Mark Daniel Bej, MD

1) "Seizure disorder" is a euphemism. Use "epilepsy", "seizures" (someone could have a seizure or seizures but not have epilepsy), "loss of consciousness", "convulsion(s)", "convulsive disorder", as appropriate. 2) Is there a policy only for epilepsy? If so, why discriminate against epileptics and not include other conditions that cause loss of awareness (LoA) or consciousness (LoC)? 3) In item (1), an across-the-board 8-year seizure-free policy is much too long. The seizure-free period should depend on the mariner's job. Is (s)he usually above or below decks? Working with flammables and moving equipment, or not? 4) Does "stable medication regimen" mean only AEDs, or all drugs? If only AEDs, there is no recognition that other meds can change AED blood levels. This item should allow for continued employment if there are stable *blood levels* even if the *medication regimen* is not identical. 5) In item (2), the 4-year seizure-free period for a single unprovoked seizure seems to me to be too long. OR, perhaps shorten the period if a 72-hour ambulatory EEG is negative. 6) For provoked seizures, in item (2)(b), do you mean *seizure* or *convulsion* provoked by syncope? 7) All the low-risk provoked seizures should, in my view, be changed to avoidance of work for a reasonable period of time (1-2 weeks) after another possibly provocative event. 8) Why is alcohol use/withdrawal not listed, or is this considered to be subsumed under "drug withdrawal"? Similarly with hypoglycemia, or is this "acute metabolic derangement"? All insulin-dependent diabetics are potentially at risk for seizures; will they be included within this policy even if they never had a seizure? 9) "dosage within the therapeutic range" is poor wording. "Therapeutic range"s are quite nebulous concepts. There are patients with "low" levels who are seizure-free for decades, and others who require so-called "critical" levels to keep them seizure free. Dosage reduction may be needed due to other meds being added