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  • ACOEM Asks FMCSA to Delay Compliance Date for Usage of New CDME Forms


    November 24, 2015

    T.F. Scott Darling, III
    Acting Administrator
    Federal Motor Carrier Safety Administration
    1200 New Jersey Avenue SE
    Washington, DC 20590

    Dear Administrator Darling:

    On behalf of the American College of Occupational and Environmental Medicine (ACOEM), we write to respectfully request that the Federal Motor Carrier Safety Administration (FMCSA) delay the compliance date for certified medical examiners (MEs) performing physical examinations of commercial motor vehicle (CMV) drivers to use the Medical Examination Report (MER) Form, MCSA-5875, in place of the current MER Form, and to use Form MCSA-5876 for the Medical Examiner's Certificate (MEC).

    We request that the compliance date be changed from December 22, 2015, to a date that is 60 days from publication of the final version of the forms and accompanying FAQs. The additional time will enable medical examiners to become familiar with the new forms, which to date have not been published; and to understand the FAQs, which also have not been published.

    FMCSA has promised to prepare and post a set of FAQs, which has not happened. To further complicate preparation, FMCSA still has not posted the final version of the medical examination reporting forms, which must be used beginning December 22, 2015. This requested delay will avoid inconsistencies amongst examiners, ensure the quality of medical examination, avoid unnecessary costs and time for drivers, and protect safety on our highways.

    ACOEM has long supported the National Registry of Certified Medical Examiners, hoping it would bring consistency and best practice to ensure safety on the public highways. Many of our members are examiners. Many have been trying to prepare for phase 2 of the NRCME since the publication in the Federal Register on April 23, 2015. The final rule has generated many questions from MEs and FMCSA hosted two calls to respond to questions. An estimated 700 examiners participated in those calls and the degree of confusion evidenced in the calls is concerning so close to the December compliance date. If the calls hosted by FMCSA are any indicator, it is very likely that the majority of the 44,000 CMEs are also ill prepared to use of the new forms.

    Thank you for your consideration of this request.

    Sincerely,

    Mark A. Roberts, MD, PhD, MPH, FACOEM
    President

    Natalie P. Hartenbaum, MD, MPH, FACOEM
    Chair, Transportation Section

    cc: Charles Horan
    Christine Hydock