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U.S. Access Board Seeks Public Comment on Final Specification for Low Transfer Surface Height of Medical Diagnostic Equipment

May 23, 2023

Medical diagnostic care is essential to everyone, including people with disabilities, and often requires people to transfer onto diagnostic equipment, such as examination tables and chairs, for evaluation. Historically, medical diagnostic equipment (MDE) has been, and continues to be, inaccessible to many people in wheelchairs, which can lead to misdiagnosis or barriers to basic care and examinations. The U.S. Access Board has issued a notice of proposed rulemaking (NPRM) on standards for accessible medical diagnostic equipment regarding one provision on the low transfer surface height for certain types of MDE used by patients in a supine, prone, side-lying, or seated position. 

The MDE Accessibility Standards require an adjustable transfer surface height with a high height of 25 inches, a low height range of 17 – 19 inches, and four intermediate heights within the high-low range. The Board created the 17 – 19-inch range for the low transfer surface height due to a lack of consensus on the MDE Advisory Committee and to allow the Board to conduct further research on the issue. Since the publication of the MDE Accessibility Standards, the Board commissioned a statistical analysis of occupied seat heights for manual and powered wheelchair users. In January 2022, the “Analysis of Low Wheelchair Seat Heights and Transfer Surfaces for Medical Diagnostic Equipment” Final Report was published, and the Board invited public comment on the findings in the final report and any new information regarding the low transfer surface height provision. In May 2022, the Board also held a MDE public meeting and accepted written comments to obtain further information on the appropriate low-height specification of transfer surfaces for MDE. 

In this NPRM, the Board is proposing to remove the sunset provisions and require a low transfer surface height of 17 inches. The Board seeks information on costs of compliance, time needed to comply, other research studies, and any other resources, data, or information the Board should consider regarding its proposed minimum low transfer surface height requirement of 17 inches. More information can be found in the NPRM published in the Federal Register

Public comments for the NPRM are due by July 24, 2023. Individuals may submit comments via any of the following methods:  

Office of Technical and Information Services  
U.S. Access Board   
1331 F Street NW, Suite 1000 
Washington, DC 20004-1111   

For background and more information, access the docket via  For further information, contact Bobby Stinnette at 1-202-272-0021 or, or Wendy Marshall at 1-202-272-0043 or