Preliminary Regulatory Assessment for Medical Diagnostic Eq uipment Accessibility Standards

Introduction Section 510 of the Rehabilitation Act, as amended by the Patient Protection and Affordable Care Act, requires the A ccess Bo a rd, i n consultation with the Food and Drug Administration, to issue accessibility standards that contain minimum technical criteria to ensure that medical diagnostic equipment is accessible to and useable by patients with disabilities. The statutory deadline for issuing the standards is March 23, 2012. The standards do not impose any mandatory requirements on health care providers or medical device manufacturers. However, other agencies, referred to as an enforcing authority in the standards, may issue regulations or adopt policies that require health care providers subject to their jurisdictio n to acquire accessible medical diagnostic equipment that conforms to the standards. The Access Board prepared this preliminary regulatory assessment to meet the requirements of Executive Order 13563 (Improving Regulation and Regulatory Review) and E xecutive Order 12866 ( Regulatory Planning and Review) for the Notice of Pr o posed Rulemaking (NPRM) requesting public comment on the proposed standards. Among other things, Executive Order 13563 directs agencies to propose or adopt a regulation only upon a reasoned determination that its benefits justify its costs; tailor the regulation to impose the least burden on society, consistent with obtaining the regulatory objectives; and, in choosing among alternative regulatory approaches, select those approaches that maximize net benefits. Executive Order 13563 recognizes that some benefits and costs are difficult to quantify and provides that, where appropriate and permitted by law, agencies may consider and discuss qualitatively values that are difficult or im possible to quantify, including equity, human dignity, fairness, and distributive impacts.

Need for and Benefits of the Proposed Standards The U.S. Census Bureau reports that 54.4 million Americans, about one in five U.S. residents, reported some level of disability in 2005. 1 The number of individuals with disabilities is almost equal to the combined total population of California and Florida. The U.S. Census Bureau provides this breakdown of the population of people aged 15 and older:

 27.4 million (11 .9 percent) had difficulty with ambulatory activities of the lower body;

 22.6 million (9.8 percent) had difficulty walking a quarter of a mile;

 21.8 million (9.4 percent) had difficulty climbing a flight of stairs;

 10.2 million (4.4 percent) used a cane, crutches, or walker to assist with mobility;

1 “Americans with Disabilities: 2005” (2008) available at: http://www.census.gov/prod/2008pubs/p70

- 117.pdf

. 3.3 million (1.4 percent) used a wheelchair or other wheeled mobility device;

 7.8 million (3 percent) had difficulty seeing words or letters in ordinary newspaper print, including 1.8 million who are co mpletely unable to see; and

 7.8 million (3 percent) had difficulty hearing conversations, including 1 million who are unable to hear conversations at all.
The prevalence of disability increases with age. The Administration on Aging reports that there we re 39.6 million persons age 65 or older in the United States in 2009, and that this population is expected to increase to 55 million in 2020. 2 Among this population, 37 percent reported some type of disability in 2005

. 3

A national survey collected infor mation on the types of medical equipment that is most difficult for individuals with disabilities to access and use. 4 The survey was completed by a diverse sample of individuals with a wide range of disabilities, including mobility disabilities and sensory disabilities. Survey respondents who had experience with specific medical equipment rated their degree of difficulty when attempting to access or use the equipment as follows:

 75 percent rated examination tables as moderately difficult to impossible to use;

 68 percent rated radiology equipment as moderately difficult to impossible to use;

 53 percent rated weight scales as moderately difficult to impossible to use; and

 50 percent rated examination chairs as moderately difficult to impossible to use. Survey respondents reported difficulties with getting on and off the equipment, positionin g their bodies on the equipment, physical comfort and safety, and communication issues. Focus group sessions of individuals with disabilities reported that participants find examination tables, imaging equipment, and other diagnostic equipment not only di fficult but

2 “A Profile of Older Americans: 2010” available at: http://www.aoa .gov/AoARoot/Aging_Statistics/Profile/index.aspx

.

