This section attempts to provide a snapshot of commonly used types of diagnostic equipment currently sold in the U.S. retail market, building on the market information provided in the Preliminary RA. The Preliminary RA presented product and unit cost information for examination tables and weight scales. This Final RA updates that information, while also providing product information (and price information, in the case of examination chairs) for two other categories of MDE: examination chairs and imaging equipment. For all four categories, the Final RA identifies whether there are versions of these products that offer features similar to the technical requirements of the MDE Standards.

This brief market overview offers the public a general sense of the extent to which currently available diagnostic equipment already provides features similar to the technical specifications in the MDE Standards. This overview may also provide enforcing agencies that may adopt the MDE Standards (or similar requirements) in the future with some baseline information against which to assess the incremental costs of a proposed regulation. The information presented below is accurate at the time of the Access Board’s promulgation of the MDE Standards. However, the market for medical diagnostic equipment may change prior to any future rulemaking that implements the MDE Standards. The Access Board expects that when rulemaking agencies propose to enforce the Standards, they will carry out regulatory assessments that provide specific cost and benefit estimates relevant to their rules.

7.1. Informal Collection of Product and Price Information

To collect information on the diagnostic equipment on the market today, between January and July 2016 the Access Board reviewed information publicly available on the internet for products in four categories of medical diagnostic equipment that are covered by the MDE Standards: (1) examination tables; (2) weight scales; (3) examination chairs; and (4) imaging machines. For each of the four categories, the Access Board checked major medical equipment suppliers’ websites, selected several major manufacturers of each type of diagnostic equipment, and reviewed each manufacturer’s website for models in those product categories.28

While the Access Board reviewed information on individual products, it did not undertake a systematic review of every feature of every product to assess potential compliance with the MDE Standards. The level of specificity of publicly available information regarding each product varies by manufacturer and product line, and it would have been impossible to compare every feature of every product. Further, such a robust, systematic study would be inappropriate at this point, given that the MDE Standards have no mandatory application.

Throughout its informal review of publicly available information on currently available medical diagnostic equipment, the Access Board sought to collect information on the market as a whole, rather than assessing whether individual products would meet the MDE Standards. The Board relied on the suppliers’ and manufacturers’ websites for its information collection, including photographs, schematics, and other specification lists and descriptions provided by the manufacturer online. The Board did not directly contact any manufacturers to discuss their products, nor did it rely on manufacturers’ characterization of products as “accessible” when determining whether a product category contained available models with features similar to the Standards; the term “accessible” is not currently regulated with respect to diagnostic medical equipment. The Access Board does not endorse any product that it reviewed for this Final RA.

After reviewing product features for each manufacturer’s full line of equipment in a particular category, the Access Board sought to build a price range for each category of product using the prices of a portion of those models for which pricing was available online. Prices of exam tables, weight scales, and exam chairs were generally available for most (but not all) reviewed manufacturers; however, pricing information for imaging equipment was almost nonexistent online. For products where prices were available online, the Access Board obtained pricing for several models in each category. A number of online MDE suppliers listed both the manufacturer suggested retail prices (MSRPs) and discounted prices. As the actual price paid for a certain piece of medical equipment can vary widely depending on the supplier from which it is purchased and the type of contract a purchaser may have, the Access Board sought to collect and review MSRP data to control for variations in actual purchase price. MSRP data were not publicly available online for all products; thus the prices for each type of product reflect pricing for some of the models where the MSRPs were available. The prices reported here are likely higher than the actual prices that MDE purchasers would pay, because purchasers typically pay less than the MSRP, due to a special sale, volume discount, or other reasons. Nevertheless, the price estimates below provide a snapshot for the range of products available in a given product type. Appendix A contains links to the public websites where the Access Board obtained the product and price information.

In the sections below, the Access Board summarizes the findings for each category of commonly used medical diagnostic equipment addressed by the final rule. The summary generally describes the equipment, notes the technical specifications that are provided under the MDE Standards, indicates how many manufacturers and products the Board reviewed, and provides a general assessment of the availability of products with features similar to those required by the Standards. In addition, for each category of product, the Board provides a price range for the available models, and where possible, provides some general observations about the products that fall in the high and low ends of the price range.

7.2. Examination Tables

There are two general types of examination tables: (a) treatment tables and (b) exam or procedure tables. Treatment tables are the most basic type of examination tables, and are commonly found in first aid stations, school nurse offices, and other places where basic medical attention is provided. Treatment tables typically have a flat table-top examination surface. Some treatment tables have adjustable backrests that support patients in a reclined position; typically, they do not support patients in a seated position. Basic treatment tables are fixed-height, with a variety of base options including H-frame open bases and closed cabinet bases. Bases can be made out of wood, particle board, or metal, and some bases offer shelves and/or drawers. Treatment tables also come in adjustable-height models that are powered by either an electric motor or a hydraulic crank.

Exam/procedure tables typically have articulating backrests and can support patients in both seated and reclined positions. Exam/procedure tables can be either “power” or “manual” tables, with the two types differentiated by how the articulating backrest operates. Power exam/procedure tables have an electronic motor that can adjust the table height and control an articulated backrest from a flat, fully reclined position to a straight-seated position. Manual tables have a non-motorized, mechanical device such as a handle or button for the backrest adjustment; articulating backrests on manual tables support from a flat, fully reclined position to a semi-reclined position. These manual tables do not support a seated position, and the heights of their examination surfaces are typically not adjustable.
For both treatment tables and exam procedure tables, the fixed height and adjustable-height tables typically comprise separate product lines. The fixed-height tables tend to be more basic in materials and design than adjustable-height models. Adjustable-height tables may have a separate set of features, such as different upholstery, different configurations of shelves and cabinets, and headrest and footrests. As separate product lines, the may also have a separate set of available options, such as pillows, straps or safety rails, which may not available for fixed-height models. The width of the examination surfaces varies widely between models.

