Sleep Safe Drivers - Comments

Document ID: FMCSA-2007-0032-0003
Document Type: Public Submission
Agency: Federal Motor Carrier Safety Administration
Received Date: January 16 2008, at 04:05 PM Eastern Standard Time
Date Posted: January 17 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: December 31 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: 
Tracking Number: 8039c362
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This is comment on Rule

Medical Review Board Public Meeting

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?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."

Related Comments

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Total: 8
John McElligott MD, FACP, MPH - Comments
Public Submission    Posted: 01/15/2008     ID: FMCSA-2007-0032-0002

Sleep Safe Drivers - Comments
Public Submission    Posted: 01/17/2008     ID: FMCSA-2007-0032-0003

John G. Chester - Comments
Public Submission    Posted: 01/24/2008     ID: FMCSA-2007-0032-0004

Michael & Rhonda Thomas - Comments
Public Submission    Posted: 01/25/2008     ID: FMCSA-2007-0032-0005

Conne F. and Artie L. Dillon - Comments
Public Submission    Posted: 02/13/2008     ID: FMCSA-2007-0032-0008