them are working paycheck to
paycheck to support their families. When both employer and employee are
actively motivated to resist a new regulation, it will not be successful. No other
broad blue collar job category with millions of employees requires them to stay
away from work once they have begun successful CPAP therapy.
2) Documented results: Working with Dr. Berger, Schneider Transportation has
implemented a program which returns drivers back to work with a minimal out-of-
service requirement. This program has documented a 52% reduction in medical
expenses overall, a 91% reduction in hospitalizations, and a 30% reduction in
accidents. So, the faster this type of program is expanded nationally, the more
money and lives will be saved. Critical to their success has been wireless
compliance monitoring, which provides better compliance outcomes than a
simple "out of work period" while the employee is going through the critical first
few weeks of adjustment to therapy.
By using 24-hour wireless monitoring, compliance can be easily monitored and
even coached to assure proper utilization of therapy. It provides clinicians with web-
based daily compliance results from anywhere in the US. Beyond Schneider,
several other transportation firms have shown that immediate return to work is
possible using 24-hour wireless monitoring. Adding this option to the guideline will
better satisfy the compliance goal that the old out-of-service standard was meant
to address, and allow drivers to return to work immediately and successfully."
Sleep Safe Drivers - Comments
This is comment on Rule
Medical Review Board Public Meeting
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