Under the MDE Standards, examination tables are covered by the technical specifications for diagnostic equipment that supports patients in a supine, prone, or side-lying position (M301). Exam/procedure tables that also support patients in a seated position must also comply with the requirements for diagnostic equipment that supports patients in a seated position (M302). See M101.2 (applying the MDE Standards to diagnostic equipment based on the “positions” they support). However, the primary difference between the specifications of M301 and M302 is the required width of the transfer surface. M301 requires a transfer surface with a width of 28 inches minimum, while M302 requires a width of 21 inches minimum. Thus, as long as the examination table has an “end” transfer surface at the seat end of the table and meets all other requirements of M301, the requirements for M302 will also be met. The technical requirements of M301 specify adjustability of transfer surface (examination surface) height (M301.2.1), the dimensions of transfer surface (M301.2.3), the provision of transfer supports (M301.3), and sufficient clearance in and around the base for a portable patient lift (M301.4).29

The Access Board reviewed treatment and exam/procedure tables built by five manufacturers. With respect to treatment tables, the five manufacturers produce a total of approximately 135 fixed-height models, and 35 adjustable-height models. Only three of the five manufacturers produce adjustable-height models. Some adjustable-height treatment tables adjust to a low height of 18.5 or 19 inches, which is within the low transfer height range of 17 to 19 inches specified by M301.2.1; however, a substantial portion of adjustable-height treatment tables lower only to 26 or 27 inches, which would not conform to the Standards.30 Treatment tables are available in varying widths, from approximately 24 inches to approximately 40 inches (for bariatric models). Several adjustable-height tables meet or exceed the 28-inch width requirement of M301.2.3. Most treatment tables appear to offer clearance for a lift either in or around the base (M301.4). Fixed-height treatment tables do not typically appear to offer any type of transfer supports, the provision of which is specified by M301.3. However, some adjustable-height treatment tables are available with optional “safety rails” on each side of the examination surface. The safety rails can be repositioned individually below the transfer surface during patient transfer, but it is not apparent from publicly available information whether the safety rails would meet the MDE Standards’ technical specifications for transfer supports, as described in M305.2.

With respect to exam/procedure tables, the five manufacturers reviewed by the Access Board produce approximately 28 total models of manual tables and 43 total models of power tables. Manual tables are not height-adjustable, and thus, would not meet the specifications for height adjustability of M301.2.1. Power exam/procedure tables are universally height-adjustable, and some adjust to within the 17 to 19-inch minimum low transfer height range of M301.2.1. Some power exam/procedure tables meet the 28-inch transfer surface width requirement of M301.2.3. Three of the reviewed manufacturers offer standard or optional grab bars, armrests, or safety supports for their power exam/procedure table models, but insufficient information was available to determine whether these grab bars, armrests, and safety supports would meet the technical requirements for transfer supports under M305.2. Most exam/procedure tables appear to meet at least one of the lift compatibility requirements of M301.4.

The table below summarizes our observations on the accessibility features currently available with treatment table models.

Table 2: Treatment Tables - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityFixed-Height Treatment TablesAdjustable-Height Treatment Tables
Transfer Surface Dimensions
(M301.2.3)
Width of transfer surface ranges from 24 to 30 inches. There are many 30-inch models available, which exceed the Standards’ technical specification of 28 inches. Width of transfer surface ranges from 27 inches to 40 inches for bariatric models.
Height Adjustability
(M301.2.1)

Fixed-height treatment tables do not adjust. Tables typically measure 31 to 32 inches from the floor to the top of the table.

 

All models are height-adjustable, with some lowering to within the Standards’ low transfer height range.

Base Clearance for Patient Lift
(M301.4)

All models appear to have sufficient clearance either in or around the base to accommodate a portable patient lift.

All models appear to have sufficient clearance either in or around the base to accommodate a portable patient lift.

Transfer Supports
(M301.3.1 and M305.2)

None observed.

 

Some models are available with optional “safety rails,” which can be repositioned below the transfer surface. It is not clear from available information whether these safety rails meet the Standards’ technical specifications for transfer supports.

 

 

The table below summarizes our observations on the accessibility features currently available with existing exam/procedure table models.

Table 3: Exam/Procedure Tables - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityManual Exam/Procedure TablesPower Exam/Procedure Tables
Transfer Surface Dimensions
(M301.2.3)
Width of transfer surface ranges from 26 to 28.5 inches, with tables from two manufacturers meeting the 28-inch transfer surface minimum width.

Width of transfer surface ranges from 26 to 34 inches (most models between 27 and 30 inches). Several meet the 28-inch transfer surface minimum width.

 

Height Adjustability
(M301.2.1)

No models have height adjustability. Examination surfaces measure 31 to 33 inches high, from the floor to the top of the table.

 

All models are height-adjustable. Several models adjust to a low height of 18 or 19 inches, which is within the Standards’ range for low transfer height.

Base Clearance for Patient Lift
(M301.4)

All models appear to have sufficient clearance around the base to accommodate a patient lift.

All models appear to have sufficient clearance around the base to accommodate a patient lift.

Transfer Supports
(M301.3.1 and M305.2)

None observed.

 

Three manufacturers offer grab bars, armrests, or safety supports as options. Available information is insufficient to determine whether they meet the Standards’ technical specifications for transfer supports.

 


 

Table 4: Examination/Procedure Tables - Price Ranges for Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

Table TypeLower-Cost Products (MSRP)Higher-Cost Products (MSRP)
Fixed-Height Treatment Tables  $500 – $850 $950 – $1,600
Adjustable-Height Treatment Tables

$1,800 – $2,100

$5,050 - $5,800
Manual Exam/Procedure Tables

$1,050

$2,500
Power Exam/Procedure Tables 

$2,150 – $3,500

$5,000 – $15,150



The price differential between lower and higher cost treatment tables appears to relate primarily to the type of base the table offers. Lower-cost treatment tables typically have an open base. By contrast, higher-cost fixed-height treatment tables have cabinets, drawers, or shelves in the base, and higher-cost adjustable-height treatment tables typically have a shrouded (metal encased) base. Manual exam/procedure tables typically offer cabinets, drawers, or shelves and, if marketed for OB/GYN use, they may have additional accessories such as pull-out footrests and attachable stirrups. Manual exam/procedure tables offer roughly the same options and functionality, regardless of price. Lower-priced power exam/procedure tables have open bases, pneumatic backrests, and manual footrests. Higher-priced power exam/procedure tables typically have premium upholstery, fully powered backrests, and power footrests.

Overall, fixed-height treatment tables and exam/procedure tables are significantly less expensive than adjustable-height models. The price differentials between fixed-height and adjustable-height models represent simply different products packaged with different parts. As discussed earlier, the fixed-height treatment tables and exam/procedure tables differ from adjustable-height models in terms of transfer height adjustability, but also in several other respects such as the width of the transfer surface and the presence of transfer supports. For example, adjustable-height models typically have wider transfer surfaces than fixed height tables. From our online search, we could not readily tease out the unit cost of each component in each model we reviewed.31 If the MDE Standards are adopted by an enforcing authority, fixed-height tables will not meet accessibility requirements, because they are not height-adjustable. One medical diagnostic equipment manufacturer has estimated that approximately 70% of all exam rooms in the United States feature a manual exam table.32 If this estimate is correct, a large number of healthcare providers may at some point need to acquire height-adjustable equipment, should a future rulemaking by an enforcing authority so require. In that case, the manufacturer providing the estimate indicated that it would not redesign manual examination tables to conform to the Standards, rather it would recommend that customers seeking accessible models instead purchase powered, height-adjustable tables and chairs that already conform.

