36 CFR Part 1195 Standards for Accessible Medical Diagnostic Equipment - Preamble

(1) Transfer Surface Location for Diagnostic Equipment Used in the Supine, Prone, or Side-lying Position

Multiple commenters expressed concerns that transfer cannot always occur at the end of the diagnostic equipment as contemplated by the requirements in the proposed rule. One commenter elaborated that stretchers and hospital beds are always entered from one or the other long side of the bed, not the foot end, due to obstructions at the head and foot ends that cannot be removed. Another commenter recommended allowing transfer space at both the center and the end of the transfer surface.

Evidence presented to the MDE Advisory Committee during its deliberations revealed that it is not always possible to transfer from adjoining sides at the end of the diagnostic equipment in the prone, supine, or side-lying position on certain types of equipment such as stretchers and imaging equipment with scanning beds. MDE Advisory Committee Report, 75-82, available at https://www.access-board.gov/guidelines-and-standards/health-care/about-this-rulemaking/advisory-committee-final-report. This is because many models of this equipment can be obstructed on the head or foot ends by necessary components such as emergency extraction handles, the gantry design, or integral patient positioning features. Id. For equipment with long patient examination surfaces such as stretchers and the scanning beds of many types of imaging machines, the foot end is not intended as a transfer point; patients transfer onto the surface on either of the long sides, approaching the equipment more towards the center. Id. Additionally, a transfer approach at the foot location may not be practical for many people with disabilities who would have to move themselves or be moved across a significant length of the surface to place their bodies into a position for effective imaging. Id. The MDE Advisory Committee recommended permitting an alternative transfer surface which was rotated in its orientation such that the width paralleled the examination surface’s length and its depth spanned the examination surface’s width, and was located near the center point of the diagnostic equipment surface. Id.

Based on the comments received and the MDE Advisory Committee recommendations, the Access Board has concluded that for diagnostic equipment used by patients in supine, prone, or side-lying positions two transfer surface orientations are possible depending on the intended location from which the transfer is to be made. These orientations are now identified as an end transfer surface and side transfer surface. This necessitated adding the definition of “end transfer surface” and “side transfer surface” to the defined terms (M102.1) in the final rule and resulted in the removal of the proposed M301.2.3 Transfer Sides, as that is now described within the two types of transfer surfaces provided. The end transfer surface accommodates the transfer method conceived of in the proposed rule; where the transfer occurs at one end of the examination surface and allows the patient the option to transfer at the end and on one adjoining side of the examination surface. The side transfer surface responds to the concerns raised by commenters and the MDE Advisory Committee to accommodate diagnostic equipment where transfer occurs within the length of the examination surface and allows patient transfer at the sides of the examination surface. Side transfer surfaces most typically will be imaging equipment, stretchers, hospital beds, and other equipment where the end is obstructed and cannot be used for transfer. Accordingly, the Access Board has reorganized the requirements regarding the transfer surface for M301 into two types based on where the transfer is to occur: “End Transfer” or “Side Transfer.” This revision to provide options for two types of transfer surfaces necessitated adding additional technical criteria addressing transfer surface size (M301.2.3) and transfer supports (M305.2), as well as adding the definition of “end transfer surface” and “side transfer surface” to the defined terms (M102.1) in the final rule. These new requirements are addressed below in the applicable section in the Section-by-Section Analysis.