Allan Stuart Troupin

The proposed criteria are quite conservative, more so than the usual (and quite undocumented) ones prevalent in the civilian and academic practices of epileptology. However, given the potential downside of having seizures while working on ships, the proposed criteria do not seem excessive. I would also add that sophisticated use of the modern anticonvulsants does lead to seizure freedom for the majority of patients, so many people should be eligible for the waivers. I would recommend consideration of one other issue under "Provoked Seizures" - sleep deprivation. The Air Force had a lot of experience with this problem some years ago and might share information with the Coast Guard that could have some bearing on the proposed rule.