7.3. Examination Chairs

The Access Board reviewed product and cost information for five types of examination chairs: obstetrics and gynecology (OB/GYN) chairs, dental chairs, optometry/ophthalmology chairs, phlebotomy chairs, and podiatry chairs. These chairs are associated with commonly used specialty medical practices. Each type of specialty chair has certain defining features. For example, OB/GYN chairs typically have pelvic tilt and stirrup options, whereas podiatry chairs have reclining backrests and leg-rests that articulate 90 degrees. We observed that particular models of chairs are marketed for more than one purpose. For example, optometry chairs may also be marketed as “Ears, Nose, and Throat” (ENT) exam chairs. Podiatry chairs may also be marketed as “procedure chairs,” “exam chairs,” or “aesthetic medicine chairs.” When determining in which category each particular model should be included, we relied on the manufacturer’s characterization of the chair and the Board’s own assessment of the chair’s primary features.

Examination chairs are covered by the technical specifications for medical equipment that supports patients in a seated position (M302). The specifications include: height adjustability of the unobstructed transfer surface (seat surface), with a low transfer height between 17 and 19 inches, and a high transfer height of 25 inches (M302.2);33 transfer supports (M302.3.1); and lift compatibility (M302.4), among other things. The technical specifications call for a transfer surface on the seat measuring 21 inches minimum in width and 17 inches minimum in length (M302.2.3), accompanied by a transfer support on one side (M302.3.1). Attached obstructions may be repositioned or removed during transfer to allow for unobstructed transfer (M302.2.5). If stirrups are provided, they must secure, position, and support the patient’s legs (M302.3.2 and M305.4). If the equipment is used in a reclined position, it must support the patient’s head and back while reclined (M302.3.3 and 305.5). As previously noted, examination chairs that also support patients in a supine position must also meet the requirements of M301. However, if the chair is always positioned in a seated position for transfer, and reclines to a supine position for diagnosis only after the patient has transferred, the chair does not need to comply with the requirements of M301 (M301.1 exception).

OB/GYN Chairs/Tables

OB/GYN diagnostic equipment comes in both chair and table designs. OB/GYN tables are typically examination tables with an articulating backrest, a “pelvic tilt” option, stirrups, and a pullout footrest. Several of the general use manual examination tables that we reviewed offer optional stirrups for OB/GYN diagnostic purposes. OB/GYN chairs typically resemble a standard examination chair with the addition of adjustable stirrups and the option for a “pelvic tilt.” OB/GYN chairs typically have an articulating backrest that reclines the equipment to a flat table position. Like OB/GYN tables, OB/GYN chairs accommodate patients in both seated and reclined positions. OB/GYN chairs are typically only available in power models.

The Access Board reviewed product information for thirteen OB/GYN chairs and tables produced by five manufacturers, including manual and power models. One of the unique features of OB/GYN chairs and tables are the stirrups that are provided to position the patient’s legs during the exam. Standard stirrups provide heel supports only, and would not be consistent with the MDE Standards’ technical specifications for leg supports, which require that where stirrups are provided, a method of supporting, positioning, and securing the patient’s legs must also be provided (M305.4). However, “knee crutches,” which support patients’ legs at the knee, are offered as an optional accessory by various manufacturers, and when used in conjunction with stirrups would be consistent with the Standards’ technical specifications. The Access Board’s observations are confirmed by two manufacturers who commented in response to the MDE NPRM that they already offer optional knee or leg crutch systems that would meet the leg support requirement, with the cost ranging from $500 to $1,100 per set.

Manual OB/GYN tables and power OB/GYN chairs have very different designs, and although they are used for similar types of exams, they are distinct products. Manual OB/GYN tables are fixed-height, and thus necessarily do not offer the height adjustability of the transfer surface specified by the Standards. Some models have bases constructed from plywood and laminate; others are made out of plastic. Some models offer electrical outlets within the base; others do not. The bases often include a pull-out step, flat pull out leg rest, and some have drawers or cabinets. Manual OB/GYN tables typically do not have transfer supports. Width of the examination surface varies by model.

Power OB/GYN chairs, however, are typically height adjustable, and all appear to meet the width requirements for the transfer surface for diagnostic equipment used in the seated position. Whether or not these chairs must also meet the requirements for equipment that supports patients in a supine position depends on whether a patient would only transfer onto the equipment in a seated position (M301.1 Exception). One of the reviewed models was sufficiently wide to meet the transfer surface width requirements for diagnostic equipment that supports patients in a supine position.
Some power chairs have moveable armrests that can be positioned during patient transfer; however, it is not apparent from publicly available information whether the armrests meet the technical requirements for transfer supports. While specific base dimensions were not available online, estimating from the size of the transfer surface, it appears that both manual and power models typically have enough clearance around the base for use with a portable patient lift.

The table below summarizes the Access Board’s observations on the accessibility features currently available with existing OB/GYN table and chair models.

Table 5: OB/GYN Tables and Chairs - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityManual TablesPower Chairs and Tables
Transfer Surface Dimensions
(M302.2.3 and M301.2.3)
Transfer surface dimensions meet requirements for seated MDE. They may not meet requirements for supine MDE. Transfer surface dimensions meet requirements for seated MDE. At least one model also meets the requirements for supine MDE.
Height Adjustability
(M302.2.1)

Manual tables are typically at least 30 inches high. They are not height-adjustable.

Transfer surface is typically adjustable. Some models meet the low transfer height specifications.
Base Clearance for Patient Lift
(M302.4)

Most manual tables appear to have sufficient clearance around the base for use with a portable patient lift, although base specifications information is not provided online.

Most power chairs appear to have sufficient clearance around the base for use with a portable patient lift, although base specifications information is not provided online.
Transfer Supports
(M302.3.1 and M305.2)

Manual tables do not appear to offer standard or optional transfer supports.

Moveable armrests are provided on some models; however, it is not clear from available information whether the armrests meet the technical specifications for transfer supports.
Stirrups that support, position, and secure legs (M302.3.2 and M305.4) Manual tables are typically offered with optional traditional stirrups that do not provide leg support and positioning. Some manufacturers offer optional knee crutches, which support, position, and secure the patients’ legs.

 

Table 6: OB/GYN Tables and Chairs - Price Ranges for Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

OB/GYN ChairsLower-Cost Products (MSRP)Higher-Cost Products (MSRP)
Manual Tables $1,050 - $1,150 $1,850 - $2,400
Power Chairs and Tables

$2,950 - $3,700

$6,100 - $7,500

 

Lower-priced OB/GYN power chairs and tables have a height-adjustable electric-powered base, and they typically have a pneumatic backrest and a manually adjustable leg rest. Higher-priced OB/GYN power chairs and tables also have a height-adjustable electric-powered base, but typically have an electric-powered articulating backrest. Manual tables have similar features, functionality, and aesthetics, regardless of price.

Again, manual tables are significantly less expensive than power chairs and tables. As discussed above, the manual tables differ from power models in terms of transfer height adjustability, but also in several other respects, such as the width of transfer surfaces and the presence of transfer supports. From our online search, we could not readily distinguish the unit costs of different components.

