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Policy responses and statements
- Name of organisation:
- Driver & Vehicle Licensing Agency (DVLA)
- Name of policy document:
- The Second European Working Group Report on "Epilepsy and Driving in Europe"
- Deadline for response:
- 13 January 2006
Background: In 2002, the expert members of the EC Driving Licence Committee recommended that Annex III of Directive 91/439/EEC on the dirving licence should be updated. This Annex deals with minimum standards of physical and mental fitness for driving, but its contents are based on advice given some 20 years ago. There was therefore a recognised need to ensure greater consistency between the legislation and current knowledge.
To progress the initiative, specialised medical groups of physicians representing various Member States were set up to consider 3 priority areas: eyesight, epilepsy and diabetes. They each met between March 2004 and June 2005 and their results, conclusions and recommendations are now available in the form of reports which, for the moment, remain working documents subject to further discussion and evaluation.
Member States have been requested to consult their relevant national expert bodies to provide feedback to the Committee early next year. The College was asked for its consideration and appraisal of the report on Epilepsy and for feedback on its findings.
COMMENTS ON
DRIVER & VEHICLE LICENSING AGENCY (DVLA)
THE SECOND EUROPEAN WORKING GROUP REPORT ON "EPILEPSY AND DRIVING IN EUROPE"
The Royal College of Physicians of Edinburgh is pleased to respond to the Driver and Vehicle Licensing Agency on its consultation on The Second European Working Group Report on "Epilepsy and Driving in Europe".
The College has a number of comments regarding this report and, in general, finds the aims of this working group commendable. They have summarised and analysed the evidence relating to driving and epilepsy, identified gaps in knowledge and made recommendations. Ideally, this would lead to harmonization of the epilepsy driving regulations across Europe, and lead to rules that are "as liberal as possible, simple and clear". Unfortunately, this latter aim is not fully achieved by this document. Our specific comments are as follows:
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The recommendation on provoked epileptic seizures and group 1 driving is vague, and does not refer to the previously discussed 20-40% /annum risk recurrence being a reasonable criterion.
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No recommendations are made for patients who have had one or more episodes of loss of consciousness of uncertain cause that might or might not be epileptic; this is a common problem dealt with very clearly by the UK regulations.
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The suggestion that driving decisions should be made by a specialist independent of the treating physician is impracticable in the UK at present, given the number of epilepsy specialists/neurologists.
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A number of the recommendations would lead to some liberalization of the current UK rules, and would lead to some improvement in the restrictions that are such a burden for people with epilepsy, namely:
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Driving would be permitted 6 months after a first seizure, instead of a year.
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People with sleep seizures would be permitted to drive sooner than at present, and those with only seizures with no loss of consciousness would be permitted to drive after the seizure free period required for epilepsy
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Driving would be permitted much sooner for people with seizures occurring on antiepileptic drug withdrawal, following reinstatement of treatment.
Copies of this response are available from:
Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.
Tel: 0131 225 7324 ext 608
Fax: 0131 220 3939
[13 January 2006]
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