Orrin Mann, MD, MPH, FACOEM
Occupational, Environmental & Preventive Medicine
Minnesota
Sleep
Society
5th Annual
Meeting
Lecture Overview
 Case studies
 Impact of Sleepy CMV drivers
 Why the conundrum
 A driver’s job
 Review the “Rules”
 Describe the regulatory issues and process
 Review the guidance available
 Quick summary: There is no “Rule” for OSA.
Case 1
 51yo male
 ESS=3, BMI 37, Neck Circumference 19”
 Remainder of H & P normal
 PSG ordered, 3 month DOT card signed
 Employer upset and threatens to pull business
Case 2
 51yo male
 ESS=3, BMI 37, Neck Circumference 19”
 Remainder of H & P normal
 PSG NOT ordered, 2 year DOT card signed
 Employer’s MD audits and insists on a 3 month card
and a PSG, citing the Joint Task Force
recommendations.
Case 3
 63 yo male CMV driver
 Off work after MVA: took 3 pills, he believes they were
Ambien and not HCTZ, “by mistake”, fell asleep, head
on collision, with severe injuries to other driver.
 Seen elsewhere and given a DOT card.
 Employer requests I repeat evaluation knowing above
information
Case 3 Continued
 Drug test + for Ambien, per employer
 H & P otherwise normal
 I initially cleared driver, but later changed my mind,
rescinding the card until evaluated by a sleep expert,
per Joint Task Force.
 Employer upset, disagrees with recommendation, and
doesn’t want to put driver through the “added
expense.”
My role today
 I am not a sleep expert: You guys are.
 I will not debate or defend any recommendations
 I will not discuss merits of Home vs. Lab PSG, MWT,
MSLT, etc.
 I hope to clarify some of the regulatory, legal,
bureaucratic, occupational, & financial issues
Tracy Morgan Critically Hurt in New
Jersey MVA 6/7/14: Wall mart sued
June 2009: Miami,Oklahoma
 76 year old driver falls
asleep after 11 hours of
driving
 Hits a line of
Stationary cars
 10 dead
Sleepy Drivers
 Drowsy driving is a leading cause of crashes and
highway fatalities, according to federal officials.
 More than 30,000 people die on highways annually in
the United States; crashes involving large trucks are
responsible for one in seven of those deaths.
 The DOT believes that fatigue-related causes
accounted for 13 percent of all trucking accidents.
2002 NHTSA study
Economic Impact of Sleepy Drivers
 6 million crashes annually resulting in an economic
impact of over $230 billion.
 >17% ($39 billion) of these costs are probably
attributed to sleepiness and even this estimate may be
relatively low.

Blincoe LJ, Seay A, Zaloshnja E, Miller TR, Romano E, Luchter S,
et al. The economic impact of motor vehicle crashes, 2000.
Washington, DC: National Highway Traffic Safety
Administration; 2002.
Sleepy Drivers
 Federal rules 2013 reduced the maximum workweek for
truckers to 70 hours, from 82 hours.
 Drivers who hit this limit can start their workweek
only after a mandatory 34-hour resting period.
“Restart” must include two periods between 1 a.m. and
5 a.m., to allow drivers to rest at least two nights a
week.
 Drivers cannot drive for more than 11 hours a day and
must have a 30-minute break in their schedule.
(FMCSA not enforcing for short haul)
Sleepy Drivers
 DOT based its new rules on the 2006 Large-Truck
Crash Causation Study: fatigue-related causes
accounted for 13 percent of all trucking accidents.
 Federal officials caution that fatigue was often
underreported in crash investigations because truck
drivers do not want to acknowledge being sleepy, lest
they be seen as at fault.
 Often difficult to find evidence that fatigue directly
caused an accident.
Sleepy Drivers
 1990 National Transportation Safety Board study of 182
heavy-truck accidents in which the truck driver died
 Concluded fatigue played a role in 31 percent of the
cases: more than alcohol or drugs.
 Extent of problem is a matter of debate, because it is
difficult to obtain evidence that the dead driver fell
asleep first.
Sleepy Drivers: MEP Report 2008
 CMV drivers with OSA are at an increased risk for a crash
when compared to their counterparts who do not have the
disorder (Strength of Evidence: Minimal Acceptable).
