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

III. Proposed alternative mechanisms to enhance patient access to diagnostic imaging equipment

Given the constraints on table redesign due to diagnostic needs, and physical and engineering limitations of many of the wide variety of imaging tables, there will be many types of imaging tables that will not be able to achieve even a 19 inch minimum if the table itself must be modified. For example, in a CT/PET system, the patient support surface is located on top of a transporter, which adds to the height of the transport surface.

DXA bone densitometry systems are currently at a fixed height of 25-28 inches because the imaging hardware is located beneath the patient and the precise position of the patient support surface relative to the x-ray equipment is critical to the clinical efficacy of the device. In the case of DXA systems, it may be most effective to specify a specific range of fixed heights that the table could be at to facilitate independent transfer, similar to the fixed height standards for everyday items like benches, bathing fixtures, and recreational structures.

For all other systems, the Committee was told that it needed to consider only modifications to the tables themselves. To the imaging industry this seems to be a rather arbitrary constraint, and one that is not reflective of the system nature of diagnostic imaging systems, their installations, nor an actual requirement in the law.

We believe that system accessibility configurations discussed in Section 7 of the Committee’s Report,
i.e., ancillary equipment that is not attached directly to the table, but rather that is part of the room layout, will need to play an essential role in enabling more imaging equipment to meet the scope of the proposed new standards. These alternative means can take many forms, and their specific designs would need to be worked out with appropriate stakeholders to maximize safety, patient handling, and of course, access.

Implementation of these alternatives, and others, will allow many more patients with disabilities to access the equipment, and can be implemented far more quickly and cost effectively than the significant time
and costs which would be required for equipment re-design. Many aspects of the system accessibility configuration concept would also be able to be applied to systems already in use, thereby increasing their accessibility.

The added benefits of implementation of these alternative means are the significant savings in healthcare costs, timelier implementation and broader system coverage which would be realized due to avoidance of costly, equipment re-design costs. Since our mutual goal is to enhance and improve access of patients to medical diagnostic equipment, we urge the Access Board to give serious consideration to these alternative means which will enable us to quickly accommodate many more patients with disabilities.