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

M305.3 Standing Supports (Section-by-Section Analysis)

M305.3 provides the technical requirements for standing supports which are required on diagnostic equipment covered by M304. This provision has been reorganized in the final rule into requirements for length and height, as opposed to vertical and horizontal.

In the MDE NPRM preamble, the Access Board noted that it was considering adopting the cross section dimensions for grab bars from the 2004 ADA and ABA Accessibility Guidelines and applying them to standing supports. The Access Board sought public input in questions 39 and 40 in the MDE NPRM preamble on whether the cross section dimensions for gripping surfaces should be applied to standing supports and whether standing supports can provide a 1½ inch minimum clearance around the gripping surface. Three commenters responded to question 39 (a medical association, accessibility consultant, and a state agency concerned with accessibility). All three concurred with adding cross section dimension requirements to standing supports. Two commenters responded to question 40 (one medical association and a state agency concerned with accessibility), and both concurred that diagnostic equipment could provide a 1½ inch minimum clearance around the gripping surface of standing supports. The MDE Advisory Committee did not address the cross section and clearance proposal for standing supports. Unlike transfer supports, standing supports can be horizontal or vertical and thus there will be variations in the configuration of standing supports dependent on the equipment configuration. Due to this wide variety of allowable standing supports and the significant difference in the nature of how a standing support is used versus a transfer support, the Access Board has decided not to adopt cross section dimensions or require a minimum clearance around the gripping surface for standing supports in the final rule.

Additionally, one commenter (manufacturer) requested that requirements for structural strength be added to the standing support provision. For the same reasons the Access Board has removed the requirement of structural strength for transfer supports (See Section IV.E.1.a. (Significant Changes – Structural Strength) the Access Board declines to adopt such a requirement for standing supports in the final rule.

M305.3.1 Length (Section-by-Section Analysis)

In the MDE NPRM, the Access Board proposed a gripping surface length of four inches minimum for horizontal standing supports. No public comments were submitted on this requirement. The MDE Advisory Committee supported the proposed technical provisions, but recommended adding additional criteria for standing supports on raised platforms with wheelchair spaces. As discussed above in the Section IV.E.2. (Significant Changes – Standing Supports), the final rule requires that horizontal standing supports be positioned horizontally in relation to standing surfaces and retains the proposed requirement of four inches minimum length. The Access Board added a new provision applying to diagnostic equipment containing a wheelchair space that also requires standing supports. This provision, M305.3.1.2 in the final rule, has added two new requirements for this type of equipment. First, for diagnostic equipment containing wheelchair spaces with one entry that also serves as the exit, the length of the gripping surface for horizontal standing supports must be equal to or greater than 80 percent of the overall length of the platform. Second, for diagnostic equipment with wheelchair spaces that permit pass-through from one end to the other, the length of the gripping surface for the horizontal standing support must be at least equal to the length of the platform. In the final rule these requirements are located in M305.3.1.1 Horizontal Position and M305.3.1.2 Diagnostic Equipment Containing a Wheelchair Space.

For vertical standing supports, the MDE NPRM proposed a gripping surface length of 18 inches minimum. There were no public comments submitted on this requirement, and the MDE Advisory Committee supported the proposed technical provisions. In the final rule, the Access Board retained the original requirement for gripping surface length and clarified that the vertical standing supports must be positioned vertically in relation to the standing surface. Both requirements are included in the new M305.3.1.3 Vertical Position provision in the final rule.

M305.3.2 Height (Section-by-Section Analysis)

For horizontal supports, the MDE NPRM proposed a gripping surface height of 34 inches minimum and 38 inches maximum above the standing surface. There were no public comments on this requirement, and the MDE Advisory Committee supported the proposed technical provisions. In the final rule the Access Board retains the original requirement. This requirement has been relocated to M305.3.2.1 in the final rule.

For vertical supports, the MDE NPRM proposed that the bottom end of the support be 34 inches high minimum and 37 inches high maximum above the standing surface. There were no public comments on this requirement, and the MDE Advisory Committee supported the proposed technical provisions. In the final rule the Access Board retains the original requirement, but made a few minor editorial changes to the text. This requirement has been relocated to M305.3.2.2 in the final rule.

M305.3.3 Fittings (Section-by-Section Analysis)

The MDE NPRM proposed to prohibit standing supports from rotating in their fittings. There were no comments on this section and it was not addressed by the MDE Advisory Committee. The Access Board made no changes to this provision.