 Crash risk for CMV driver: 0.08 MVA/person-year
 Crash risk (expected) CMV driver with OSA:
0.10-0.46 MVA/person-year or as much as 5+ times higher
 Non-CMV drivers with OSA are at an increased risk for a
motor vehicle crash when compared with comparable
drivers who do not have the disorder (Strength of Evidence:
Strong).
In the event of a crash with injury or death, the medical
exam will be among the first things scrutinized
Why the Conundrum????
 Cost: PSG, CPAP, Lost income
 Anxiety: Financial, career
 Confusion
 Mixed messages from DOT
 Legal impediments to regulatory guidance
 Rules, regulations, guidance, panels, boards: Huh???
 Multiple contradictory recommendations
 Trucking industry inconsistency
 Medical field inconsistency
The Job of a Commercial Driver
 Driver’s duty may include:
 Coupling and uncoupling trailer(s) from tractors
 Loading and unloading
 Inspecting vehicle and trailer
 Lifting, installing and removing chains, tarps
 Agility, bend, stoop, crouching, climbing
 DOT instructs that all CMV drivers with a medical
certificate must be able to do all of these, not merely
their own job!
The Job of a Commercial Driver
 Duties may included:
 Abrupt schedule changes
 Rotating work schedules
 Irregular sleep conditions

Could impact CPAP compliance, and sleep quality
 Beginning a trip in a fatigued condition
 Long hours
 Extended time away from family and friends
49 CFR 391.41
Physical Qualifications for Driver
 A driver must have
 The perceptual skills to monitor a sometimes complex
driving situation
 The judgment skills to make quick decisions
 The manipulative skills to control an oversize steering
wheel, shift gears using a manual transmission, and
maneuver a vehicle in crowded areas.
Purpose of Interstate Commercial Driver
Physical Examination
FMCSA describes the periodic physical qualification
examination of the interstate CMV driver to be a
"medical fitness for duty" examination. The purpose
of the physical examination is to detect the presence
of any physical, mental, or organic conditions of
such character and extent as to affect the ability of
the driver to operate a CMV safely.
The DOT Exam
 First DOT exams required January 1, 1954
 Standard last revised (49CFR 391.41) 1970
 Only MDs could perform exam till 1992.
 After 1992: added doctors of osteopathy, physician
assistants, advanced practice nurses, and doctors of
chiropractic, licensed to perform medical
examinations in their state.
1999: FMCSA
 Federal Motor Carrier Safety Administration (FMCSA)
established.
 One branch of the Department of Transportation
(DOT).
 One goal: ensuring safety in motor carrier operations
through strong enforcement of safety regulations
FMCSA
Office of Medical Programs
 "The mission of the Office of Medical Programs is to
promote the safety of America's roadways through the
promulgation and implementation of medical
regulations, guidelines and policies that ensure
commercial motor vehicle drivers engaged in
interstate commerce are physically qualified to do so."
 Develops and implements medical regulations,
policies, and procedures
The DOT Exam
 13 standards for medical fitness
 4 “non-discretionary” disqualifying standards:
 Seizures, insulin, vision, hearing
 “Regulations are law and must be followed”
 9 “discretionary standard”
 Examiner determines whether to sign the medical
certificate
 These are neither regulations nor laws.
Discretionary standards
 The Federal Motor Carrier Safety Administration
(FMCSA) provides medical Guidelines or advisory
criteria based on expert review, and considered best
practice.
 Published in the Medical Examiners Handbook:
http://nrcme.fmcsa.dot.gov/documents/FMCSAMedic
alExaminerHandbook-2014MAR18.pdf
Discretionary standards
 “The examiner may or may not choose to use these
recommended guidelines. When the certification
decision does not conform to the recommendations,
the reason(s) for not following the medical guidelines
should be included in the documentation.”
 Legal ramifications of diverging from Guidelines.
Discretionary standards
 Where “Big G” guidance is unavailable, can use “little
g” sources such as MEP or MRB recommendations,
Motor Carrier Safety Advisory Committee
recommendations, medical literature, consultants
recommendations, or community best practices.
 Spring 2014: FMCSA removed all “Chronic Sleep
Disorders”, “Sleep Disorder Test” Guidelines, and
FAQ’s on OSA and EDS from the Handbook.
 FAQ remains on Narcolepsy: Disqualifying.
Discretionary standards
 391.41(b)(5): “Has no established medical history or
clinical diagnosis of a respiratory dysfunction likely to
interfere with his ability to control and drive a
commercial motor vehicle (CMV) safely.”
