I wanted to reiterate some facts of my case. First and foremost, I have not been diagnosed with epilepsy. I experienced a single "seizure like" event (a term given by neurologist in a written statement) on March 10, 2008. I have been seizure free quickly approaching 2 years and 6 months. I currently hold a regular class C drivers license with no restrictions. I do not hold a CDL license. I am not required to take anti-seizure medication and have been off all medications since April 11, 2009. In my occupation as a UPS package car driver I average 45 hours a week on road with approximately 60-80 miles driven daily all within the city limits of Arlington, Texas. Due to a clerical error by UPS I was allowed to return to my duties as a full time package car driver on September 10, 2009. I resumed all duties during UPS's peak season which entails an avg of 50-60 hours per week with 60-100 miles driven per day. I remained on my truck for seven months till I needed my biannual dot re-certification that was due on April 9 ,2009. During that time I was able to demonstrate that I could achieve/exceed the level of safety required while performing all duties required by a full time package car driver. I am still employed at UPS assigned to alternate work inside the hub. I am required to split shift to maintain my full time employment which requires that I must make a commute of 60 miles one way four times daily(240 miles a day driven appx. 4.5 hours of drive time) to maintain my employment. My new duties are more physically challenging than those of a package car driver as I am currently loading package cars in the morning and loading semi trailers in the evening. Current temperatures have been in the low 100's in the early evening with the temperature in the semi trailer averaging about 130 degrees. I have submitted all required information to demonstrate that I merit consideration for the earlier return to work provision set forth in the dot guideline.
James C. Dyer - Comments
This is comment on Rule
Qualification of Drivers; Exemption Applications; Epilepsy and Seizure Disorders
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