So what can a medical examiner do when faced with a driver who may have excessive daytime sleepiness (EDS)? For now, medical examiners should recognize that FMCSA guidelines for EDS and sleep disorders are guidance, not regulation. This means that medical examiners should consider FMCSA guidelines, but are not required to follow FMCSA guidelines in every case.
What are FMCSA guidelines for sleep disorders? They include the recommendation that all drivers be screened for possible sleep disorders based on certain driver characteristics. Sleep study evaluation is recommended for drivers with the following characteristics: a body mass index (BMI) > 35, neck size > 17 inches (men) and 16 inches (women), and drivers who score 10 or more on an Epworth Sleepiness Scale instrument. Although not required, it is highly recommended that all drivers presenting for a DOT medical examination be screened for these characteristics.
Recommended screening includes a monitored sleep study. Guidelines are silent on whether in-home sleep studies are acceptable, although such testing is becoming more common. If a driver tests positive for sleep apnea, most commonly defined as > 30 hypoapnea episodes per hour, guidelines recommend that the driver should be disqualified until the driver has been successfully treated, defined as a repeat sleep study demonstrating that sleep apnea is no longer present. Yearly monitoring to assure that sleep apnea continues to be controlled is recommended.
In addition to sleep apnea, other sleep disorders should be considered. Chief among these is restless leg syndrome (RLS) associated with EDS. FMCSA guidelines indicate that RLS-EDS is disqualifying. The guidelines are silent on whether successful treatment of RLS allows a driver to be qualified.
Screen drivers for EDS. Unless there is a compelling reason not to do so, follow FMCSA guidelines for evaluation and management of sleep disorders. Doing so will help manage driver safety risks as well as mitigating risk for DOT medical examiners.
Steven St. Clair, MD, MPH
Dr. St. Clair is a medical consultant to the NRCME Training Institute, LLC. The NRCME Training Institute, LLC provides an affordable 100% online DOT medical examiner training program which meets and exceeds FMCSA requirements.
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