 391.41(b)(9): “Has no mental, nervous, organic, or
functional disease or psychiatric disorder likely to
interfere with his ability to drive a CMV.”
DOT History
 Yes or No: “Sleep disorders, pauses in breathing while
asleep, daytime sleepiness, loud snoring.”
 Questions on Hypertension, Diabetes and medications
for these conditions.
 May add Epworth Sleepiness Scale, similar tools, or
other questionnaires. Epworth in the setting of the
DOT exam is unreliable in my experience. Drivers are
either unaware of, under report, or underestimate
EDS.
DOT Physical Examination
 Height and Weight: required.
 BMI , Neck circumference: NOT required.
 Yes or No: “Abnormal chest wall expansion, abnormal
respiratory rate, abnormal breath sounds including
wheezes or alveolar rales, impaired respiratory
function, cyanosis. Abnormal findings on physical
exam may require further testing such as pulmonary
tests and/or xray of chest.”
 Exam of limited utility for sleep disorders
Instructions to the Medical
Examiner
(On the DOT exam form)
 “There are many conditions that interfere with oxygen
exchange and may result in incapacitation,
including…sleep apnea. If the medical examiner detects
a respiratory dysfunction, that in any way is likely to
interfere with the driver’s ability to safely control and
drive a commercial motor vehicle, the driver must be
referred to a specialist for further evaluation and
therapy.”
1999: SAFTELU
 Safe, Accountable, Flexible and Efficient
Transportation Equity Act: A Legacy for Users.
 Required Certified Driver Medical Examiners (CDME),
registered on National Registry of Cerified Medical
Examiners (NRCME). Effective May 21,2014.
 Before: 900,000 examiners.
 Now: 40,000 CDMEs.
SAFTELU
 Exam results are submitted to a national database. In
3 years FMCSA will forward the medical certification
status to the states for inclusion in the Commercial
Driver Licensing Information System (CDLIS).
 Drivers with Canadian or Mexican CDLs who are
operating in the United States under NAFTA
agreements are not required to be examined by
examiners on the NRCME.
FAQ: “What happens if a driver is not truthful about
his/her history on the medical examination form?”
 Driver is required to complete the Health History
section and certify that the responses are complete and
true.
 Must certify that he/she understands that inaccurate,
false or misleading information may invalidate the
examination and medical examiner’s certificate issued
based on it.
 A civil penalty may also be levied against the driver
under 49 U.S.C. 521(b)(2)(b), either for making a false
statement or for concealing a disqualifying condition.
FMCSA Standard and Guideline
Review
 Based on agency experts’ analysis of international,





national and state data
Interagency national and international regulatory
analysis
Evidence reports, written by FMCSA based on above
items
Medical Expert Panels (MEP)
Medical Review Board (MRB)
Motor Carrier Safety Advisory Committee (MCSAC)
MEP
MEDICAL EXPERT PANEL
 “Each MEP is comprised of an independent panel of
physicians, clinicians, and scientists who are experts in
their specialty fields.”
 An MEP is periodically commissioned by FMCSA for
specific medical topics. MEP reviews the evidence in the
about a question or topic, and makes recommendations to
the Agency in the form of a report.
 This report is an “opinion for consideration” for FMCSA.
http://www.fmcsa.dot.gov/rulesregulations/topics/mep/mep-reports.htm
 Once approved, it become a Guidline.
MRB
MEDICAL REVIEW BOARD
 “The MRB is composed of five of our Nation's most
distinguished and scholarly practicing physicians.
These physicians were chosen from a field of many
qualified candidates who possess a wide variety of
expertise and experience. MRB members specialize in
the areas most relevant to the bus and truck driver
population.”
MCSAC- Chartered 2006
MOTOR CARRIER SAFETY ADVISORY COMMITTEE
 “Is comprised of 20 experts from the motor carrier
safety advocacy, safety enforcement, industry, and
labor sectors.”
 Not medical professionals
 Provide advice and recommendations to the FMCSA
Administrator on motor carrier safety programs and
motor carrier safety regulations.
 See link for current members:
http://mcsac.fmcsa.dot.gov/members.htm
FMCSA Standard and Guideline
Review
 MRB: Meets 3-4 x per year
 Review Evidence Reports and MEP opinions, if an MEP
has been convened
 Proposes recommendations to FMCSA
 FMCSA reviews all of this, and considers feasibility
and impact.
