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MEDICAL DIAGNOSTIC EQUIPMENT ADVISORY COMMITTEE -

Minority Report Regarding: 17 Inch Low Transfer Surface Height

09.27.13

These organizations endorse this minority report. 

1. June Isaacson Kailes - Harris Family Center for Disability and Health Policy at 

Western University of Health Sciences 

2. Don Brandon -The ADA National Network

3. Kat Taylor - Equal Rights Center

4. Mark Derry - National Council on Independent Living

5. Maureen Simmons - Paralyzed Veterans of America

6. Kleo King - United Spinal Association

7. Tamara James - Duke University and Health System

8. Rochelle J. Mendonca - University of the Sciences in Philadelphia, Department of 

Occupational Therapy

A height range of 17 inches - 25 inches would accommodate a significant portion of 

people with disabilities. Data provided to the Committee and expert advice of medical 

practitioners led many to conclude that a lower height of 17 inches is essential to ensure 

safe transfers by patients with disabilities and thus, accomplishes accessibility for the 

greatest number of people. 

Studies of Wheeled Mobility Devices and Transferring Abilities

Accessible medical equipment needs to facilitate safe transfers that accommodate the 

largest possible portion of people with disabilities, including people who use wheeled 

mobility devices. The safest and most easily accessible transfers are those with no or 

very little horizontal and vertical distance between the seat of the wheelchair and the 

transfer surface. Specifically, transferring to a higher surface applies greater exertion of 

the upper limbs.

1

 

A study of wheeled mobility devices, including manual wheelchairs, power wheelchairs, 

and scooters examined the seat height of 495 users. The height was measured as the 

vertical distance from the floor to the lowest point of the seating surface of the mobility 

 

1

The Impact of Transfer Setup on the Performance of Independent Transfers: Final Report. Presentation to US

Access Board. Washington, DC. 2011
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device, while the occupant was seated in the device. Thus, the surface of the mobility 

device was in a compressed state. The study noted that a range of 17 inches -25

inches accommodates the vast majority of wheeled mobility device users, while 

continuing to exclude 6% of manual wheelchair users whose devices are lower than 17

inches. Increasing the low end to 19” height excludes many users, specifically over 

30% of female manual chair users and over 15% of male manual chair users.

2

There is limited information on the ability of people with disabilities to transfer to a height 

different from the height of their wheeled mobility device. The Impact of Transfer Setup 

on the Performance of Independent Transfers: Final Report provides an analysis of the 

effect of height, horizontal gap, placement of armrests, and placement of grab bars on a 

person’s ability to transfer. The study noted that 86% of wheeled mobility device users 

could transfer to heights that were 2 inches above and below the height of their wheeled 

mobility device. However, this study was not representative of the diversity of wheeled 

mobility device users. Individuals were explicitly excluded from the study if they had 

significant upper extremity pain or injury that affects the ability to perform transfers, or

had an active or recent history of pressure sores. Furthermore, the vast majority of 

subjects in the study were men.3 Numerous research studies as well as anecdotal

reports from people with a variety of mobility disabilities (spinal cord injury, cerebral 

palsy, polio, traumatic brain injury, etc.) have detailed and reinforced that fact that 

people who live with disability experience a greater prevalence of and earlier onset of 

age related conditions such as arthritis, pain contractures, weakness, deconditioning, 

and shoulder injuries etc.4

 

2 D’Souza, Clive and Edward Steinfeld, IDeA Center. Analysis of Seat Height for Wheeled Mobility Devices. 2011.

3

The Impact of Transfer Setup on the Performance of Independent Transfers: Final Report. Presentation to US

Access Board. Washington, DC. 2011

4

Jensen, M.P., Molton, I.R., Groah, S.L., Campbell, M.L., Charlifue, S., Chiodo, A., Forchheimer, M., Krause, J.S., 

& Tate, D. (2011). Secondary Health Conditions in Individuals Aging with SCI: Terminology, Concepts, and 

Analytic Approaches. Spinal Cord, 50(5): 373-378.

Groah, S.L., Charlifue, S., Tate, D., Jensen, M.P., Molton, I.R., Forchheimer, M., Krause, J.S., Lammertse, D.P., & 

Campbell, M. (2012). Spinal Cord Injury and Aging: Challenges and Recommendations for Future Research. 

American Journal of Physical Medicine & Rehabilitation, 91(1): 80. doi: 10.1097/PHM.0b013e31821f70bc. 

