As indicated in Section 5.1.1, the MDE Advisory Committee recommends that equipment with transfer surfaces be height adjustable in continuous increments. That decision required the Committee to consider the ranges of heights through which adjustable MDE must move to accommodate individuals with disabilities getting onto the transfer surface. The Committee reached consensus that the highest point of this range must be at least 25” (Section 5.1.2). However, despite extensive discussion, review of available evidence, and recommendations from lengthy deliberations of the Examination Tables and Chairs Subcommittee (Section 3.2), the Advisory Committee failed to reach consensus about the recommended lowest or minimum height for adjustable-height transfer surfaces (Section 5.1.3). Recommendations split across three options:

  • 17”;
  • 18”, which was viewed by some proponents as a compromise position and by others as their preferred minimum height; and
  • 19”.

Given the complexity of this issue and the variety of views, the Editorial Committee debated at length how best to present the rationales offered by Advisory Committee members to support their preferred option. The Editorial Committee ultimately suggested – and the Advisory Committee agreed – that a relatively brief Section 6 should: describe the Committee’s deliberation process for the minimum height recommendation for transfer surfaces (Section 6.1); list information about the presentations that Advisory Committee members considered in evaluating the minimum height options (Section 6.2); and introduce the Minority Reports concerning this topic appended to this report (Section 6.3). Details about various Advisory Committee member perspectives on the minimum transfer surface height recommendations appear in these Minority Reports.

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

M301.2.1 and M302.2.1 would require the height of the transfer surface during patient transfer to be 17 inches minimum and 19 inches maximum measured from the floor to the top of the transfer surface. This height range is based on provisions in the 2004 ADA and ABA Accessibility Guidelines for
architectural features that involve transfers (e.g., toilet seats, shower seats, dressing benches).

Summary. Architectural and Transportation Barriers Compliance Board, Notice of Proposed Rulemaking, RIN 3014-AA40 Medical Diagnostic Equipment Accessibility Standards, February 8, 2012, p. 17.

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.

6.2 Presentations that Informed the Minimum Height Deliberations

As described in Section 3.3, Advisory Committee members considered several different types of evidence in their deliberations about the minimum transfer surface height recommendation. Different Committee members gave differing weights to the various types of evidence. The deliberative process did not require Committee members to agree about evidentiary standards (i.e., which type of evidence was most important or valid).

Presentations at meetings gave Committee members an opportunity not only to hear from individuals knowledgeable in relevant topics but also allowed for dialogue with the speaker, including discussions about the pros and cons of different minimum height options. As noted in Section 3.3.1, Edward Steinfeld, ArchD, attended the second Advisory Committee meeting and presented results from the Anthropometry of Wheeled Mobility Project, conducted at the Center for Inclusive Design and Environmental Access (IDeA) at the State University of New York at Buffalo. Dr. Steinfeld also spoke with the Subcommittee on Examination Tables and Chairs by teleconference about the minimum height question. A variety of stakeholders gave presentations representing various perspectives and making the case for different minimum height levels. Expanding upon the summary lists of presenters in Tables 3.3.2 and 3.3.3, Tables 6.2(a) and 6.2(b) indicate the presentation titles of the clinician speakers and industry representatives, respectively.

Table 6.2(a)

Presentations by Clinicians to Advisory Committee

 Name and Affiliation  Title of Presentation  Date
Barbara Ridley, RN, FNP
Alta Bates Summit Medical Center
U.S. Access Board: Advisory Committee on Medical Equipment   01/22/13

Cathy Ellis, PT
National Rehabilitation Hospital 

Michael Yochelson, MD
MedStar National Rehabilitation Network

Medical Diagnostic Equipment   01/22/13
Lauren Snowden, PT, DPT
Kessler Institute for Rehabilitation
Practitioner Perspective on Transfers to Examination Surfaces 01/22/13
Nüket Curran, PT
UPMC Centers for Rehabilitation Services
Diagnostic Equipment & Patient Accessibility: Closing the “GAP” 01/22/13
Douglas Coldwell, MD
University of Louisville
Medical Imaging 01/23/13
Theresa Branham, RT, ARRT
American College of Radiology
Technologist Perspective to Patient Access 01/23/13


Table 6.2(b)

Presentations by Manufacturers and Engineers to the Advisory Committee

 Name and Affiliation  Title of Presentation  Date
Willa Crolius, Coordinator of Public Programs, Institute for Human Centered Design  No Formal Presentation; presented a series of videos showing transfers   01/23/13
Michelle Lustrino, Mechanical Engineer, Hologic, Inc.  Mammography Industry:
Accessibility Standards 
Glenn Nygard, Senior Principal Engineer. Hologic, Inc  Dual-energy X-ray Absorptiometry (DXA) for Osteoporosis Assessment  01/23/13 
Elisabeth George, Vice President of Global Regulations & Standards Chair of Technical and Regulatory Affairs Committee, Philips Healthcare, MITA  Medical Imaging  01/23/13 

John Jaeckle, Chief Regulatory Affairs Strategist Chair of CT – Xray Committee, GE Healthcare, MITA 

John Metellus, Product Marketing Manager, Siemens Healthcare

Equipment with Bores and X-ray Devices Accessibility  01/23/13 

Bob Menke, Engineering Manager
Midmark Corporation

Jon Wells, Vice President of Marketing, Midmark Corporation

Examination Table Accessibility Standards  02/26/13 

Jeff Baker, President
Medical Technology Industries, Inc. 

Brad Baker, Executive Vice President, Medical Technology Industries, Inc. 

Darren Walters, Engineering Manager. Medical Technology Industries, Inc.

Performance and Efficacy Considerations for Examination Chairs  02/26/13 



6.3 Minority Reports

Because the Advisory Committee did not achieve consensus on the recommendation for a minimum transfer surface height standard, U.S. Access Board rules allowed individual Committee members to submit their views about this issue through a Minority Report. As shown in Table 6.3, the following Advisory Committee member organizations submitted a Minority Report, which appear in Appendix A. All Minority Reports were submitted voluntarily by Committee members and are unedited (i.e., the reports in Appendix A have not been altered through the Committee editorial process; the reports thus represent the views of the submitting organization as stated by that organization). A full reading of these Minority Reports is critical to understanding the range of views guiding the various stakeholder organizations that served on the MDE Advisory Committee about the recommendation for the minimum transfer surface height.

Table 6.3

Committee Members Submitting Minority Reports on the Minimum Transfer Surface Height

  • Boston Center for Independent Living
  • The ADA National Network
  • Brewer Company
  • Duke University and Medical Center
  • Equal Rights Center
  • GE Healthcare
  • Harris Family Center for Disability and Health Policy
  • at Western University of Health Sciences
  • Hausmann Industries, Inc.,
  • Hologic, Inc.
  • Medical Technology Industries, Inc.
  • Midmark Corporation
  • National Council on Independent Living
  • Paralyzed Veterans of America
  • Philips Healthcare
  • Siemens Medical Solutions USA, Inc.
  • United Spinal Association
  • University of the Sciences in Philadelphia