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2 hour testing and DVLA notification - inconsistencies?

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This thread is now closed. Please contact Anna DUK, Ieva DUK or everydayupsanddowns if you would like it re-opened.

Becka

Well-Known Member
[Mod Edit] This discussion was split from another thread

Yes, taking insulin does have those kinds of costs. (Other medications also do: anything where you might have hypoglycaemia requires informing the DVLA and may involve that kind of testing.)

And you only need to notify the D.V.L.A. if you have impaired hypo awareness, experience two severe episodes within the last year, or after one severe episode if it occurs whilst driving or you are a lorry or bus driver. Which though unlikely, applies regardless of medication taken.
 
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And you only need to notify the D.V.L.A. if you have impaired hypo awareness, experience two severe episodes within the last year, or after one severe episode if it occurs whilst driving or you are a lorry or bus driver. Which though unlikely, applies regardless of medication taken.
You do need to inform the DVLA if you are on insulin, they will take away your lifetime licence and replace it with one which has to be renewed every 3 years and then insist that you fill in medical forms and get your eyes tested before they renew it. My mum lost hers a few years ago now because she failed the eye test. (Well when I say she lost it, i mean it wasn’t renewed). She had never ever had an accident or any points in her licence in 49 years of being a driver.
I believe the testing every two hours rule is true also as many members on here have mentioned it, although I don’t know where to find evidence, I think @Pumper_Sue does
 
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Sorry, I should have been clearer and said "non-insulin medications." The point was that sulfonylureas like Gliclazide can cause hypos, but unlike insulin the D.V.L.A. do not need to know until you are unaware of them or have experienced severe ones.

You are correct about the two-hour testing rule for people taking insulin. And failure to monitor your levels would be taken into account by a court or insurance company if you had an accident. You are also supposed to stop driving if you levels are under 5 mmol/L, and the not resuming driving until you have been 5 mmol/L or greater for 45 minutes.

Meanwhile if you take Gliclazide you can drive at 4 mmol/L for as long as you like without taking a break and nobody cares!

Any diabetic can be prevented from driving certain vehicles if their diabetes causes issues with eyesight or circulation issues that can make them lose sensation of a vehicle's controls, though.
 
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For the avoidance of doubt, rather that basing any judgements on our differing understandings of the DVLA, I suggest anyone unsure consults the DVLA ‘assessment of fitness to drive‘ guidance, which is what our Drs are supoosed to be telling us, or asks the DVLA directly 🙂


For people on Sulfs and Glinides:

May drive and need not notify the DVLA, provided:​
■ no more than 1 episode of severe hypoglycaemia while awake in the last 12 months and the most recent episode occurred more than 3 months ago​
■ should practise appropriate glucose monitoring at times relevant to driving​
■ under regular review.​
So depending on how you read it, you must not drive for 3 months after any severe hypo, and must inform the DVLA if you have one. But you should not drive for at least 3 months after your second.

Ozempic (semaglutide) does not seem to be on the ‘inform DVLA’ list, but extra care must be taken if used in conjunction with either insulin or sulfs.

 
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It has always been stressed to me (as an insulin user) that checking immediately before driving and every 2 hours during a long journey is a requirement, rather than a suggestion. I believe part of my 3 year renewal application is signing to commit myself to doing so?
 
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It has always been stressed to me that checking immediately before driving and every 2 hours during a long journey is a requirement, rather than a suggestion. I believe part of my 3 year renewal application is signing to commit myself to doing so?
The form you fill in makes it clear that it’s a legal requirement, and as you rightly recall, you have to sign to say you will.
1.2 Do you agree to monitor your glucose/sugar levels at times relevant to driving?
* Times relevant to driving means testing less than 2 hours before the start of a journey, and every 2 hours after driving
has commenced. A maximum of 2 hours should pass between the pre-driving glucose check and the first glucose check after driving has commenced.
(!) This is a legal requirement for drivers with insulin treated diabetes
 
For the avoidance of doubt, rather that basing any judgements on our differing understandings of the DVLA, I suggest anyone unsure consults the DVLA ‘assessment of fitness to drive‘ guidance, which is what our Drs are supoosed to be telling us, or asks the DVLA directly 🙂

But now you have created doubt!