Dental Chairs

Dental chairs are typically narrower than other types of examination chairs, to allow for provider access to the patient. They are typically powered hydraulically with a fully adjustable backrest, integrated fixed footrest, double articulating headrest, and fixed or swing-away armrests.

We reviewed 24 dental chairs made by five manufacturers. Many dental chairs are height-adjustable; some are not. At least some current models appear to have continuous height adjustability spanning the full transfer height range specified by the MDE Standards. The length and width of the examination seat of most dental chairs typically exceeds the required dimensions of the transfer surface of diagnostic equipment used in a seated position. Due to their integrated footrests that prevent patient transfer on the end of the examination surface, accessible dental chairs must accommodate unobstructed patient transfer from either long side of the examination surface. Existing models of dental chairs typically have armrests, most of which can be moved out of the way during patient transfer. It is unclear from publicly available information on the internet whether these armrests currently meet transfer support technical requirements.

Dental chairs are typically cantilevered off of a solid base. Thus, it does not appear that dental chairs typically meet requirements for clearance in the base. It is not apparent from information available on the internet whether there are dental chairs that currently meet the “clearance around base” requirements.

The table below summarizes our observations on the accessibility features currently available with dental chairs.

Table 7: Dental Chairs - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityDental Chairs
Transfer Surface Dimensions 
(M302.2.3)
The seat of most dental chairs meets the minimum specifications for transfer surface size.
Height Adjustability
(M302.2.1)

The transfer surface (seat) height is adjustable for many chairs; some chairs have continuous (rather than discrete) seat height adjustability.

Transfer Supports
(M302.3.1 and M305.2)

Moveable armrests are available on many models. It is not apparent whether these armrests meet the technical specifications for transfer supports.

Base Clearance for Patient Lift
(M302.4)
It is unclear from available specifications whether sufficient clearance around the base exists with most models for patient lift compatibility.



Table 8: Dental Chairs - Price Ranges for Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

Dental ChairsLower-Cost Products (MSRP)Higher-Cost Products (MSRP)
Power Chairs $6,300 - $7,700 $8,850 - $11,650

  
Dental chairs appear to have fairly consistent functionality, appearance, and technology across models. The disparity in price appears to relate to the quality of the upholstery, the degree to which the chair tilts and swivels, the type of headrest, and features such as heat and massage systems.

Optometry/Ophthalmology Chairs

Optometry (and ophthalmology) chairs typically are upright, upholstered chairs with a headrest, leg rest, armrests, and flat footrest or foot bar. Optometry chairs typically rotate 330 to 360 degrees atop a solid base, which may or may not raise and lower the examination surface of the chair. There are three main types of chairs: chairs whose backrest manually reclines, chairs that tilt backward as an entire unit, and chairs with a fully articulating electrically powered backrest. Some manual chairs remain in fixed upright position and do not recline.

We reviewed product information for 21 optometry/ophthalmology chairs made by five manufacturers. Of the models we reviewed, some had seat widths exceeding the MDE Standards’ specified transfer surface width of 21 inches; some had seat widths of less than 20 inches. Due to their integrated fixed footrests that prevent patient transfer from in front of the equipment, the technical requirements of the MDE Standards would require that optometry chairs accommodate unobstructed patient transfer from either side of the seat. Optometry chairs typically have armrests that can be moved out of the way during patient transfer. It is unclear from information available on the internet whether these armrests currently meet the technical requirements for transfer supports. A main feature of optometry chairs is their ability to tilt a patient back for examination. All optometry chairs reviewed universally appear to provide the patient with head support while in a reclined or tilted position, which is consistent with the technical specifications of the rule. Optometry chairs typically rotate on a solid base. It appears that some models have sufficient clearance around the base for compatibility with a portable patient lift. None of the models reviewed appeared to lower to a height within the low transfer height range of 17 to 19 inches, although some models came close to the higher end of the range, lowering to 19.5 or 19.75 inches.

The table below summarizes our observations on the accessibility features currently available with optometry and ophthalmology chairs.

Table 9: Optometry/Ophthalmology Chairs - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityOptometry/Ophthalmology Chairs
Transfer Surface Dimensions
(M302.2.3)
Some, but not all, models meet the minimum specifications.
Height Adjustability
(M302.2.1)

Seat height is adjustable for many optometry/ophthalmology chairs; however, they did not seem to adjust as low as the 17 to 19-inch low transfer height range. Some models came within half an inch of a low transfer height consistent with the technical specifications.

Transfer Supports
(M302.3.1 and M305.2)

All chairs appear to support the patient’s head and back in reclined and/or tilted positions.

Head and Back Support
(M302.3.3 and M305.5)
All chairs appear to support the patient’s head and back in reclined and/or tilted positions.
Base Clearance for Patient Lift
(M302.4)

Base specifications are not available; however, some chairs appear to have sufficient clearance around the base for patient lift compatibility.

 

 

 

Table 10: Optometry/Ophthalmology Chairs - Price Ranges for Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

Optometry/Ophthalmology ChairsLower-Cost Products (MSRP)Higher-Cost Products (MSRP)
Full Power Procedure Chairs $5,850 $7,350 - $8,000
Tilt Chairs

$4,600 - $5,550

$6,350 - $7,000
Manual Recline Chairs

$3,450

$4,200 - $5,800

 

Optometry chair price ranges seem to create a continuum with manual chairs at the low end and full power chairs at the high end. Within each product group, the price range seemed to reflect aesthetic design, the amount of contouring and cushioning, and the type of upholstery. The functionality of the models within each product group is similar, with the exception that some of the manual chairs do not recline.

Phlebotomy Chairs

Phlebotomy chairs, also called “Blood Drawing” chairs, position the patient so that a technician can draw blood from the patient’s arm. Phlebotomy chairs typically have at least one wide armrest and a “flip arm” attached to the end of the armrest that is repositioned in front of the patient after he or she is seated. This additional armrest can swing either up or out from the chair to allow patient access. There are three types of phlebotomy chairs: fixed chairs, which sit at a fixed height on four legs; hydraulic chairs, which sit on a round metal base, and can be raised and lowered with a foot pedal; and power chairs, which are raised and lowered by an electric motor.

We reviewed 56 phlebotomy chairs made by eight manufacturers. None of the reviewed phlebotomy chair models met the MDE Standards’ transfer height requirements. As noted above, the main clinical feature of phlebotomy chairs is their wide armrests upon which a medical provider positions a patient’s arm to draw blood. Phlebotomy chairs typically have wide armrests on each side of the seat. The armrests are often height-adjustable and usually completely removable; however, with most models, the stationary posts that secure the armrests to the chair protrude above the seat surface and cannot be repositioned. Such stationary posts would obstruct the transfer surface of the chair, which is inconsistent with the technical specifications of the MDE Standards calling for an unobstructed transfer surface.

