MDE Minority Paper for a 17 inch low Transfer Surface Height

Submitted to the U.S. Access Board By the National Council on Independent Living

September 27, 2013

In our opinion, this issue goes back to the beginning. Before we ever met as a 

Committee, the need for lowered transfer surface heights was identified with regard to 

exam tables and imaging equipment. In plain language, one need that started all of this 

was transfer surface – being able to get to the medical equipment for a diagnostic exam 

like everyone else. The surface height we had recommended historically was 17 to 19

inches above the floor, which has been around for years in existing Standards. If you 

have to pick an “absolute” low number, it only makes sense to pick 17 inches for the low 

height providing access to the greatest number of individuals with disabilities in order to 

access a standard of healthcare equal to all other people. 

We should not be picking a new low height! 17 inches has always been the low 

height most commonly referenced in accessibility Guidelines and Standards. We

already agreed to the high height in this application which is 25 inches. So this is just 

about the low number for accessibility - and that has already been established for 

decades as 17 inches! 

Most of the information we received from other experts in the field, studies done on seat 

height of mobility devices (never mind all of the people who use other types of mobility 

devices or are short in stature), and our own experiences as people with disabilities 

pointed to having the lowest height available, at a minimum for initial access and egress 

from the equipment. 

The manufacturers represented on the Committee consistently offered arguments

based (whether they admit it or not) on the current equipment they have on the market, 

or what can be offered without much research and development or re-engineering

(a.k.a. cost). Most manufacturers on the Committee had a 19 to 21 inch surface 

available currently, with at least one having a product at 18. Their argument has always 

been that providing the lowest transfer heights would be an extraordinary expense and 

burden on the business community (their consumer), not based on how it benefitted a 

patient with a disability. This effort was never supposed to be about the manufacturers 

or the doctors. It is the charge of this committee to answer questions and come up with 

recommendations for accessibility, based by some members on engineering and others 

by experience. NCIL’s 30-plus years of experience as advocates for people with 

disabilities dictates that we continue to strongly insist that the U.S. Access Board 

maintain the low accessible height at 17 inches above the floor in order for medical and 

diagnostic equipment to be accessed by the greatest number of people. 
Dr. Ed Steinfeld’s study and testimony presented to the Committee recommended a 

height of 17 inches to provide the greatest level of access, and he himself stated 18

inches would be a compromise. The study showed that increasing the low end to 

19 inch height excludes many users, specifically over 30% of female manual chair 

users and over 15% of male manual chair users. It wasn’t our charge to come up 

with a reasonable compromise. It was our charge to come up with what numbers 

provided the greatest level of accessibility. That number on the low end must be 17 

inches or we are excluding a large segment of people who happen to use mobility 

devices from accessing an equal standard of care. 

How the new standards are implemented – some over time, some right away, or not at 

all – that is to be determined by the authorities having jurisdiction for enforcement - like 

the Department of Justice, whose contributions to this committee process have been 

greatly appreciated. NCIL represents individuals with disabilities and IL organizations 

that are run by and for people with disabilities, as do many of the other advocacy 

organizations represented on the committee. We came to this committee because we 

were uniquely qualified to bring decades of experience making things accessible that 

were once not – based on the needs of consumers with disabilities. However with such

technical equipment and engineering, it is not for us to provide all the technical answers 

to the roadblocks presented by some manufacturers represented on the Committee. 

The Subcommittees spent way too much time trying to solve engineering problems, 

when the point was to understand accessibility needs and meet them. If we drove all of 

our advancements over time based on what currently exists, we would still be in the 

stone age. We must make recommendations based on what will work best tomorrow to 

provide an equally high standard of care to more people with disabilities. 

We should not recommend things based on what equipment currently exists. We must

recommend things based on what people with disabilities need for equal treatment. The 

manufacturers are still trying to tell us what is best for us. We have challenged the 

medical model and tried to promote person-centered treatment for decades. We have 

NCIL members across the country who have not had the same standard of care as 

everyone else just because they use a mobility device – a wheelchair that may very well 

be 17 inches above the floor to the seat surface. They are who this rulemaking is for. 

NCIL urges the Access Board to consider this and other minority reports calling 

for the 17 inch low transfer height, and to continue their rich history of providing 

accessibility that serves the greatest number of individuals with disabilities, and 

in this case provides much needed improvements in health care for Americans 

with disabilities including our Wounded Warriors.