Comment from ELIU IRIZARRY

To Whom It May Concern: I appreciate the opportunity to comment on FMCSA's information collection regarding techniques for preventing and enforcing controlled substance and alcohol violations involving non CDL CMV drivers. As a transportation safety and compliance professional responsible for overseeing a nationwide fleet of non CDL commercial motor vehicles, I believe this research addresses an important gap in commercial motor vehicle safety. In my experience, there is a common misconception that non CDL CMVs present a significantly lower public safety risk than CDL vehicles. While differences in vehicle size and licensing requirements certainly exist, both groups are operating commercial motor vehicles on public roadways, often in densely populated areas, interacting with pedestrians, passenger vehicles, bicyclists, and other motorists. The consequences of an impaired driver operating a 10,001-26,000-pound commercial vehicle can be severe regardless of whether a CDL is required. From a safety management perspective, employers are expected to maintain safe operations, investigate crashes, train drivers, enforce policies, and protect the motoring public. Those responsibilities do not change simply because the vehicle does not require a CDL. I believe FMCSA should carefully evaluate whether current approaches to preventing and detecting controlled substance and alcohol violations provide an equivalent level of safety for non CDL CMV operations. While I recognize there are operational and economic considerations, any future recommendations should prioritize public safety while remaining practical for employers to implement. Several areas deserve consideration: Consistent expectations for commercial motor vehicle operators regardless of CDL status when operating vehicles subject to FMCSA regulations. Increased education and training for supervisors responsible for recognizing signs and symptoms of impairment. Collection of reliable national data to better understand the frequency and causes of substance-related violations involving non CDL CMV drivers. Identification of best practices already being used successfully by private fleets and other employers to prevent impaired driving. Many employers, including private fleets, already maintain drug and alcohol policies that exceed minimum federal requirements because they recognize that impairment risk is tied to operating a commercial vehicle, not simply to whether the driver holds a CDL. I encourage FMCSA to use this research as an opportunity to evaluate whether greater consistency between CDL and non CDL commercial motor vehicle safety programs would improve highway safety while balancing the practical realities faced by employers. Thank you for the opportunity to provide comments and for your continued commitment to improving commercial motor vehicle safety. Respectfully, Eliu Irizarry Transportation Safety & Compliance Leader