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

M305.5 Head and Back Support (Section-by-Section Analysis)

As discussed above in Section V.C.3.c (Section-by-Section Analysis – M301.3.3) and Section V.C.7.c. (Section-by-Section Analysis – M302.3.3), the technical requirements for head and back supports from M301 and M302 have been relocated to M305 Supports. The MDE NPRM proposed to require diagnostic equipment used by patients in the supine, prone, or side-lying position and the seated position that can be adjusted to a reclined position to provide head and back support throughout the entire range of the incline. Three manufacturers commented on this provision. One manufacturer asserted that this requirement was ambiguous and that he had to read it multiple times to understand it; however, this commenter also indicated that the tables it currently manufactures meet the proposed requirement. Another manufacturer noted that existing MRI equipment meets this requirement. The final manufacturer asserted that a reclining backrest necessarily provides head and back support, unless the Access Board intended a different meaning for “support.” The MDE Advisory Committee did not review the proposed requirement for head and back support, and thus provided no recommendations on this requirement.

After review of the comments, the Access Board has decided not to make any changes to this provision in the final rule. All of the commenters on this topic agree that current diagnostic equipment meets the proposed requirement and the Access Board believes that this requirement is clearly articulated. Therefore, the final rule requires that where diagnostic equipment can be adjusted to a reclined position, head and back support must be provided.