3 See footnote 1.

4 The results of the survey are reported in Jill M. Winters, Molly Follette Story, Kris Barnekow, June Issacson Kailes, Brenda Premo, Erin Schier, Sarma Danturthi , and Jack M. Winters, “Results of a National Survey on Accessibility of Medical Instrumentation for Consumers,” in “Medical Instrumentation Accessibility and Usability Considerations,” edited by Jack M. Winters and Molly Follette Story (Boca Raton, CRC Pr ess, 2007), 13

- 27.unsafe to use, and that these negative health care experience s can result in their not scheduling

regular medical examinations and diagnostic procedures

. 5
A report on the “The Current State of Health Care for People with Disabilities” issued by the National Council on Disability found that individuals with disabilities experienced significant health disparities and barriers to health care, as compared to individuals without disabilities. 6 Among the key barriers cited in the report is the lac k of accessible examination equipment. A report on the “Importance of Accessible Examination Tables, Chairs and Weight Scales” issued by the Center for Disability Issues and the Health Professions discusses how the lack of accessible equipment reduces the likelihood that individuals with disabilities will receive timely and appropriate health care. 7 Health care providers may not perform some diagnostic procedures for patients with disabilities because they lack accessible equipment. This can result in sub optimal examinations, missed or delayed diagnoses, and worsening conditions that require more expensive and extensive treatments. The proposed standards address many of the barriers that have been identified as
a ffecting the accessibility and usability of diagnostic equipment by individuals with disabilities

. The standards will ensure that medical diagnostic equipment is accessible to and usable by individuals with disabilities, and will allow independent entry to, use of, and exit from the equipment by such individuals to the maximum extent possible. The standards will improve the quality of health care for individuals with disabilities and ensure that they receive examinations, diagnostic procedures, and other health care services equal to those recei ved by individuals without disabilities. The standards will facilitate independent transfers by individuals with disabilities onto and off of diagnostic equipment , and enable them to maintain their independence, confidence, and dignity

. Th e standards will lessen the need for health care personnel to assist individuals with disabilities when transferring on and off of diagnostic equipment

. Where assisted transfers are necessary, the proposed standards will also facilitate such transfers. T he proposed standards will reduce the risk of injury during transfers to both health care personnel and patients. 8 The proposed standards will result in more positive health care experiences for individuals with disabilities and health care providers.

Entities Potentially Affected by Proposed Standards The proposed standards do not impose any mandatory requirements on health care providers or medical device manufacturers. Thus, there are no compliance costs that can be attributed to the proposed stand ards. As discussed below, if an enforcing authority such as the

5 The results of the focus group sessions are reported in Molly Follette Story, Erin Schwier, and June Issacson Kailes, “Perspectives of Patients with Disabilities on the Accessibility of Medical Equipment: Examination Tables, Imagi ng Equipment, Medical Chairs, and Weight Scales,” Disability and Health Journal 2 (2009), 169

- 179.

6 The report is available at: http://www.ncd.gov/publications/2009/Sept302009

.

7 The repor t is available at: http://www.cdihp.org/products.html#tables

.

8 Lifting and transferring patients is a major risk factor for back injury among nurses and health aides. See Alan Hedge, “Back C are for Nurses” available at: http://www.spineuniverse.com/wellness/ergonomics/back

- care
- nurses

.Department of Justice (DOJ) adopts the standards as mandatory requirements for entities subject

to its jurisdiction, health care providers may experience some compliance costs. Medical devic e manufacturers may have an economic incentive to produce accessible products that conform to the standards for health care providers who need to acquire accessible medical diagnostic equipment.

Health Care Providers
The Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act are civil rights laws that prohibit discrimination on the basis of disability. Title II of the ADA (42 U.S.C. 12131 to 12165) applies to state and local governments, and T itle III of the ADA (42 U.S.C. 12189 to 12189) applies to private entities that are public accommodations such as health care providers. Section 504 of the Rehabilitation Act (29 U.S.C. 792) applies to recipients of federal financial assistance such as Me dicaid and federally conducted programs. Pursuant to the ADA and Section 504 of the Rehabilitation Act, health care providers must provide individuals with disabilities full and equal access to their health care services and facilities. DOJ has entered into settlement agreements with health care providers to enforce the ADA and Section 504 of the Rehabilitation Act