The advice to medical professionals that you have linked to differs to that given by the D.V.L.A. to the public at https://www.gov.uk/diabetes-driving . As a staff member I would suggest that Diabetes UK should take this up with relevant bodies to ensure consistent and correct guidance is offered.

In leaflet INF188/2 titled "Information for drivers with diabetes treated by non insulin medication, diet, or both" via the public website there is no separate guidance given to drivers who take any specific medication to monitor.


Similarly leaflet INF294 "A guide to insulin treated diabetes and driving" states that "Drivers with insulin treated diabetes are advised to take the following precautions … You should check your glucose less than 2 hours before the start of the first journey and every 2 hours after driving has started. …" This contradicts the medical professional guidance which says this is a requirement.


However there is only a legal requirement to undertake "appropriate monitoring to assess glucose levels and any risk of hypoglycaemia" if treated by insulin. There is no legal definition of appropriate that requires this to occur every two hours or in any other prescribed manner.

The Motor Vehicles (Driving Licences) Regulations 1999 set out the medical requirements for being issued a driving licence, but the version of it online has not been consolidated with its amendments. Fortunately the regulations regarding diabetes were added through an amendment (to implement an E.U. directive into U.K. law to harmonize requirements across all member states), so they can be easily read alone.


Those regulations also do not include any monitoring requirements on anyone taking non-insulin medications.

Following an update to the E.U. directives, a small amendment was made a few years ago to relax the "two severe hypo episodes" rule.


Incidentally, I had not realized the legislation does limit the refusal of a driving licence after two severe hypos to those taking a non-insulin "medication which carries a risk of inducing hypoglycaemia." I had trusted the official public guidance on that, which I now regret!
 
The advice to medical professionals that you have linked to differs to that given by the D.V.L.A. to the public at https://www.gov.uk/diabetes-driving . As a staff member I would suggest that Diabetes UK should take this up with relevant bodies to confirm the current guidance is offered.

Thanks @Becka. I was only offering my own understanding based in the guidance I was reading. If there is inconsistency between the guidance given to healthcare professionals, and ‘patient and public’ then that is quite worrying. And you are right, it would be helpful to have an authoritative response, so I will contact the information team for clarity on ‘requirement’ vs ‘advice’ and ask them to press the DVLA to ensure consistent and correct guidance is offered to both HCPs and people with diabetes.

In the mean time I would suggest that treating regular testing as a requirement as that seems to be the safer approach? I suppose my viewpoint is skewed towards regular check because as an insulin user you are reminded of the requirement so frequently!
 
Thanks @Becka. I was only offering my own understanding based in the guidance I was reading. If there is inconsistency between the guidance given to healthcare professionals, and ‘patient and public’ then that is quite worrying. And you are right, it would be helpful to have an authoritative response, so I will contact the information team for clarity on ‘requirement’ vs ‘advice’ and ask them to press the DVLA to ensure consistent and correct guidance is offered to both HCPs and people with diabetes.

In the mean time I would suggest that treating regular testing as a requirement as that seems to be the safer approach? I suppose my viewpoint is skewed towards regular check because as an insulin user you are reminded of the requirement so frequently!
A second definition of 'advise' in Collins online dictionary is ‘to inform or notify' which means a requirement. Its a pity they've chosen this word, because it can be confused with the first definition, which is more of a suggestion.
1.
to offer advice (to a person or persons); counsel
he advised the king
to advise caution
she advised him to leave
2. (transitive; sometimes foll by of) formal
to inform or notify


When the police 'advise you of your rights' I don't think they’re making a suggestion!
 
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When the police 'advise you of your rights' I don't think they’re making a suggestion!

And they are also not giving you an order. Your rights are not a requirement, they are just things of which you need to be aware. To advise is to either make a suggestion or to make aware of something.

