Recommendations on Standards for the Design of Medical Diagnostic Equipment for Adults with Disabilities, Advisory Committee Final Report

6.1 Deliberative Process

Box 6.1 shows the transfer surface height recommendation in the February 2012 Notice of Proposed Rulemaking on MDE accessibility standards (Section 1.3). At its first meeting, the Advisory Committee considered this NPRM recommendation of 17” to 19”, which applied to either fixed or adjustable height transfer surfaces. An initial Committee decision was to recommend adjustable height transfer surfaces, and this 17” to 19” range for the minimum height was consistent with the NPRM. However, some Committee members worried that setting a range (17”-19”) as the putative “minimum” value would be confusing, especially since the Committee recommended a single value (25”) as its high height. Several members interpreted the range as essentially setting the low point at 19”, while others felt that a range recommendation recognized 17” as a “best practice.” In an effort to be consistent and establish a clear minimum, the Committee focused its subsequent deliberations on a single endpoint for the transfer surface low height recommendation.

Box 6.1

Across all meetings the Advisory Committee spent considerable time examining available evidence, consulting experts, and discussing the merits of the three minimum height options. The Examination Tables and Chairs Subcommittee held six meetings, at which this issue was considered in depth. At the subcommittee’s final meeting, members agreed to recommend to the Advisory Committee 19” as the minimum height standard, with 17” recommended as a “best practice.”

At the final in-person meeting, all Advisory Committee members (including those participating by teleconference) were asked to state their recommendation among these three options and their willingness to change that recommendation to reach consensus. These statements of preferences polling revealed a Committee virtually evenly split between the 17” and 19” options, with a few individuals suggesting a compromise at 18” and a few preferring 18” outright. After this initial stating of views, Advisory Committee members were asked to indicate whether they would be willing to compromise to 18”, but many Committee members continued to support their original views. The Advisory Committee therefore agreed that despite their best efforts to reach consensus on this recommendation, member views remained split.