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

National Network of ADA Centers

National Network of ADA Centers, Minority Report- Transfer Heights.

In Section 5.1, pages 66 and 69, justifications for a higher transfer height is made at 25” and chapter 6 (page 139) a more clear discloser is given for a high height number and the exclusion of a low height transfer number. The report says there was much disagreement for the low height transfer number and because of time frames, the high height number was never called to question.

Part of the confusion for not coming to a low height number was the fact that a high number was never clearly factored into the discussions, nor was the distance of movement of 8”

The proposed standards have a clear transfer height factored into their proposal of 17” to 19” and the advisory states that a seating height can move any distance up or down as long as the proposed transfer height was available. The proposed standards are simple and clear enough to meet all the concerns of manufacturers and people with disabilities. The minimum low and high height for compliance are stated and still allow for higher heights for motorized chairs, scooters, and people who ambulate using walkers, crutches or other type of mobility device

Much discussion was given to 17” and 18” heights being too low and manufactures wanted a 19” low height. If the proposed standards are accepted for transfer height the needs of manufacturers are met and compliance is achieved and the availability to move up and down to any other height is available after a transfer is made.

Since the proposed standards for transfer height are met. the National Network of ADA Centers proposes no change to M302.2.1,

M302.2.1 Height. The height of the transfer surface during patient transfer shall be 17 inches (430 mm) minimum and 19 inches (485 mm) maximum measured from the floor to the top of the transfer surface.