. In July 2010, DOJ and the Department of Health and Human Services issued a guidance document for health care providers regarding their resp onsibilities to make their services and facilities accessible to individuals with mobility disabilities under the ADA and Section 504 of the Rehabilitation Act. See Access to Medical Care for Individuals with Mobility Disabilities available at: http://www.ada.gov/medcare_ta.htm

. The guidance document includes information on accessible examination rooms and the clear floor space needed adjacent to medical equipment for individuals who use mobility devices to approach the equipment for transfer; accessible medical equipment (e.g., examination tables and chairs, mammography equipment, weight scales); patient lifts and other methods for transferring individuals from their mobility devices to medical equipment; a nd training health care personnel

. In July 2010, DOJ also issued an advance notice of proposed rulemaking (ANPRM ) announcing that , pursuant to the obligation that has always existed under the ADA for covered entities to provide accessible equipment and furniture, it was considering amending its regulations implementing Titles II and III of the ADA to include specific standards for t he design and use of accessible equipment and furniture that is not fixed or built into a facility in order to ensure that programs and services provided by state and local governments and by public accommodations are accessible to individuals with disabil ities

. See 75 FR 43452 (July 26, 2010). Among other things, the ANPRM stated that DOJ was considering amending its ADA regulations to specifically require health care providers to acquire accessible medical equipment and that it would consider adopting th e standards issued by the Access Board. DOJ also indicated its intention to include in its ADA regulations scoping requirements that specify the minimum number of types of accessible medical equipment required in different types of health care facilities. I f DOJ proposes to amend its ADA regulations as announced in the ANPRM, it will publish a notice of proposed rulemaking (NPRM) requesting public comment and will prepare a regulatory assessment in accordance with Executive Orders 13563 and 12866

. Medical Device ManufacturersI f DOJ amends its ADA regulations as announced in the ANPRM, medical device

manufacturers may have an economic incentive to produce accessible products that conform to the standards for health care providers who need to acquir e accessible medical diagnostic equipment. The size of the economic incentive will depend on the amount of accessible medical diagnostic equipment health care providers need to acquire and the manufacturers’ incremental costs to design or redesign and man ufacture accessible products that conform to the standards. Many medical device manufacturers currently incorporate accessible features in some of their products such as patient support surfaces that are height adjustable, transfer and positioning suppo rts, and scales designed for use by patients seated in a wheelchair. The incremental costs for manufacturers to conform these products to the standards are expected to be small because the features may already meet or closely meet the standards. The incr emental costs may be greater for manufacturers that do not currently incorporate accessible features in their products but plan to do so in future designs or redesigns of their products. The incremental costs to design or redesign and manufacture accessib le products that conform to the standards will be incurred voluntarily by manufacturers that choose to produce them for health care providers who need to acquire accessible medical diagnostic equipment. Some manufacturers may choose not to design or redes ign and manufacture accessible products that conform to the standards, or may produce accessible products with less market appeal than that of their competitors, thereby losing market share and incurring losses. These economic impacts are not regulatory c osts and are not generally social costs because for the most part, one manufacturer’s loss is another manufacturer’s gain.

The following questions in the NPRM preamble request comments on the incremental costs to design or redesign and manufacture ac cessible products t hat conform to the technical criteria in the proposed standards , as well as alternative and additional technical criteria that the Access Board is considering:

 Questions 9 and 10 on the technical criteria in Chapter M3;

 Questions 1 4 (a) and (b) on height adjustable patient support surfaces;

 Question 1 5 (b) on width of patient support surfaces on equipment used by patients in a supine, prone, or side

- lying position;

 Question 1 8 (a) on structural strength of repositionable transfer supports;

 Question 1 9 (c) on location and size of transfer supports;

 Question 2 3 ( a ) on stirrups;

 Question 2 4 (b) on positioning supports;

 Question 2 9 ( a ) on alternative dimension for minimum d epth of wheelchair spaces; Question 30 on edge protection for wheelchair spaces on raised platforms ;

 Question s 3 3 on dimensions for wheelchair spaces on raised platforms;

 Question 3 4 (a) on alternative dimensions for toe clearance and knee clearance a t wheelchair spaces;

 Question 3 5 (b) on handrails on diagnostic equipment ramps;

 Question 3 7 (c) on a folding or removable seat on weight scale platforms or other types of diagnostic equipment used by patients in a standing position;

 Question 4 1 (b) on audible, visible, and tactile communications; and

 Question 4 2 (a) on operating force for operable parts. The Access Board will consider the information provided in the comments when preparing the final standards, and will provide an analysis of the incremental costs with the final standards.