 Posts proposed changes to current standards for
comment
 Medical Examiners Handbook updated with new
Standards or Guidelines
•May 2010: The American Sleep Apnea
Association, the American Trucking
Associations and the FMCSA co-sponsored a
national Sleep Apnea & Trucking Conference
about sleep apnea’s effect on truckers.
•April 20, 2012: FMCSA published a Proposed
Regulatory Guidance for obstructive sleep
apnea (OSA) and request for comment.
•April 27, 2012: FMCSA published a
withdrawal notice on its Proposed
Recommendations on Obstructive Sleep
Apnea.
H.R.3095, enacted Oct 15, 2013
 To ensure that any new or revised requirement
providing for the screening, testing, or treatment of
individuals operating commercial motor vehicles for
sleep disorders is adopted pursuant to a rulemaking
proceeding, and for other purposes.
 Does not prohibit enacting Guidelines (e.g. in the
Handbook), but FMCSA intends to only propose new
Guidelines through the notice and comment process.
 Net effect: Everything is delayed.
FMCSA Standard and Guideline
Currently nothing on sleep disorders is
available in the Medical Examiners
Handbook, and prior Guidelines have
been vacated.
Current FAQ: Narcolepsy
“The guidelines recommend disqualifying a CMV
driver with a diagnosis of Narcolepsy, regardless of
treatment, because of the likelihood of excessive
daytime somnolence.”
Trucking Industry Opposes Rule
changes
 On 6/6/14 Senator Susan Collins, pushed an
amendment through the Senate Appropriations
Committee that would freeze the rules, stating the
administration had failed to take into account that the
new rules would put more trucks on the roads during
peak traffic hours, and safety studies are needed.
 Trucking officials and executives also said that drivers
needed to be afforded maximum flexibility in their
work and should not be told when to rest.
 Industry claim: rules reduce productivity.
Assessing Risk
Does the Driver Pose a Risk to Public Safety?
 “As a medical examiner, any time you answer “yes“ to
this question, you should not certify the driver as
medically fit for duty.”
 A balance between the “right” or desire to work and
public safety
Assessing Risk
 Physical Conditions:
 Symptoms: Does the condition interfere with the ability
to drive?
 Does the condition cause incapacitation?


Sudden: Can driver safely stop vehicle before incapacitation
or LOC?
Gradual: Is the driver unaware of diminished capacity,
adversely affecting safety?
Assessing Risk
 Mental conditions
 Cognitive: Can the driver process environmental cues
rapidly and make appropriate responses, independently
solve problems, and function in a dynamic
environment?
 Behavioral: Are the driver reactions appropriate,
responsible, and nonviolent?
Assessing Risk
 Medical treatment:
 Effects: Does treatment allow the driver to perform
tasks safer than without treatment?
 Side effects: Do side effects interfere with safe driving
(e.g., drowsiness, dizziness, orthostatic hypotension,
blurred vision, changes in mental status)?
Acceptable Risk
From Cardiovascular Advisory Panel (MEP)
 Acceptable Risk is a medical and societal issue
 “Given the complex demands of operating a large truck
or bus, coupled with the high fatality risk for occupants
of the other vehicle in crashes involving CMV’s, a
conservative approach is required.”
 1% annual risk of sudden incapacitation
(impairment) is often used.
VACATED Former FMCSA GUIDELINES
Chronic Sleep Disorders
 Waiting period
 Minimum – 1 month after starting CPAP
 Minimum – 3 months symptom free after surgical treatment
 Maximum certification – 1 year
 Recommend to certify if the driver has:
 Successful nonsurgical therapy with


Multiple Sleep Latency Test WNL
Resolution of OSA confirmed by repeat sleep study during treatment
 Continuous successful non surgical therapy for 1 month
 Compliance with continuing nonsurgical therapy
 Resolution of symptoms following completion of post-
surgical waiting period
VACATED Former FMCSA GUIDELINES
Chronic Sleep Disorders
 Recommend not to certify if the driver has:
 Hypoxemia at rest
 Diagnosis of:





Untreated symptomatic OSA
Narcolepsy
Primary (idiopathic) alveolar hypoventillation syndrome
Idiopathic CNS hypersonmolence
RLS with EDS
 The driver who is being treated for OSA should remain
symptom free and agree to:


Continue uninterrupted therapy
Undergo yearly objective testing (e.g. MSLT or MWT)
VACATED Former FMCSA GUIDELINES
Sleep Disorder Tests
 PSG “in a controlled sleep laboratory”
 Severity (AHI)
 Mild : 5+ episodes/hour
 Moderate : 15+ episodes/hour
 Severe : 30+ episodes/hour
 Apnea/hypopnea >30 episodes/hr of sleep is considered a
diagnosis of OSA
 Self-reported Sleepiness Surveys:
 NOTE: Self-reported sleepiness does NOT always correlate
with objective testing (PSG). The driver may not perceive
sleepiness as excessive or may be hesitant to disclose
sleepiness.