Fixed phlebotomy chairs are not height-adjustable; thus, none of the fixed chairs would comply with the Standards’ technical requirements for height adjustability of the transfer surface. Hydraulic and power phlebotomy chairs typically have adjustable height ranges of approximately 20 inches above the floor to 29 inches above the floor; none of the reviewed chairs had a low transfer height of 17 inches to 19 inches as required by the Standards. With respect to transfer surface dimensions, we observed that while all models have seats that are at least 17 inches long, the width of the seats varies from approximately 18 inches wide to 30 inches wide (in bariatric models). Thus, some models have sufficiently wide seats consistent with the MDE Standards’ specifications for transfer surface dimensions. Although specific dimensions are not provided online, the manufacturers’ photographs suggest that several models of phlebotomy chairs would meet the base clearance requirement for portable patient lifts.

Our observations with respect to the accessibility features currently available with existing phlebotomy chairs are summarized in the chart below.

Table 11: Phlebotomy Chairs - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityPhlebotomy Chairs
Transfer Surface Dimensions
(M302.2.3)
Seats are typically at least 17 inches long, which meet the required length in the Standards. The width of the seats ranges from 18 to 30 inches; only seats with widths of at least 21 inches meet the technical specifications for transfer surface dimensions.
Height Adjustability
(M302.2.1)

Seat height is not adjustable for fixed chairs; however, for hydraulic and power chairs, seat height is adjustable and ranges from 20 to 29 inches. None of the height-adjustable chairs reviewed meets the low transfer height specification of 17 to 19 inches.

Unobstructed Transfer Surface
(M302.2.5)

Chairs typically have wide armrests on each side of the chair, which are used to position the patient’s arm for blood draw. The armrests are usually adjustable and removable; however, some products have stationary posts that secure armrests to the chair, which protrude above the height of the top of the transfer surface, and would obstruct the patient transfer.

Transfer Supports
(M302.3.1 and M305.2)
Chairs typically have wide armrests, which may exceed the 2-inch cross-section dimension for transfer supports. 
Base Clearance for Patient Lift (M302.4)

Many models appear to have sufficient clearance around the base for use with a portable patient lift.

 

Table 12: Phlebotomy Chairs - Price Ranges for Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

Phlebotomy ChairsLower-Cost Products (MSRP)Higher-Cost Products (MSRP)
Fixed Chairs $400 - $850 $900 - $1,300
Hydraulic Chairs

$1,000 - $1,250

$1,300 - $1,500
Power Chairs

$1,800 - $2,050

$2,600 - $2,850


Within each product group, the products had similar functionality. The difference in price between the various models often reflected whether the seats were made out of molded plastic or padded upholstery, and whether they had an attached drawer for supplies. The higher cost products in both the fixed chair and power chair categories typically were bariatric models.

Podiatry Chairs

Podiatry chairs are typically fully powered exam chairs with a cushioned upholstery exam surface. Podiatry chairs tend to have fully articulating backrests with a fixed or integrated headrest; some models allow the entire chair to tilt back as a unit. The defining feature of a podiatry chair is an adjustable leg rest. Some models have separate leg rests for each leg that are independently adjustable. Many models are equipped with a debris tray within or underneath the leg rest.

We reviewed 12 podiatry chairs constituting the full line of podiatry chairs from five manufacturers. The width of the transfer surface (seat) for podiatry chairs ranges from 24 inches to 30 inches (bariatric models), which exceeds the transfer surface width specifications of the MDE Standards. The leg rests on podiatry chairs typically adjust down 90 degrees from the seat, and can therefore be positioned during transfer so as not to obstruct the transfer surface. Podiatry chairs typically have moveable armrests that can be flipped up out of the way during patient transfer. It is unclear from information available on the internet whether these armrests currently meet the technical requirements for transfer supports. All podiatry chairs reviewed appear to provide the patient with head support while in a reclined or tilted position. Podiatry chairs are typically height-adjustable, and some lower to 19 inches, which falls within the range of the low transfer height as specified in the MDE Standards. Podiatry chairs typically sit atop a solid base; thus, it does not appear that podiatry chairs would likely meet requirements for clearance in the base. However, some models may have sufficient clearance around the base to make them compatible with a portable patient lift.

The table below summarizes our observations on the accessibility features currently available with podiatry chairs.

Table 13: Podiatry Chairs - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityPodiatry Chairs
Transfer Surface Dimensions
(M302.2.3)
All chairs reviewed exceed the Standards’ specifications for minimum width of the transfer surface.
Height Adjustability
(M302.2.1)
Seat height was adjustable for all reviewed models; some models lower to 19 inches within the low transfer height specifications of the Standards.
Transfer Supports
(M302.3.1 and M305.2)

All reviewed chairs have armrests that can be flipped up during patient transfer. It is not apparent from available information whether these armrests meet the Standards’ technical specifications for transfer supports.

Unobstructed Transfer Surface
(M302.2.5)

Leg rests adjust down 90 degrees from the seat, and thus do not obstruct the patient’s access or use of the transfer surface. Armrests can also swing away from the transfer surface.

Head and Back Support
(M302.3.3 and M305.5)
All chairs appear to support the patient’s head and back in reclined positions.
Base Clearance for Patient Lift (M302.4)

Some models may have sufficient clearance around the base for use with a patient lift.

 

Table 14: Podiatry Chairs - Price Ranges for Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

Podiatry ChairsLower-Cost Products (MSRP)Higher-Cost Products (MSRP)
Power Chairs $4,350 - $7,200 $7,900 - $9,800

 

All reviewed chairs have similar functionality. The higher priced products may have higher quality upholstery and/or a wider seat. Two of the reviewed manufacturers do not list MSRPs online; thus, although we reviewed the products of five manufacturers, the price ranges in the table reflect three manufacturers’ pricing.

7.4. Weight Scales

We reviewed three types of weight scales: stand-on scales, wheelchair scales, and chair scales. We updated product data and unit costs of stand-on scales and wheelchair scales included in the Preliminary RA, and obtained recent product data for chair scales for this Final RA. We reviewed only models marketed for professional use. All three types of scales are available in mechanical and digital formats, although mechanical scales are increasingly uncommon.

Stand-On Scales

Stand-on scales are covered under the MDE Standards’ specifications for diagnostic equipment used by patients in a standing position (M304). The technical criteria under M304 of the final rules includes the provision of a slip-resistant standing surface (M304.2.1) and standing supports (M304.2.2). Although scales communicate information, the communication requirements of M306 do not apply to scales, because no information necessary for performance of the diagnostic procedure is being communicated directly to the patient; the medical professional performing the diagnostic procedure can complete the procedure without the scale communicating the patient’s weight directly to the patient.