Product Data and Unit Costs

T he Access Board and its contractor, Eastern Research Group, collected product data and unit costs for a broad sample of examination tables and weight scales, including products w ith accessible features. The Access Board and Eastern Research Group did not evaluate the products for conformance with the proposed standards and do not endorse any of the products included in the sample. The Access Board and Eastern Research Group used the Internet to collect the product data and unit costs. Medical equipment suppliers typically list the manufacturer suggested retail price (MSRP) for the products on their web sites and sell the products at discounted prices. The discounted prices for the same product can vary widely among medical equipment suppliers. Health care providers typically purchase the products for less than the MSRP (i.e., actual price paid is less than MRSP). The unit costs in the tables below are the MSRP, and are shown a s a range of lower cost and higher cost products rounded to the nearest $50. The data shows that there are a wide variety of examination tables and weight scales available to meet almost every budget.

Product data and unit costs for examination chairs an d imaging equipment will be provided when the final standards are issued.

Examination Tables

Product data and unit costs were collected for examination tables produced by five manufacturers. The manufacturer’s web sites typically grouped the tables by the followingtypes: treatment tables, manual tables, and power tables

. 9 The number of each type of table

made by the manufacturers, the number of tables included in the sample, and range of lower cost and higher cost products are summarized below.

Table Type Products Products in Sample Lower Cost Products MSRP Higher Cost Products MSRP Treatment 74 20 $400

- $850 $850

- $1,450 Manual 15 9 $1,250 $2,250 Power 30 25 $1,650

- $2,900 $3,650

- $16,800

Treatment tables typically have a flat top. Some products have adjustable backrests, but the backrests typically cannot support patients in a sitting position. Treatment tables typically have a fixed height of 31 inches measured from the floor to the top of the table. The lower cost products have an open base with an H

- brace or shelf. The higher cost products have cabinets, drawers, or shelves. Adjustable height treatment tables are available, but are not included in the sample. The MSRP for adjustable height treatment tables ranged from $1,500 to $ 2,400.

Manual tables typically have a fully articulated , pneumatic backrest . The backrests typically can support patients in a seated position and recline to a lying position. Manual tables typically have a fixed height of 3 2 inches measured from the floor to the top of the table

. Manual tables typically have cabinets, drawers, or shelves.

Power tables have an electric motor that can adjust the table height to as low as 18 inches and as high as 40 inches above the floor on some pr oducts . The higher cost products have a fully articulated , pneumatic or powered, backrest that can support patients in a seated position and recline to a lying position. Some power tables have armrests, grab rails, side rails , and cabinets or drawers

. W eight Scales

Product data and unit costs were collected for weight scales produced by eight manufacturers. The scales are grouped by the following types: stand

- on scales and wheelchair scales. Within each group, there are mechanical and digital scales. Unit costs are presented for stand

- on scales with and without handrails. Unit cost s are presented for wheelchair scales with raised platforms and with flush platforms in the floor. The number of stand

- on scales and wheelchair scale s made by the manufacturers, the number of scales included in the sample, and range of lower cost and high er cost products are summarized below.

Stand

- On Scale s Products Products in Sample Lower Cost Products MSRP Higher Cost Products MSRP Mechanical
w ithout Handrails 22 3 $250 $550 Mechanical
w ith Handrails 1 1 $700 $700 Digital
w ithout Handrails 50 15 $300

- $600 $700

- $1,200

9 Bariatric tables were not included.Stand

- On Scale s Products Products in Sample Lower Cost Products MSRP Higher Cost Products MSRP Digital
w ith Handrails 21 9 $600

- $1,050 $1,750

- $2,600
Stand

- on mechanical scales typically have a weight capacity ranging from 400 to 500 pounds. Stand

- on digital scales without handrails typically have a weight capacity ranging from 400 to 750 pounds, and the higher cost products typically have larger platf orms. Stand