OSA: Unofficial Guidance
 2006 Joint Task Force
 ACOEM, NSF, ACCP
 2008 Medical Expert Panel
 FMCSA Medical Review Board
 2012 Motor Carrier Safety Advisory
Committee/Medical Review Board
FMCSA has not chosen which guidelines to follow, but
says that the only incorrect action is to do nothing.
OSA: Unofficial Guidance
(MEP, JTF, MRB/MCSAC)
 All address (with some differences)
 Criteria for OSA screening (BMI, neck circumference,
medical DX, symptoms, etc.)
 Disqualifying vs. In-service (conditional) criteria
 Waiting period
 Diagnostic screening
 Treatment
 Monitoring
 All agree to one year certification with OSA
Members of MEP
Sonia Ancoli-Israel, PhD :Professor of Psychiatry at the University of California
San Diego School of Medicine, Director of the Sleep Disorders Clinicat the
Veterans Affairs San Diego Healthcare System, Co-Director of the Laboratory
for Sleep and Chronobiology at the UCSD GCRC, and Co-Director of the
Education and Dissemination Unit of the VA VISN-22 Mental Illness Research,
Education and Clinical Center (MIRECC).
Charles Czeisler, PhD MD Baldino Professor of Sleep Medicine, Harvard
Medical School and Senior Physician for the Division of Sleep Medicine at
Brigham and Women's Hospital.
Charles George, MD FRCPC Professor of Medicine at the University of Western
Ontario in London, Canada and Director of the LHSC Sleep Disorders
Laboratory.
Christian Guilleminault, MD BiolD Professor of Psychiatry and Behavioral
Sciences at the Stanford School of Medicine.
Allan Pack, MB, ChB, PhD Professor of Medicine, and Neurology at the
University of Pennsylvania School of Medicine and chief of the Division of
Sleep Medicine and director of the Centerfor Sleep and Respiratory
Neurobiology
MEP 2008
 Studies in passenger car drivers all show there is an
increased risk of crashes in individuals with an AHI>30
 Some studies show that there is an increased risk in
individuals who have less severe sleep apnea.
 Studies comparing individuals with excessive sleepiness to
those who do not have sleepiness find that having an
AHI≥20 episodes/hour is a risk factor for excessive
sleepiness.
 (Pack, A.I., et al.,(2006). Risk factors for excessive sleepiness in older adults.
Ann. Neurol. 59:898-904.)
 The expert panel thus believed that individuals with an
AHI <20 who were not excessively sleepy could be certified
to drive.
MEP: Certify annually if
 Has untreated OSA with an AHI </= 20 AND
 Has no daytime sleepiness, OR
 Has OSA that is being effectively treated
MEP: Conditional Certification
 BMI >/=33: one month certification pending sleep
study (Panel wanted to make this a one week
certification, but not practical due to lack of access to
PSG.)
 Note: contradict themselves. See next slide
 Recently diagnosed OSA
 Certify for 1 month while starting CPAP
 After 1 month, certify x 3 months
 Reassess compliance after 3 months, and if good, certify
for 1 year
MEP: Do NOT certify
 Report of excessive sleepiness while driving, OR
 Experience a crash associated with falling asleep, OR
 AHI > 20, until compliant with CPAP
 Have undergone surgery, < 3 months post-op, OR
 Individuals non-compliant with treatment at any
point, OR
 BMI >33, pending sleep study
Joint Task Force (JTF): 2008
 Made up members of
 American College of Chest Physicians
 American College of Occupational and Environmental
Medicine
 National Sleep Foundation
Joint Task Force
 Disqualify
 Observed/confessed excessive sleepiness
 MVA related to sleep unless evaluated since
 ESS>/=16 or FOSQ<18
 Diagnosed OSA


Noncompliant or no follow-up
Surgical Tx w/o objective follow-up testing
 AHI>30
Joint Task Force
 In-service Qualification (3 months) if any one of the
following 5 categories:
 History suggestive of OSA
 2 or more:
 BMI>35;
 BP new/uncontrolled/2+ medications;
 neck circumference >16”Women or >17”men
 ESS>10
 Unconfirmed treatment compliance
 Prior PSG with AHI 6-29, AND:
 no MVA, No EDS, and <2 BP meds.
