Comment from George Nealis

Docket Nos. FMCSA-2013-0108, FMCSA-2015-0115, FMCSA-2015-0321, FMCSA-2021-0026, FMCSA-2022-0042, FMCSA-2022-0043, FMCSA-2024-0021 Re: Notice of Renewal of Exemptions; Request for Comments — Epilepsy and Seizure Disorders Exemption Renewals for 13 CMV Drivers To the Federal Motor Carrier Safety Administration: I am submitting this comment as an individual member of the public in response to the above-referenced notice renewing exemptions from 49 CFR 391.41(b)(8) for 13 interstate commercial motor vehicle drivers with a history of seizures who are on anti-seizure medication. I do not take a position for or against renewal of these specific exemptions. I am writing to ask FMCSA to clarify several procedural points as part of the record for this notice: Data supporting renewal decisions. The notice states that each driver's certified driving record was reviewed and that no medical issues arose during the prior two-year exemption period. Can FMCSA clarify whether summary safety outcome data for the full population of active seizure-disorder exemption holders (e.g., crash rates, seizure-recurrence rates, revocations) is published anywhere, or would be available upon request, so the public can evaluate the program's track record rather than relying on notice-by-notice, case-by-case summaries? Annual reporting compliance. Condition (2) in Section VI requires annual physician reports attesting to treatment stability and seizure-free status, and condition (7) requires annual certified driving records from the SDLA. Does FMCSA track and publish an aggregate compliance rate for these annual reporting requirements across all exemption holders, and what happens procedurally if a driver misses a reporting deadline before a violation is otherwise discovered? Seizure and crash self-reporting. Conditions (1), (5), and (6) rely on the driver to self-report seizures, crashes, and disqualifying citations/convictions within set windows (24 hours, 7 days, 7 days respectively). Is there any independent verification mechanism (beyond the annual physician and SDLA reports) that would catch a missed or delayed self-report in the interim, and if so, what is it? Basis for the 2007 Medical Expert Panel criteria. The notice relies on medical advisory criteria developed from a 2007 Medical Expert Panel review. Has FMCSA conducted or planned any more recent review of the medical literature on seizure recurrence and CMV driving risk to confirm the criteria remain current, and if so, when was the last such review? I appreciate FMCSA's consideration of these questions as part of the docket for this notice. Respectfully submitted