DVLA and UK Government: Stop the blanket suspension of drivers licences for diabetics.
The current UK DVLA legislation regarding diabetes mellitus (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:223:0031:0035:EN:PDF) was introduced by the European Union in 2011 and has faced opposition from the UK Prime Minister David Cameron as well as Diabetes UK (http://www.guardian.co.uk/society/2011/dec/21/driving-licence-form-revamp-diabetes). The directive is grossly unfair and incredibely myopic for reasons that are outlined below.
The directive states that if two "severe" hypoglycaemic episodes (defined as requiring assistance from a third party to treat or recover from) occur in the space of one year, these episodes must be mentioned in the DVLA's DIAB1 form (http://www.direct.gov.uk/prod_consum_dg/groups/dg_digitalassets/@dg/@en/@motor/documents/digitalasset/dg_066647.pdf) when applying or reapplying for a driver's licence. If it is the case that a diabetic has suffered from two severe hypoglycaemic attacks in the space of 12 months then the driver's licence is immediately suspended. The DVLA and the DIAB1 form however do not consider any context with regards to these hypoglycemic attacks and context plays a huge part in the severity of a hypoglycemic episode.
After having type 1 diabetes mellitus for twenty-two years and after driving for eight of these, I was informed today that after reapplying for my driver's licence it was being suspended due to the reasons above. The hypoglycaemic attacks that I mentioned in the form occurred whilst I was asleep and therefore, I had no awareness of them. It was only when my girlfriend and paramedics had helped me to recover did I realise what had happened.
Unawareness of night-time hypoglycaemia is medically referred to as "asymptomatic nocturnal hypoglycaemia". This phenomenon is well documented by the scientific community with many experiments devoted to its investigation (see http://www.plosmedicine.org/article/info:doi/10.1371/journal.pmed.0040069, http://diabetes.diabetesjournals.org/content/42/9/1233.short, http://www.nejm.org/doi/full/10.1056/NEJM199806043382303 etc). I have excellent hypoglycaemic awareness when fully conscious and have never had a "severe" hypoglycemic attack whilst awake. Therefore, I find the grounds on which my licence being suspended completely unjustifiable as I have never endangered any other person by driving whilst hypoglycaemic. Neither will I ever pose a risk unless my hypoglyaecemic awareness disappears altogether. I am sure that my opinion is shared by thousands of other diabetics who are in similar situations.
I rely on my car for many things: getting to work, picking up shopping, going to my diabetes clinics etc. and the fact that I am no longer able to do this, even though I pose no credible risk to other motorists, is devastating. The directive sets out rules that are both over generalised and not supported by any medical evidence whatsoever.
Furthermore, the response I received from the DVLA does not indicate what medical grounds my licence has been suspended upon, the length of the suspension or the date I can reapply. This information should be provided as stipulated by the DVLA themselves (see "part 3" of the following website: https://www.gov.uk/driving-medical-conditions/what-the-dvla-will-decide). As mentioned here: http://www.guardian.co.uk/society/2011/dec/21/driving-licence-form-revamp-diabetes), the DVLA state that:
"We must apply European medical standards but we consider every case individually and only refuse licences where absolutely necessary. We regularly review our forms to make sure they are as clear as possible and are pleased to be working with Diabetes UK to ensure all our information on this important subject is well understood."
The letter I have received states that "From the information given on the forms I have to advise you that you do not meet the standards required to hold a driving licence". No other information was provided other than that I had had two hypoglycaemic attacks in the space of 12 months and it does not appear that the DVLA have even contacted my GP or diabetes nurse specialist to quote, "consider every case individually and only refuse licences where absolutely necessary". As can be seen on the DIAB1 form however (http://www.direct.gov.uk/prod_consum_dg/groups/dg_digitalassets/@dg/@en/@motor/documents/digitalasset/dg_066647.pdf) there is no space to elaborate on the details of these hypoglycaemic attacks nor is there space to comment upon my own diabetes management. Based upon a 90 day sample of 138 readings, my average blood glucose averages at 8.8 (hypoglycaemia usually occurs when blood glucose is less than 3.5) with a standard deviation of 5.1. Given these figures I am extremely unlikely to suffer from hypoglycaemic attacks as my blood glucose is far higher on a tightly controlled average than blood glucose readings that would indicate hypoglycaemia. The information capable of being provided on the DIAB1 form is just too narrow for such a contextual condition such as diabetes and basing the decision to suspend a person's drivers licence based upon such limited information is bordering upon discrimination.
Please help me to improve this legislation for other diabetes mellitus suffers like myself who are being treated unfairly by an agency that cares little about the subjectivity of such a complex condition.
I call on you to put pressure upon the EU to redraft the directive that has led to this medically objectionable decision being enforced by the DVLA.