In the case of the leaflet if the latter meaning was used it would say "you are advised you need to do something" as in "you need to be aware you need to do something." It would make no sense to say "you need to be aware to do something," that context can only be interpreted as "it is suggested you do something."

But as much as I enjoy linguistics (it was my favourite part of my first year at uni, but I changed courses so could not continue it), I linked to the actual legislation so there is no need to try and interpret words when you can see there is no such requirement. As I said on another topic recently, when I want to understand something I research it rather than just read headlines.

I know I can get carried away, but it meant I could be certain when I said that the two-hourly testing is not a legal requirement but will be taken into account. Because the only legal requirement is that a driver taking insulin "undertakes appropriate blood glucose monitoring" (Reg. 72(6)(b)). Such a regime would meet this requirement, but it does not preclude you being able to demonstrate that you follow another appropriate regime.

And sorry, but I do not understand why you want to discuss the noun "advice," but I think you misunderstand the second meaning. This refers to formal notifications which proffer specific information, usually financial or legal, but they do not create requirements. To be clear, legal advice may contain requirements but the advice is only relaying them, it does not create or compromise them. It only makes you aware of them existing elsewhere, and the advice could be wrong.

I would recommend the examples given on Oxford's online dictionary which are very good.

 
Hello again

I’ve had a very prompt response from the information team, and the policy team will be looking into it further.

Hope this helps! (My emphasis)

At the moment, the best source of information to try to resolve any confusion is “Assessing fitness to drive: a guide for medical professionals” - https://www.gov.uk/government/publi...ss-to-drive-a-guide-for-medical-professionals At the risk of stating the obvious, it’s aimed at medical professionals so the language is quite technical in places. But it is in the public domain, so no reason people can’t be signposted to it. It is updated every 6 months, so I always direct people to the webpage from which to downloaded it, rather than directly to the document. This ensures they are accessing the current version.

In terms of the queries in your email.

  • Appendix A, p115 sets out the legal basis for the medical standards and explains that under the Road Traffic Act 1988, as an overarching rule, anyone suffering a medical condition which makes it potentially dangerous for them to drive must not be licensed. However, there are situations where a licence can be granted provided certain conditions are met. So things like testing blood glucose every 2 hours fall under conditions for driving safely, so a requirement, rather than advisory. Further, it is explicitly mentioned as a “requirement of licencing” on p73.
  • Chapter 3, p70 covers diabetes generally and diabetes treated by medication other than insulin is covered on p76. The information uses double negatives extensively which makes it a little difficult to follow. But, basically, people taking sulphonylureas and glinides should notify the DVLA if they have had a severe hypo whilst awake within the last 3 months. They definitely have to stop driving if the severe hypo occurred while driving. It’s not entirely clear if they must stop driving if it occurred at any other time. So probably recommend that this situation is discussed with their HCP as a matter of urgency.
  • Blood glucose testing 2 hours before and every 2 hours during is required for people taking sulphonylureas and glinides – see 76
 
And sorry, but I do not understand why you want to discuss the noun "advice," but I think you misunderstand the second meaning. This refers to formal notifications which proffer specific information, usually financial or legal, but they do not create requirements
I think we are violently agreeing here! B** Autocorrect changed advise to advice at the start of my post! I’ve now corrected it. It was the definition of 'advise' that I was quoting, which is broadly the same as your Oxford dictionary definition.
I don’t misunderstand the legal meaning of advise (I’m a retired Lawyer). The wording here is to advise people (ie, inform them) that 'They should' test, 'Should' being the part of the wording that contains the instruction and creates the requirement. I agree, it’s not the clearest meaning, but as I quoted in Post #6 it’s much clearer in the form you actually have to sign and return.
I'm not actually sure whether there is any other form of monitoring you could undertake that would be the equivalent of the two hour testing, Libre readings are now accepted, but you’d still have to swipe and look at them every two hours to fulfil the criteria. Lawyers normally try to 'future proof' any legislation, but when it comes to it, if it needs clarification due to the invention of some new technology, all they’ve got to do is draft an amendment.
 
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An amendment without punctuation for the avoidance of any misinterpretation obviously LOL
 
I’ve had a very prompt response from the information team, and the policy team will be looking into it further.

