Richard Hom - Comments

I wish to comment on DOT Docket No. FMCSA-2008-0292 as submitted by the Advocates for Highway and Auto Safety (Advocates) on November 7, 2008. As you may know, this document details and argues against the application for exemption of drivers with some kind of vision impairmment in meeting the federal vision standards for safe operation of commercial motor carrier vehicles. As an optometrist with more than 35 years of experience, I concur that in the case of optometrists or ophthalmologists, their recommendations on whether a particular individual can operate a vehicle safely enough may not be in their purview. While I am talented and knowledgeable in the assessment of the level of vision and may be capable in determining the efficiency of reading for my patients who may have vision impairment of one kind or another, I would beg or defer from attesting to the ability of my patient to operate safely a large commercial vehicle. As mentioned in this document, actual operation of a motor vehicle is probably not within the realm of most eye care providers unless they have had specific experience doing so, much like a flight surgeon for pilot certification. What eye care providers, whether optometrists or ophthalmologists, can attest is the potential obstacles of a patient's eye condition and any possible performance problems deriving from that. However, these performance appraisals do not necessarily equate to safe operation of a vehicle. Even giving a patient a clean bill of health only means that there are no vision components that should prevent a possible problem, but that doesn't necessarily translate to an ability to read road signs, or react quickly and decisively in a potential hazardous driving condition. In recognition of this quandary, I don't believe it serves the public welfare to have eye care providers to attest to the ability of a driver to operate a motor vehicle safely. I believe that their value is in addressing the vision performance of a patient under laboratory conditions which aren't necessarily relevant or related to actual driving conditions. Respectfully yours, Richard Hom O.D. San Francisco, CA