Darren Jude Duet

Document ID: USCG-2012-0734-0004
Document Type: Public Submission
Agency: Coast Guard
Received Date: September 19 2012, at 12:00 AM Eastern Daylight Time
Date Posted: September 24 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: September 7 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: October 9 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 8111db52
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This is comment on Proposed Rule

Medical Waivers for Merchant Mariner Credential Applicants with Anti-Tachycardia Devices or Implantable Cardioverter Defibrillators (Federal Register Publication) (Notice of proposed policy change and request for comments.)

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The USCG guidance on medical issues is geared toward identifying mariners with medical conditions that have an inordinate risk of sudden incapacitation. With this in mind, an implantable cardioverter-defibrillator (ICD) is only implanted in patients who are at inordinate, defined risk of sudden cardiac death due to ventricular arrythmia (as per its medical indication). Any inordinate risk of sudden death is the sine qua non of sudden incapacitation. Public safety is of paramount importance, and "waiving" a medical issue that has an inordinate risk of sudden incapacitation is in contrast to the purpose of the medical evaluation process of the USCG and public safety.