Has there been any updates to this?

I re-read INF188/2 yesterday after someone on the forum asked about the driving rules (in the thread below) to see if anything had changed. But there has still been no update to the leaflet.


It is all well and good the shadowy figure behind the scenes saying that they direct people to the guidance for medical professionals as it is in the public domain, but how many diabetics do they get to talk to? At no point was I ever told by anyone to read it, nor told to ignore the advice the government specifically published to explain what a driver needs to do.

And it would never have occurred to me to just assume such advice might be wrong, assume there exists a document aimed at medical professionals, assume it is publicly available, and assume I need to read it to know what I should do. It is near impossible to think anyone who is not a obsessed with detail as me would ever end up going down such a chain of events!

No would I expected doctors to examine every bit of information to discover that the publicly stated advice does not match that which is shared with them. I do not recall being told anything at all, but had I been it would no doubt have been just to read the government leaflet. Unless a doctor has concerns over someone's fitness to drive, why would they do anything other than direct them to that?

I also disagree with the shadowy figures's statement that
Blood glucose testing 2 hours before and every 2 hours during is required for people taking sulphonylureas and glinides – see 76

Page 76 only says those on such medications "should practise appropriate glucose monitoring at times relevant to driving." Nowhere does it define what is appropriate. This is in contrast with the guidance for those who take insulin (page 72) where it instead states someone issued a licence "practises appropriate glucose monitoring as defined in the box below," the box setting out the two-hour rules as in leaflet INF294. The box is also titled "Group 1 and Group 2 requirements for insulin-treated drivers licensed on review," so is unambiguously in not being relevant to those on sulphonylureas.

This is also relevant to my curiosity on discovering the different guidance that C.C.G.s have for testing requirements and prescribing test strips to patients with T2DM. Most do state that more strips should be prescribed if necessary to meet D.V.L.A. requirements, but as those requirements are not defined it does not help patients ensure they receive enough.

I pointed out the Walsall guidance in the thread below, and they state for those on sulphoylureas that there is no need to routinely test, and only give HGV and PSV drivers in the list of exceptions to that. Normally when the weather is good I would go on 300–400 mile day trips on my bike at the weekend, so have been testing 7–8 times to satisfy the D.V.L.A. Even in an abundance of generosity, had I moved to Walsall a second pot every three months would have still quickly ran out. Even their one pot per month for insulin treated T2DM would not last in a good month.


Obviously none of this applies to me now anyway, but I still think it is an important issue. Because it seems that the D.V.L.A. have an undefined requirement that is kept secret from the public, and that medical professionals do not really understand either.

I think Diabetes U.K. needs to talk to the D.V.L.A / government to:

* Define what is the appropriate level of testing for those treated by sulphonylureas and glinides.

I never had a hypo while riding, I never was told to test when doing so, I have hypo awareness, so for me not testing never seemed inappropriate. I am guessing in hindsight the D.V.L.A. would disagree, but technically I was following their unbeknownst-to-me rule.

* Update leaflet INF188/2 so that diabetics and not just medical professionals are aware of such a rule.

Even if they want to stick with the ludicrously vague "appropriate," at least tell people they should be using their judgment rather than expecting them to spontaneously realize they need to seek out documents aimed at medical professionals/

* Ensure N.H.S. commissioning groups and trusts are aware of the requirements.

So that it gets included in policies and patient can ensure access to testing rather than having to fight to meet such rules. In the thread above, Lucyr said how she had to fight to get more test strips despite being on M.D.I. therapy so needs to follow the two-hour testing rules. There is probably also a case for discussions with the N.H.S. or NICE for standard policies on testing requirements for T2DM on sulphonylureas or insulin, though that is another matter.
 
Although I was giving a leaflet on levels on driving and test strips when put on Glicliazide, I only got 50 a month. Though that was probably 10 years ago.
 
Has there been any updates to this?

Thanks @Becka

It certainly does still seem confusing. I’ve emailed the Information team to see if there have been any updates
 
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