- on digital scales with handrails typically have a weight capacity ranging from 500 to 1,000 pounds, and the higher cost products typically are bariatric scales

.
Wheelchair Scale s Products 10 Products in Sample Lower Cost Products MSRP Higher Cost Products MSRP Mechanical with Ramped Platform 2 2 $1, 200 $2, 900 Digital with Ramped Platform 32 15 $800

- $1,700 $2,100

- $4,950 Digital with Flush Platform in Floor 8 5 $3,300 $6,500 Wheelchair mechanical scales with a ramped platform typically have a weight capacity ranging from 350 to 500 pounds. Wheelchair digital scales with a ramped platform typically have a weight capacity ranging from 800 to 1,000 pounds. Wheelchair digital sc ales with a flush platform in the floor typically have a weight capacity of 1,000 pounds. Some wheelchair digital scales have standard or optional handrails for use as a stand

- on bariatric scale.

Conclusion

The Access Board has made a preliminary determination based on the preliminary regulatory assessment that the benefits of the proposed standards will justify the costs; that the proposed standards will impose the least burden on society, consistent with obtaining the regulator y objectives; and that the regulatory approach select ed will maximize net benefits. January 30 , 2012

10 One of the manufacturers makes digital wheelchair scales with a ramped platform (6 models) and with a flush platform in floor (6 models). The MSRP for the wheelchair scales were not listed on the manufacturer’s website or medical equipment suppliers’ we bsites, and are not included in columns on products or products in sample.A ttachment A: Product Data and Unit Costs

T he Access Board and its contractor, Eastern Research Group, collected product data and unit costs for a broad sample of examination tables and weight scales, including products with accessible features. The Access Board and Eastern Research Group did not evaluate the products for conformance with the proposed standards and do not endorse any of the pr oducts included in the sample. The Access Board and Eastern Research Group used the Internet to collect the product data and unit costs. Medical equipment suppliers typically list the manufacturer suggested retail price (MSRP) for the products on their w eb sites and sell the products at discounted prices. The discounted prices for the same product can vary widely among medical equipment suppliers. Health care providers purchase the products for less than the MSRP (i.e., actual price is less than MRSP). The unit costs in the tables below are the MSRP, and are shown as a range of lower cost and higher cost products rounded to the nearest $50.

Treatment Tables Lower Cost Products $400

- $850 MSRP Higher Cost Products $ 850

- $ 1 , 4 50 MSRP Clinton 3010 Clinton 1010 Clinton 9001 Hausmann 4002

- 030 Clinton 3020 Clinton 1020 Ritter 95 UMF 5588 Brewer 2010 Brewer 2030 $380

$417 $432 $457 $482 $497 $561 $624 $730 $850 Clinton 8870

Clinton 3013 Clinton 9070 Clinton 1013 Clinton 9013 Hausmann 4043

- 030 UMF 5570 Clinton 9133 UMF 5560 Brewer 2240 $863

$892 $910 $963 $1 , 032 $1,039 $1,208 $1,345 $1,390 $1,438

T reatment tables typically have a flat top. Some products have adjustable backrests, but the backrests typically cannot support patients in a sitting position. T reatment tables typically have a fixed height of 31 inches measured from the floor to the top of the table

. Adjustable height products are available, b ut are not included in the sample. 11 The lower cost products have an open base with an H

- brace or shelf. The higher cost products have cabinets, drawers, or shelves.

Manual Tables Lower Cost Products $1,250 MSRP

- Higher Cost Products $2,250 MSRP UMF 5250 UMF 5290 Brewer 4000 $1,262 $1,350 $1,728

11 Hausman 4723 ( $2,425 MSRP http://www.quickmedical.com/hausmann

- power
- plinth

- treatment

- table

- 4723.html ) and Oakworks ProLuxe Seville and Celestra PerformaLift

- Rectangular Top ($1,479 and $2,370 MSRP http://www.oakworks.com/electric

- lift

- tables.asp ) are examples of adjustable hei ght treatment tables. Other manufacturers produce adjustable height treatment tables within the same cost range.Hausmann 4420

Ritter 204 Midmark 604 Hausmann 4423 Hausmann 4400 Brewer 5000 $1,754 $1,845 $1,926 $1,946 $2,258 $2,260

Manual tables typically have a fully articulated , pneumatic backrest . The backrests typically can support patients in a seated position and recline to a lying position. Manual tables typically have a fixed height of 3 2 inches measured from the floor to the top of the table

. Manual tables typically have cabinets, drawers, or shelves.

