To Whom It May Concern,

We are deaf commercial truck drivers who currently must renew our hearing waivers every two years under FMCSA regulations. We respectfully request a change to this policy for individuals who are profoundly deaf.

Profound deafness is a permanent condition. Some of us were born profoundly deaf, while others lost their hearing during infancy or childhood. In either case, our hearing loss is lifelong and cannot be improved or reversed. Therefore, requiring a hearing waiver renewal every two years places an unnecessary burden on drivers with a condition that will not change.

We recognize that individuals who are hard of hearing may experience gradual hearing loss over time, especially as they age. These individuals may require periodic hearing evaluations to determine whether a waiver is still needed. A two-year renewal process may be appropriate in such cases, especially if their condition is not yet considered profoundly deaf.

However, profoundly deaf individuals have had years - if not a lifetime - of experience adapting to their balance and spatial awareness without relying on hearing. We believe this distinguishes us from those with progressive hearing loss and justifies a different standard.

We propose that individuals who can provide medical documentation confirming a diagnosis of profound deafness be granted a permanent hearing waiver, provided there are no other medical conditions that require monitoring. If a driver has additional waivers for other conditions, those can continue to be reviewed on a two-year basis as needed.

For those with progressive hearing loss or age-related hearing decline, the existing two-year renewal process could remain in place until or unless they are diagnosed with profound deafness. At that point, they too could be eligible for a permanent waiver.

We hope FMCSA will consider this distinction between profound deafness and partial hearing loss and update the hearing waiver policy to better reflect the permanent nature of our condition.

Thank you for your time and consideration.

Sincerely,

Christa Butner