Calvin Liburd - Comments

To whom it may concern, I am writing in response to the Federal Register Docket , FMCSA-2011-0276 with a comment closing date of 30 November 2011. I think the exemption of the vision standards in 49 CFR 391.41(b)(10) for the 16 mentioned potential drivers should be granted for a few reasons: First it was stated in your research of the personnel records that even with the impairments to vision they will still be able to maintain a level of safety equivalent to that if they did not need an exemption. Second, the formula used for the basis of your research, an “Accident Rate Potential: An Application of Multiple Regression Analysis of a Poison Process,” by Weber, Donald, C, stated in the Journal : “Journal of American Statistical Association, June 1971, which uses a person driving record from the past three years to predict the probability of an accident in the future; none of the potential drivers had any accidents in the past three years. Another reason, is the majority of the requested driver exemptions were from drivers that had experience in driving straight trucks with at least 280,000 miles, and several of the drivers have their CDL license. Also the restrictions that wereput in place, as far as only exempting for two years and having to present a letter from their optometrist showing their vision have not declined. With all these factors, I think the exemptions should be granted.