Available from: 

http://journals.lww.com/ajpmr/Abstract/2012/01000/Spinal_Cord_Injury_and_Aging__Challenges_and.10.aspx. 

Accessed December 18, 2012.

Turk M. Secondary conditions and disability. In: Field MJ, Jette AM, Martin L (eds). Workshop on disability in 

America. A new look. Summary and background papers. Board on Health Sciences Policy, Institute of Medicine of 

the National Academies, The National Academies Press: Washington DC, 2006, pp. 185–193. 

Kemp, B.J., & Mosqueda, L. (Eds.) (2004). Aging with a Disability: What the Clinician Needs to Know. Baltimore, 

MD: Johns Hopkins University Press.

Kailes, J. (2000). Health, Wellness and Aging with Disability, KAILES - Publications, 

http://www.jik.com/resource.html, jik@pacbell.net.
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Data Deficiencies 

Advocates on the committee, representing the interests of people with disabilities, 

strongly stated that a 17” height is essential to accommodate the largest segment of 

people with disabilities. While general information can be found regarding average 

height of wheeled mobility devices, and people’s ability to transfer, data is not available 

regarding the needs of people of short stature and people with mobility disabilities who 

do not use wheeled mobility devices. The promulgation of standards for accessibility is

required to take into account all people with disabilities, not just those who use wheeled 

mobility devices. In the absence of additional data, being inclusive versus exclusive is 

the most responsible approach in the development of standards.

Expert Advice of Medical Practitioners

Numerous practitioners commented on the importance of the availability of a lower 

transfer surface. Nüket J. Curran, PT, Director, Quality & Risk Management at UPMC 

Centers for Rehab Services, noted the importance of patient safety, staff safety, and 

ease of use. She stated that a 14 inch high transfer surface on tables and chairs would 

be ideal to facilitate the safest transfers, noting that 17 inches can be too high for some 

people. Ms. Lauren Snowdon, PT, DPT, Clinical Manager at the Kessler Institute for 

Rehabilitation, provided in depth analysis of the transferring abilities of wheeled mobility 

device users and the ideal height of transfer surfaces. Based on her experience that 

the general range of customized manual wheelchair height is 15.5 inches- 19.5 inches

and that power wheelchairs range from 16.5”- 22” high, she stated that the option of a 

17 inch high surface would be preferable to a 19 inch height. A 17 inch height allows for 

safer, easier transfers of patients whose wheelchair height is at the low end of those 

ranges. Other practitioners stated that the current height option of 18” was satisfactory 

and facilitated safe transfer for most patients. However, within this group, there was 

also a general consensus that a 17 inch height would provide greater accessibility, and 

enhance the safety of transfers for some patients. Given the importance of safe 

transfers and height ranges of wheeled mobility devices, a low height of 17 inches is 

considered by some to be a compromise solution. 

The Limits of Utilizing a Cost-Benefit Analysis

Many advocates strongly cautioned against attempting a strict cost/benefit analysis 

when ample data is unavailable. To our knowledge there are no studies that provide a 

fully comprehensive analysis of the effects of the height of a transfer surface on people 

with various disabilities. Additionally, every time a patient with a disability is denied 

 

Kailes, J. (1995). "Midlife Cripdom: Getting Fewer Miles per Gallon?" The Disability Rag 16(4).

Kailes, J. (2001). Aging with Disability - Good News and Bad News. Western U-View. XX: 17.
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access to health care due to an inability to access equipment, the cost is often far more 

than traveling to a different health care facility. Delayed diagnosis and treatment 

translates into higher HEALTH CARE costs due to the need for more extensive and 

expensive treatment. Furthermore, the cost of the systemic denial of health care to 

these individuals can be life threatening. 

There is additional risk to patients when medical practitioners attempt to manually 

transfer patients to diagnostic equipment. Risk of injuries due to being dropped, as well 

as skin shear and shoulder injuries can occur when the transfer surface cannot be 

adjusted low enough to accommodate a straight transfer for individual wheeled mobility 

devices of varying heights. The cost of medical practitioner injuries while performing 

these types of tasks has been widely documented and should also be considered. 

While, there are always practical limitations on accommodating every individual, in the 

case of access to a service as essential as health care, advocates strongly urge the 

Access Board to develop standards that are not only practical to industry interests, but 

will guarantee access to the vast majority of people with disabilities.