We reviewed product information for 84 stand-on scales made by seven manufacturers. Stand-on scales are scales that have a platform upon which the patient stands to be weighed. Stand-on scales have platforms of varying sizes, and the MDE Standards do not provide specifications for the size of stand-on scale platforms. Some stand-on scale models are available with handrails; 23 of the models we reviewed offer some type of handrail. However, it is not apparent from information provided on the internet whether these handrails meet the technical specifications for standing supports. Most stand-on scales with handrails are digital; one reviewed stand-on mechanical scale was available in a version with a handpost at a slightly higher cost. Manufacturers’ typically describe stand-on scales as having an “anti-slip” or “skid-proof” surface.

The tables below summarize our observations on the accessibility features currently available with stand-on scales.

Table 15: Stand-On Scales - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityStand-On Scales
Slip-Resistant Standing Surface
(M304.2.1)
Most scales are marketed as having an “anti-slip” or “skid-proof” surface.
Standing Supports
(M304.2.2)
Handrails are available on many models; however, there is not enough information available to determine whether they typically meet the technical specifications for standing supports.


Table 16: Stand-On Scales - Price Ranges for Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

ModelsLower-Cost Products (MSRP)Higher-Cost Products (MSRP)
Mechanical without handrails $300 $400
Mechanical with handpost (1 model)

$500

$500
Digital without handrails

$350 - $650

$700 - $1,250
Digital with handrails

$750 - $1,000

$1,700 - $2,600

 

Higher-cost scales without handrails tend to have larger platforms, and higher-cost products with handrails are typically bariatric scales. While there is less variation in medical scales than with exam tables or chairs, there is still substantial variation in product design. Some models with handrails have larger standing platforms and elevated digital displays in contrast to products without handrails. As a result, we were able to figure out the unit costs of accessible features specified in the MDE Standards. There are too few mechanical scales with handposts on the market to draw meaningful cost comparison.

Wheelchair Scales

Wheelchair scales are covered under the specifications for diagnostic equipment used by patients seated in a wheelchair (M303). The technical criteria under M303 include sufficient space for a wheelchair to enter, exit, and remain on the platform during use (M303.2.2 and M303.2.3); edge protection to prevent a wheelchair from sliding off a raised platform (M303.2.6); and minimal change in level at entry (M303.3.1).

Wheelchair scales typically have a platform that is either installed flush with the floor or raised from the floor and accessed via one or two ramps.34 The MDE Standards specify the minimum dimensions for a single-ramped entry wheelchair scale as well as for a dual-ramped scale permitting pass-through from one end to the other. The technical specifications of the MDE Standards would require that a single-ramped entry platform wheelchair scale must have platform dimensions of 32 inches wide and 48 inches deep. A dual-ramped platform wheelchair scale allowing pass-through is permitted a depth of 40 inches. Wheelchair scales installed flush with the floor must be 36 inches wide, and 40 inches deep, assuming that the scale offers entry and exit on opposite ends of the scale.

We reviewed product information for 36 wheelchair scales (only one of which was mechanical), constituting the full line of wheelchair scales made by seven manufacturers. We observed that many of the reviewed products conform to the Standards’ minimum dimensions for platforms; however, some models had platform depths of 32 to 36 inches, which is not quite deep enough to meet the requirements. Some, but not all models, offer edge protection on ramps and raised platforms.

The table below summarizes our observations on the accessibility features currently available with wheelchair scales.

Table 17: Wheelchair Scales - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityWheelchair Scales
Platform Dimensions 
(M303.2.2 and M303.2.3)
Many, but not all, models meet or exceed the minimum requirements.
Edge Protection
(M303.2.6)

Many, but not all, scales have ramp and/or platform edge protection.

 

 

Table 18: Wheelchair Scales - Price Ranges for Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

Wheelchair ScalesLower-Cost Products (MSRP)Higher-Cost Products (MSRP)
Mechanical with Ramped Platform (1 model) $3,100 $3,100
Digital with Ramped Platform

$900 - $1,800

$2,450 - $5,850
Digital with Flush Platform

$3,900

$7,300

 

Less expensive ramped platform wheelchair scales tended to be portable models with smaller platforms. The most expensive products had handrails, a fold-down seat, and wireless capability. The cost of wheelchair scales with platforms flush with the floor generally correlated to the size of the platform – the bigger the platform, the more expensive the scale.

Chair Scales

Chair scales, which consist of a molded plastic chair suspended by a metal frame, weigh patients in a seated position. Typically, a chair scale has armrests and a footrest that is designed to ensure that the scale captures the patient’s full weight. Some chair scales have wheels attached to the base for ease of transporting the scale.

Chair scales are covered by the technical requirements for diagnostic equipment used in a seated position (M302). As discussed above with respect to examination chairs, the relevant requirements for diagnostic equipment used in a seated position include specifications for the height and size of the transfer surface (seat) (M302.2), and a requirement for transfer supports (M302.3.1), and lift compatibility (M302.4). The transfer surface of diagnostic equipment used in a seated position must be 21 inches wide minimum and 17 inches long minimum (M302.2.3).

We reviewed product information for 20 chair scales that comprise the full line of chair scales made by 8 manufacturers. Chair scales are not typically height-adjustable, so that the currently available models we reviewed do not meet the minimum height specifications of the MDE Standards. Chair scales typically have seats that meet the minimum dimensions for transfer surfaces; however, some chair scales are not sufficiently wide to meet the 21-inch width requirement. Chair scales typically have armrests, although from the available information, it is not clear if these meet the technical specifications for transfer supports. Some models have armrests that swing up to allow unobstructed patient transfer, as required by M302.2.5. The footrests on chair scales are typically adjustable but not necessarily removable. Chair scales typically have open bases; thus, it appears that some models may have sufficient clearance within the base to accommodate a patient lift, as described in M302.4.1. Most models appear to have sufficient clearance around the base to accommodate a patient lift, as described in M302.4.2.

The table below summarizes our observations on the accessibility features currently available with chair scales.

Table 19: Chair Scales - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityChair Scales
Transfer Surface Dimensions
(M302.2.3)
Many scales meet or exceed the minimum dimension requirements for the transfer surface.
Height Adjustability
(M302.2.1)
Seat height is not adjustable for most chair scales, which would not meet the transfer surface adjustability requirements.
Transfer Supports
(M302.3.1 and M305.2)

Chair scales typically have armrests, although from the available information, it is not clear if these meet the technical specifications for transfer supports.

Unobstructed Transfer Surface
(M302.2.5)

Some models have armrests that can swing up during transfer. Footrests may obstruct patient transfer.

Base Clearance for Patient Lift (M302.4)

Many chair scales appear to have sufficient clearance around the base.

 

 

Table 20: Chair Scales - Price Ranges for Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

Chair ScalesLower-Cost Products (MSRP)Higher-Cost Products (MSRP)
Mechanical Chair Scales

$700

$750
Digital Chair Scales

$800 - $1,250

$1,600 - $2,400

 

The chair scales reviewed had similar functionality, features, and aesthetics. Products at the very high end of the range had wireless capability to print patient results to a wireless printer. As shown above, digital chair scales are more expensive than mechanical models; the price differentials appear more related to the technology of the weighing mechanism and display rather than features relevant to the accessibility of the scale.

