                                       
TASK TITLE:  Doctors of Chiropractic and the Merchant Mariner Medical Examination 

PROBLEM STATEMENT:

The Coast Guard seeks the input of industry, via MEDMAC, on whether the agency should allow the merchant mariner medical examination to be conducted by doctors of chiropractic.

BACKGROUND:

Title 46 CFR10.302(b) requires that all merchant mariner medical examinations "be performed, witnessed, or reviewed by a licensed medical doctor, licensed physicians assistant, licensed nurse practitioner, or a designated medical examiner (DME)."  Members of professional chiropractic organizations have provided public comment at past MEDMAC meetings to request that the committee make recommendation to the Coast Guard to allow doctors of chiropractic to perform the merchant mariner medical examination. The agency has also received informal queries and formal petitions for rulemaking related to this issue in the past.  To date, MEDMAC has not taken up the issue as a formal task.
The general question at hand, is whether doctors of chiropractic have sufficient formal education and training to conduct merchant mariner medical examinations. The scope of practice for chiropractors varies by state, and in some states chiropractors are allowed to perform certain types of physical examination, including commercial driver exams. The Federal Motor Carrier Safety Administration (FMCSA) allows chiropractors to conduct physical examinations and issue medical certificates for commercial motor vehicle drivers, in states where their scope of practice allows.  The Federal Aviation Administration (FAA), however, does not allow chiropractors to conduct examinations for pilots seeking a medical certificate.   
With varying scopes of practice allowed by states, and with different practices among the other modes of commercial transportation safety, the Coast Guard invited the Council on Chiropractic Education to speak at the Spring 2016 MEDMAC meeting to provide information specific to the minimum levels of education and training provided to students of accredited schools of chiropractic.
   
DESCRIPTION OF TASK/DELIVERABLES:
Provide recommendations/findings for the following:
   1. To what extent does the formal education and training of doctors of chiropractic prepare them to conduct the merchant mariner medical examination?
   2. Whether the formal training and education received by doctors of chiropractic sufficient to provide them the clinical acumen necessary to ensure that mariner applicants have no conditions that pose a significant risk of sudden incapacitation or debilitating complication.  Please explain your answer.
   3. How do the practices of FMCSA and FAA, with regard to use of chiropractors, affect your recommendation with regard to merchant mariner examinations?
   4. Are there significant similarities/differences between the merchant mariner medical examination, and the merchant mariner work environment that should be taken into consideration in deciding whether doctors of chiropractic should be allowed to perform the merchant mariner medical examination? Please discuss.
   5. Whether the Coast Guard should undertake a rulemaking project to allow merchant mariner medical examinations to be performed by doctors of chiropractic.  Please explain your recommendation.

Coast Guard technical representative: Dr Adrienne Buggs. 

















                              Annex to Task 16-21
                                       
                        MISSION AND GUIDING PRINCIPLES
     Doctors of Chiropractic and the Merchant Mariner Medical Examination
                                       .
The Merchant Mariner Medical Advisory Committee (MEDMAC) hereby establishes a standing Working Group to provide recommendations to the Coast Guard on Doctors of Chiropractic conducting merchant mariner medical examinations.  
    
The Working Group shall make recommendations to the MEDMAC for the purpose of providing guidance to the Coast Guard on whether Doctors of Chiropractic should conduct merchant mariner medical examinations.    

The Working Group shall respond to specific task assignments requested by the Coast Guard or the Chair of the MEDMAC.

The Working Group shall make recommendations to the MEDMAC in the form of specific written reports.  

In carrying out its work the following guiding principles apply:

   1. The Working Group shall be chaired by one member of MEDMAC. 
   2. The Working Group may have participation from the public and other interested parties.  
   3. Meetings of the Working Group shall occur at regular meetings of the MEDMAC at a minimum.  Additional meetings may be called by the Working Group Chair or at the request of the MEDMAC Chair of the Coast Guard.  All meetings of the Working Group will be announced in the Federal Register.
   4. Meetings of the Working Group should be guided by Roberts Rules of Order and the Working Group Chairman shall organize and conduct the meetings.  In the absence of the Chairman, another MEDMAC member from the Working Group shall act as Working Group Chair. 
   5. The Working Group shall recognize the work and recommendations from previous Working Group work.

