First Amendment Action Time

First Amendment Action Time

Marty Russo, a retired Congressman, addressed the American Sleep and Breathing Association annual meeting last weekend with a strong call to action.

The commissions that oversee Railroad Operators and the Trucking industry have opened a public comment time for critical rule making associated with treating Obstructive Sleep Apnea. Marty talked about searching the current public comments and finding only one mentioning dentists at all, so he put together an action sheet. If we want the regulators to hear about oral appliances, it’s completely up to us to ‘petition our government,’ a right enshrined in our Constitution just for this very purpose.

Here’s what he advises us to do:

Dental Sleep Medicine Has A Big Opportunity

Speak Up To Federal Policy Makers – Let’s Be Heard In Washington

The Opportunity:
The U.S. Department of Transportation has requested public comments on proposed rulemaking about screening, diagnosing, treating and tracking compliance for OSA in individuals occupying safety sensitive positions in highway and rail transportation. These agencies need input from experts on the science of dental sleep medicine.

Federal Motor Carrier Safety Administration (FMCSA)
Federal Railway Administration (FRA)

How You Can Prepare:
Read the announcement outlining the proposed rulemaking. There are twenty specific questions about OSA that cover the areas of most interest to federal policy makers. Address the questions that most closely align with your expertise. The announcement can be located by going to your Internet browser and searching for these two docket numbers:

FMCSA-2015-0419

FRA-2015-0111

What You Can Do:
Online: Go to http://www.regulations.gov. Search separately for each docket number listed above. Follow instructions to make comments on each docket number.

a) Review comments

https://www.regulations.gov/#!docketDetail;D=FMCSA-2015-0419

b) Add comment

https://www.regulations.gov/#!submitComment;D=FMCSA-2015-0419-0001

    • Present your credentials and relevant experience.
    • Be concise and support your claims.
    • Use scientific evidence from dental sleep medicine. Include scientific studies on oral appliance therapy and your own experience as an expert. There is the ability to upload documents that support your position.
    • Address trade-offs and opposing views.
    • Include the costs and benefits to patients of your approach. It is especially important for oral appliance therapy to address costs and compliance.
    • Do not attempt any perceived commercialization for your product of services.
    • Comments are not votes, but one well supported comment is more influential than a thousand form letters.

DEADINE FOR COMMENTS IS July 8, 2016, 11:59 pm ET

DO NOT let this opportunity pass us by. If we don’t impress our views on the rule-makers, years will pass before we can have this chance again.