7.5. Imaging Equipment

Imaging equipment is typically used in a supine, prone, or side-lying position (such as a bone density scanner); or in a standing position (such as an x-ray machine). Persons with disabilities may also use imaging equipment while seated in a wheelchair (such as a mammography machine). Imaging equipment that typically is used in a supine, prone, or side-lying position (such as an x-ray table) may occasionally be used in a seated position depending on the image sought by the healthcare provider. Imaging equipment seeking to comply with the MDE Standards would be subject to the requirements for each patient position that the equipment supports.

The four types of imaging equipment the Access Board reviewed include: (1) imaging machines with bores such as magnetic resonance imaging (MRI) machines and computed tomography (CT) scanners; (2) bone density scanners; (3) radiology and fluoroscopy machines; and (4) mammography machines. Due to a lack of detailed product information available on the internet, we were unable to assess with specificity the extent to which existing products have features that are similar to the technical specifications in the MDE Standards.

In addition, because no pricing of new imaging equipment was publicly available on the internet, we are unable to present a general price range for these products. However, the Access Board has been told that the prices of imaging equipment are substantially higher than prices of the other three categories of diagnostic equipment discussed above. While a typical examination table may cost several hundred dollars and an exam chair several thousand, imaging equipment may cost hundreds of thousands or millions of dollars. The high price of imaging equipment reflects the advanced technology of imaging machines. In some instances, a manufacturer may produce a line of equipment that has physically similar models, which feature different types of technology to produce an image. Available technology ranges from analog (traditional film) to several generations of digital technology that link directly to workflow management software systems. Analog systems may be referred to as “value” or “economy” in marketing materials, suggesting lower prices for this type of technology.

Below, we provide a general overview of product information for existing models of certain types of imaging equipment.

Imaging Equipment with Bores

Several types of imaging equipment move a patient through a bore while he or she lies on a table, including magnetic resonance imaging (MRI) machines and computed tomography (CT) scanners. The table may be integral to the equipment, or it may separate and move via casters or wheels, allowing the patient to be transferred and prepared in another room before transport to the imaging equipment. The width of the bore dictates the maximum width of the table, as the table must fit through the bore for proper functioning of the equipment.

Imaging equipment with a bore is covered by the technical criteria for equipment that supports patients in a supine, prone, or side-lying position (M301). The technical requirements under M301 include: a transfer surface with a width of 21 inches minimum (M301.2.3); height adjustability of the transfer surface with a low transfer height between 17 and 19 inches (M301.2.1); transfer supports (M301.3); clearance in or around the base for compatibility with a portable patient lift (M301.4), among other requirements. The MDE Standards also require that information communicated through the equipment to the patient be communicated in at least two formats (M306).

We reviewed product information for 12 wide-bore MRI machines from five manufacturers and eight CT scanners from five manufacturers. Wide-bore MRIs typically have table widths exceeding 21 inches, ranging from approximately 25 to 29 inches. CT scanners, on the other hand, typically have table width of less than 21 inches, ranging from approximately 16 to 20.5 inches. Both types of equipment have height-adjustable tables. Wide-bore MRI tables have minimum heights ranging from approximately 17 to 27 inches, while CT scanners tend to range from approximately 17 inches to 23 inches high. Neither wide-bore MRI machines nor CT scanners have clearance within the base for compatibility with a portable patient lift. However, both types of equipment appear to have sufficient space around the base to accommodate a patient lift.

Neither wide-bore MRI machines nor CT scanners have transfer supports. The Medical Imaging & Technology Alliance (MITA), an association of imaging equipment manufacturers, asserted in a public comment in response to the MDE NPRM that the incorporation of support structures could have an impact on image quality, although it did not elaborate on how the image quality could be impacted.35 MITA indicated that redesign to incorporate transfer supports would involve a “significant technical impact,” but could not provide an estimate for the incremental cost of such a redesign. MITA noted generally, however, that the “economic impact would be lessened if features conforming to the Standards are incorporated in a [regularly scheduled] major new design plan.”

Imaging equipment with bores typically have communication features so that a medical provider can communicate instructions to the patient while the patient is inside the bore. Wide-bore MRI machines typically have gantry mounted LCD screens and intercom systems, and CT scanners have visual breath hold indicators and prerecorded messages. It is not apparent whether the instructions communicated to patients via these devices are communicated in more than one method; however, MITA indicated that the provision of two of the three communication methods (audible, visible, and tactile) could be incorporated into new designs.36

The table below summarizes our observations on the accessibility features currently available with imaging equipment.

Table 21: Imaging Equipment - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityWide-Bore MRI Machines  CTScanners
Transfer Surface Dimensions
(M301.2.3)
Width of the transfer surface ranges from 25 to 29 inches, all exceeding the minimum specification of 21 inches.  Width of transfer surface ranges from 16 to 20.5 inches, none of which meet the minimum specification of 21 inches.
Height Adjustability
(M302.2.1)
All models are height-adjustable; however, only a few of the reviewed models lowered to within the low transfer height range of 17 to 19 inches.  All models are height-adjustable. Several, but not all, adjust to within the low transfer height range.
Base Clearance for Patient Lift
(M301.4))

Models appear to offer sufficient clearance around the base. 

Models appear to offer sufficient clearance around the base.
Transfer Supports
(M301.3.1 and M305.2)

None observed.

None observed.
Communication of Information (M306)

An intercom system is typically provided inside the bore. It does not appear that communications are offered by an additional method.

Visual indicators and pre-recorded messages are provided to patients inside the bores. It does not appear that these communications provide the same information, or that information is provided via more than one method.

 

Bone Density Scanners

Bone density scanners, also called DEXA or DXA machines, are used by patients in a supine, prone, or side-lying position. They typically consist of a solid base fixed-height table, and a C-arm scanner that moves back and forth over a patient lying on the tabletop. The C-arm scanner is attached to a large x-ray system located within the base of the table. DXA machines are typically operated by a technician within the room who assists the patient with proper positioning; thus, DXA machines do not include communication features.

DXA scanners are covered by the requirements of M301 for diagnostic equipment used by patients in a supine, prone, or side-lying position (M301). The technical requirements under M301 address the minimum width of a transfer surface (M301.2.3); height adjustability of the transfer surface with a low transfer height between 17 and 19 inches (M301.2.1); transfer supports (M301.3); and clearance in or around the base for compatibility with a portable patient lift (M301.4), among other requirements.

