Comment from George Nealis

July 22, 2026 Dockets Operations U.S. Department of Transportation 1200 New Jersey Avenue SE, W58-213 Washington, DC 20590-0001 Re: Docket Nos. FMCSA-2013-0108, FMCSA-2015-0115, FMCSA-2015-0321, FMCSA-2021-0026, FMCSA-2022-0042, FMCSA-2022-0043, FMCSA-2024-0021 — Notice of Renewal of Exemptions from 49 CFR 391.41(b)(8) (Epilepsy and Seizure Disorders); Request for Comments Dear Dockets Operations: I write to oppose FMCSA's renewal of exemptions from 49 CFR 391.41(b)(8) for the 13 drivers identified in this notice. This standard exists because a seizure, or any other sudden loss of consciousness, occurring behind the wheel of a commercial motor vehicle can be fatal not only to the driver but to everyone sharing the road. I respectfully urge the Agency to reconsider its blanket approach to renewing these exemptions and to apply a more rigorous, individualized standard of review before any further renewal. 1. The exemption relies heavily on self-reporting The terms and conditions described in this notice require each driver to self-report a seizure within 24 hours and to report crashes and citations within 7 days. A driver who experiences a seizure, particularly one that causes confusion or memory loss, may not be a reliable reporter of that very event. The program's safety case depends substantially on drivers accurately disclosing episodes that could end their livelihood, which creates an inherent conflict of interest that the notice does not address. 2. A clean driving record over two years does not rule out seizure risk FMCSA's stated basis for renewal is that each driver's SDLA record shows no disqualifying violations or crashes during the prior exemption period. A clean record of this kind is a reasonable indicator of general driving conduct, but it says little about the likelihood of a future seizure, since seizure recurrence is a medical question, not a driving-record question. The notice would be strengthened by more specific medical evidence in the record, such as seizure-free intervals, medication compliance data, and EEG or neurological follow-up findings, rather than relying primarily on driving history as a proxy for medical stability. 3. The consequences of a seizure at highway speed are severe and irreversible A commercial motor vehicle can weigh tens of thousands of pounds. A single loss of consciousness at highway speed, even a brief one, can result in a crash involving multiple vehicles, and unlike many other safety risks, this one is not something the driver can correct once it begins. Given the severity and irreversibility of this specific failure mode, the Agency should hold this exemption to a higher evidentiary standard than exemptions from requirements with less catastrophic downside risk. 4. Requested action I ask that FMCSA decline to renew these exemptions, or, at minimum, that the Agency: (a) publish the underlying medical evaluations and seizure-free intervals for each driver rather than a summary conclusion; (b) require independent verification of seizure-free status beyond the treating physician's annual attestation and the driver's own report; and (c) shorten the renewal period for drivers whose seizure history is more recent or less well documented. The public should be able to evaluate the actual medical basis for each renewal, not just the administrative fact that a renewal was granted. Thank you for the opportunity to comment. Respectfully submitted, George