MRB/MCSAC Recommendations:
OSA
 Diagnosis of OSA precludes 2 yr certification
 May certify a driver with OSA if:
 AHI </= 20 (i.e. mild-moderate OSA) and
 The driver does not admit to experiencing excess
sleepiness during the major wake period, or
 The driver’s OSA is being effectively treated.
 May certify a driver with OSA annually based on
demonstrated compliance with treatment.
 Minimally acceptable compliance with PAP is
4 hours/day, 70% of days.
4
MRB/MCSAC Recommendations:
OSA
 Disqualify immediately or fail to certify if any of the
following:
 The driver admits to experience excessive sleepiness
during the major wake period while driving, or
 The driver experienced a crash associated with falling
asleep, or
 The driver has been found non-compliant with
treatment, as defined above.
MCSAC/MRB
 The MCSAC members are not medical professionals
 The MRB members are not experts in sleep disorders
 For these reasons, I treat MCSAC/MRB guidance with
the least weight of all the recommendations.
Competing Guidelines Summary
Waiting Period after treatment started
 ME Handbook (Vacated Big G)– requires 1 month
compliance after diagnosis to return to driving
 Joint Task Force (little g)– requires 2-4 weeks
compliance for those with AHI >30, and no wait for
those with AHI 5-30
 MCSAC/MRB (below little g) – requires 1 week
compliance for those initially disqualified, and no wait
for those who conditionally qualified
 MEP- no waiting period, but they suggest <2weeks of
treatment needed to be effective
Antihistamines
 Recommend to certify if:
 As the medical examiner, you believe that the treatment
does not endanger the health and safety of the driver
and the public.
 Recommend not to certify if:
 Treatment interferes with driving ability
 “The driver should abstain from medication for 12
hours prior to operating a vehicle.”
Sleeping Pills
 First generation antidepressants: FMCSA




recommends NOT to certify
Trazadone: not discussed
Sedating Anxiolytics: recommend not to certify
Hypnotic: May certify
Hypnotic, if the medication is:
 Short-acting (half life of less than 5 hours).
 The lowest effective dose. Used for a short period of
time (less than 2 weeks)
Sedating Medications
Drug
Onset
Peak
Half Life
Duration
Alprazolam
1 Hour
N/A
11 Hours
5 Hours
Amitriptyline
N/A
4 Hours
15 Hours
N/A
Benadryl
1-2 Hours
N/A
2/5-9 Hours
N/A
Eszopiclone
30 Minutes
N/A
6 Hours
8 Hours
Gabapentin
N/A
2-4 Hours
5-7 Hours
N/A
Lorazepam
20-30 Minutes
N/A
18 Hours
N/A
Mirtazepine
N/A
2 Hours
20-40 Hours
N/A
Nortriptyline
N/A
7-8 Hours
28-31 Hours
N/a
Pregabalin
N/A
1/5 Hours
6.3 Hours
N/A
Ramelteon
30 Minutes
N/A
1-2.6 Hours
8 Hours
Temazepam
1-2 Hours
N/A
3.5-18 Hours
6-10 Hours
Trazedone
N/A
30-100 Min.
7-10 Hours
N/A
Triazolam
15-30 Minutes
N/A
1.5-5.5 Hours
2-5 Hours
Zaleplon
N/A
1 Hour
1 Hour
4 Hours
Zolpidem
30 Minutes
1.5 Hours
2.5 hours
6-8 Hours
Zolpidem CR
30 Minutes
1.6 Hours
2.8 Hours
8 Hours
Summary
 Sleepy CMV drivers are deemed an unacceptable risk
 FMCSA has vacated all previous OSA Guidelines
 Legislation has delayed the issuance of new Guidelines
 FMCSA has said that the only incorrect action is to do
nothing
 Multiple competing recommendations exist.
 Sedating medications should not be used by CMV
drivers.
Any Questions?