We reviewed product information for 16 DXA scanners made by three manufacturers. We observed that DXA scanner tabletops are fairly wide, ranging from approximately 34 to 51.5 inches, which exceeds the Standards’ technical specifications for a transfer surface width of 28 inches. DXA scanners do not typically offer transfer supports, which the Standards require of all accessible diagnostic equipment used in the supine, prone, or side-lying position. DXA scanners are not typically height adjustable, although there are a few models that adjust between 27 and 30 inches in height. Industry representatives have indicated that the technology used in DXA machines, which is located inside the base of the table, cannot be reduced in size such that the scanners could be redesigned to meet the Standards’ height adjustability requirements, or low transfer height.37 Currently, most DXA scanners have fixed-height tables that appear to range in height from approximately 25 to 29 inches high. The Standards provide a general exception for structural or operational characteristics that prevent conformance with an applicable technical requirement. If structural or operational characteristics prevent conformance with an applicable technical requirement, the Standards require compliance to the maximum extent practicable (M201.2). If height adjustability is not achievable, and if the height of the table cannot be lowered due to technology that cannot be changed, the Standards do not require that those specifications be met. Some DXA scanners may have sufficient clearance around the base such that they are compatible with portable patient lifts to assist in patient transfer.

The table below summarizes our observations on the accessibility features currently available with bone density scanners.

Table 22: Bone Density (DXA) Scanners - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityBone Density (DXA) Scanners
Transfer Surface Dimensions
(M301.2.3)
The width of the transfer surface ranges 34 to 51.5 inches; all exceed the minimum specifications.
Height Adjustability
(M302.2.1)
Most models are not height-adjustable. A few scanners adjust between 27 to 30 inches in height, which is higher than the transfer height range specified by the Standards.
Base Clearance for Patient Lift
(M301.4)

Some models may have sufficient clearance around the base for compatibility with the patient lift; others may be too wide.

Transfer Supports
(M301.3.1 and M305.2)

None provided.


 

Radiography and Fluoroscopy Machines

Radiography (x-ray) systems and fluoroscopy systems can typically be used in both a supine and standing position. Radiography machines are typically mounted to the ceiling or to a post, and can be positioned both over a large flat radiography table and in front of a wall stand with a “bucky,” the drawer-like sleeve that holds an x-ray cassette and grid, for use in a standing position. In some models, the x-ray machine is attached to the radiography table by a C-arm. To use this model in the standing position, the entire table and C-arm is rotated 90 degrees. The patient then stands between the table and the C-arm while the image is captured. A wheelchair can also be positioned between the table and C-arm for imaging while the patient remains in his or her wheelchair, if clinically appropriate.

Radiography machines are available in analog (film) and digital models, but have similar physical structures regardless of the type of technology they employ.
Fluoroscopy machines, which produce x-ray imaging in motion, typically feature a fluoroscopy mechanism that is attached to a table on a C-arm. Combination radiography/fluoroscopy machines also have a C-arm attaching the combo x-ray/fluoroscopy mechanism to the table. Fluoroscopy machines and combo machines are designed to tilt 90 degrees while the patient is on the table. The table has a foot platform upon which the patient stands with his or her back or front flush with the table. The table tilts while the image is captured.

Accessible radiography and fluoroscopy systems would conform to the Standards’ requirements of diagnostic equipment used in a supine, prone, or side-lying position (M301) as well as those used in a standing position (M304). Where a patient remains seated in a wheelchair, requirements for diagnostic equipment for patients seated in a wheelchair would also be met (M303).38

We reviewed product information for 12 radiology and fluoroscopy machines made by four manufacturers. Limited technical specifications were publicly available online for radiology and fluoroscopy machines. Information on table width was available only for three of the reviewed models, but all exceeded the required 28-inch width. Manufacturers’ photographs of other models for which specifications were not provided suggest that most tables meet or exceed the 28-inch width requirement. Seven of the 11 reviewed models indicated height adjustability of the table, and two models provided specifications indicating that they could adjust to 19 inches, which is within the low transfer height range of the Standards. None of the reviewed tables appeared to offer transfer supports, although several tables appeared to have sufficient clearance around the base to accommodate a patient lift. Fluoroscopy machines that tilt to a standing position did not appear to offer standings supports. Information about the standing surface was not provided, thus it is unknown if the surface is slip-resistant.

The table below summarizes our observations on the accessibility features currently available with X-ray and fluoroscopy machines.

Table 23: X-Ray and Fluoroscopy Machines - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityX-Ray & Fluoroscopy Machines
Transfer Surface Dimensions
(M301.2.3)
The tables generally appear to meet the 28-inch width requirement, although width specifications were available for only three models.
Height Adjustability
(M302.2.1)
Several models are height-adjustable, and at least two lower to the low transfer height range of the Standards.
Base Clearance for Patient Lift
(M301.4)

Some models appear to have sufficient clearance around the base for use with a patient lift.

Transfer Supports
(M301.3.1 and M305.2)

None provided.

Slip-Resistant Standing Surface
(M304.2.1)

Insufficient information was available to assess whether fluoroscopy machines that tilt to a standing position have a slip-resistant standing surface.

Standing Supports
(M304.2.2)
Fluoroscopy machines, which tilt to a standing position, do not appear to offer standing supports.


 

Mammography Machines

Mammography machines are typically used by patients in a standing position. For patients that cannot comfortably stand or are unable to stand, some mammography machines can be used with a specialized chair, or while a patient is seated in her wheelchair. Mammography machines typically feature a central column with a height-adjustable breast platform that positions and compresses the breast for imaging. The breast platform may tilt to the left or right for better positioning. Mammography machines sometimes offer handholds for arm positioning, but they are not intended for use as standing supports.

The MDE Standards provide technical specifications for mammography machines only when used to diagnose patients while seated in a wheelchair. These specifications include provision of a wheelchair space oriented in the same direction as a patient not seated in a wheelchair would be oriented (M303.2.1). The breast platform must be continuously adjustable from a low height of 26 inches to a high height of 42 inches (M303.4.1). In addition, clearance beneath the breast platform for the knees and toes of the patient must comply with technical specifications (M303.2.4.1).

We reviewed eight mammography machines made by five manufacturers.39 For all of these machines, patients seated in a wheelchair orient in the same direction as patients who use the equipment while standing. All appear to have a height-adjustable breast platform, and several are consistent with the height range required by the Standards. Although the exact specifications are not available, the knee and toe space provided under the breast platform of most models appears to be consistent with the Standards’ technical specifications for knee and toe clearance.

The table below summarizes our observations on the accessibility features currently available with mammography machines.

Table 24: Mammography Machines - Accessibility Features on Sampling of Commercially Available Equipment (Based on USAB Informal Market Research)

MDE Standards’ Specifications for AccessibilityMammography Machines Designed to be Used by Patients Seated in a Wheelchair
Orientation for Wheelchair User Same as Non-Wheelchair User
(M303.2.1)
All models provide for orientation in the same direction as patients who use the equipment while standing.
Height Adjustability of Breast Platform
(M303.4.1)
Several models are height-adjustable, and at least two lower to the low height range of the Standards.
Knee and Toe Clearance
(M303.2.4.1)

Specifications of this space are not provided online; however, the knee and toe space provided under the breast platform of most models appears to be consistent with the technical specifications.