Oregon Department of Motor Vehicles - Comments

Oregon DMV submits the following comments: When we reviewed the original NPRM that was published on December 1, 2008 we were a bit surprised that there seemed to be no explicit requirement for the licensing agency to verify the validity of registry numbers entered on medical certificates that were submitted to the state for the purpose of CDL qualification. Our understanding is that the role of DMV in the registry process is, as proposed, limited to simply collecting and storing the registry number and passing it on to authorized users, when asked. Since the usefulness of the National Registry is greatly diminished without verification, we assumed FMCSA had other plans for verification that would eventually be revealed. As a state driver licensing agency we often forget about CMV operators that may require medical certification but need no CDL. Consequently, we initially thought an electronic verification process using CDLIS and the National Registry database or through DMV access to the database made the most sense. However, such a solution is, of course, no solution for verification of examiners that evaluate non-CDL holders. Rather than further complicating a medical certification process (that has already been made sufficiently complicated) by establishment of multiple verification processes, we believe the employer verification process described in the modified proposed rules published on March 16, 2011 is reasonable.