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

National Council on Independent Living 

MDE Minority Paper for a 17 inch low Transfer Surface Height

Submitted to the U.S. Access Board By the National Council on Independent Living
September 27, 2013

In our opinion, this issue goes back to the beginning. Before we ever met as a Committee, the need for lowered transfer surface heights was identified with regard to exam tables and imaging equipment. In plain language, one need that started all of this was transfer surface – being able to get to the medical equipment for a diagnostic exam like everyone else. The surface height we had recommended historically was 17 to 19 inches above the floor, which has been around for years in existing Standards. If you have to pick an “absolute” low number, it only makes sense to pick 17 inches for the low height providing access to the greatest number of individuals with disabilities in order to access a standard of healthcare equal to all other people.

We should not be picking a new low height! 17 inches has always been the low height most commonly referenced in accessibility Guidelines and Standards. We already agreed to the high height in this application which is 25 inches. So this is just about the low number for accessibility - and that has already been established for decades as 17 inches!

Most of the information we received from other experts in the field, studies done on seat height of mobility devices (never mind all of the people who use other types of mobility devices or are short in stature), and our own experiences as people with disabilities pointed to having the lowest height available, at a minimum for initial access and egress from the equipment.

The manufacturers represented on the Committee consistently offered arguments based (whether they admit it or not) on the current equipment they have on the market, or what can be offered without much research and development or re-engineering (a.k.a. cost). Most manufacturers on the Committee had a 19 to 21 inch surface available currently, with at least one having a product at 18. Their argument has always been that providing the lowest transfer heights would be an extraordinary expense and burden on the business community (their consumer), not based on how it benefitted a patient with a disability. This effort was never supposed to be about the manufacturers or the doctors. It is the charge of this committee to answer questions and come up with recommendations for accessibility, based by some members on engineering and others by experience. NCIL’s 30-plus years of experience as advocates for people with disabilities dictates that we continue to strongly insist that the U.S. Access Board maintain the low accessible height at 17 inches above the floor in order for medical and diagnostic equipment to be accessed by the greatest number of people.

Dr. Ed Steinfeld’s study and testimony presented to the Committee recommended a height of 17 inches to provide the greatest level of access, and he himself stated 18 inches would be a compromise. The study showed that increasing the low end to 19 inch height excludes many users, specifically over 30% of female manual chair users and over 15% of male manual chair users. It wasn’t our charge to come up with a reasonable compromise. It was our charge to come up with what numbers provided the greatest level of accessibility. That number on the low end must be 17 inches or we are excluding a large segment of people who happen to use mobility devices from accessing an equal standard of care.

How the new standards are implemented – some over time, some right away, or not at all – that is to be determined by the authorities having jurisdiction for enforcement - like the Department of Justice, whose contributions to this committee process have been greatly appreciated. NCIL represents individuals with disabilities and IL organizations that are run by and for people with disabilities, as do many of the other advocacy organizations represented on the committee. We came to this committee because we were uniquely qualified to bring decades of experience making things accessible that were once not – based on the needs of consumers with disabilities. However with such technical equipment and engineering, it is not for us to provide all the technical answers to the roadblocks presented by some manufacturers represented on the Committee. The Subcommittees spent way too much time trying to solve engineering problems, when the point was to understand accessibility needs and meet them. If we drove all of our advancements over time based on what currently exists, we would still be in the stone age. We must make recommendations based on what will work best tomorrow to provide an equally high standard of care to more people with disabilities.

We should not recommend things based on what equipment currently exists. We must recommend things based on what people with disabilities need for equal treatment. The manufacturers are still trying to tell us what is best for us. We have challenged the medical model and tried to promote person-centered treatment for decades. We have NCIL members across the country who have not had the same standard of care as everyone else just because they use a mobility device – a wheelchair that may very well be 17 inches above the floor to the seat surface. They are who this rulemaking is for.

NCIL urges the Access Board to consider this and other minority reports calling for the 17 inch low transfer height, and to continue their rich history of providing accessibility that serves the greatest number of individuals with disabilities, and in this case provides much needed improvements in health care for Americans with disabilities including our Wounded Warriors.