Power Tables Lower Cost Products $1,650

- $2,900 MSRP Higher Cost Products $3, 65 0

- $16,800 MSRP Clinton 80100 Clinton 80200 Clinton 80220 Clinton 80330 Clinton 80360 Clinton 81100 Clinton 81200 Clinton 81220 Clinton 81330 Clinton 81360 $1,653

$1,793 $1,793 $1,918 $2,214 $2,337 $2,447 $2,447 $2,621 $2,917 Hausmann 4430

UMF 4070 Ritter 222 UMF 4040 Hausmann 4440 Hausmann 4460 Ritter 223 Midmark 623 Midmark 625 Brewer 6500 UMF 4010 Ritter 230 Midmark 630 Brewer 7000 Brewer 7500 $3,672

$4,373 $5,499 $5,694 $5,776 $6,034 $7,036 $8,081 $8,427 $8,536 $9,349 $11,551 $12,884 $14,198 $16,798

Power tables have an electric motor that can adjust the table height to as low as 18 inches and as high as 40 inches , measured from the floor to the top of the table . The higher cost products have a fully articulated , pneumatic or powered, backrest that can support patients in a seated position and recline to a lying position. Some power tables have armrests, grab rails, side rails , and cabinets or drawers

. Stand

- On Mechanical Scales

Without Handrails $250

- $550 MSRP With Handrails $ 700 MSRP HealthoMeter 4 00KL SECA 700 Detecto 337 $228

$295 $538 Detecto 349 $675

Stand

- on mechanical scales typically have a weight capacity ranging from 400 to 500 pounds.Stand

- On Digital Scales Without Handrails Lower Cost Products $300

- $600 MSRP With Handrails Lower Cost Products $600

- $1,050 MSRP Detecto DR400C Detecto PD200 HealthoMeter 500KL Detecto PD300 Charder MS3900 Detecto DR400

- 750 Charder MS4900 AmCells DRS500 $323

$372 $415 $426 $459 $534 $547 $600 Charder MS2500

Befour PS8070 Detecto 6449 $604

$957 $1,026

Without Handrails Higher Cost Products $700

- $1,200 MSRP With Handrails Higher Cost Products $1,750

- $2,600 MSRP Befour FS0900 AmCells WWS500 AmCells DRS 750 Befour FS0961 P ro
- BMI AmCells WWS750 Detecto 6437 SECA 763 $699

$700 $700 $819
$900 $927 $1,190 HealthoMeter 1100KL SR Scales SR555 HealthoMeter 4011 HealthoMeter 4021 SECA 644 Detecto 6854DHR $1,725

$1,822 $1,838 $2,075 $2,139 $2,584

Stand

- on digital scales without handrails typically have a weight capacity ranging from 400 to 750 pounds, and the higher cost products typically have larger platforms. Stand

- on digital scales with handrails typically have a weight capacity ranging from 5 00 to 1,000 pounds, and the higher cost products typically are bariatric models.

Wheelchair Mechanical Scales with Ramped Platform Lower Cost Products $1,200 MSRP

- Higher Cost Products $2,900 MSRP Detecto 485 Detecto 495 $1,191 $2,891 Wheelchair mechanical scales with a ramped platform typically have a weight capacity ranging from 350 to 500 pounds.

Wheelchair Digital Scales with Ramped Platform Lower Cost Products $800

- $1,700 MSRP Higher Cost Products $2,100

- $4,950 MSRP Charder MS3800 LW Measurements LWC HealthoMeter 2400KL AmCells WHS $799

$900 $1,551 $1,701 SECA 674

SR Scales SR755L SR Scales SR725L HealthoMeter 2700KL Detecto 6500 HealthoMeter 2600KL $2,089

$2,358 $2,422 $2,449 $2,881 $2,888Detecto FHD133

- 11 SECA 664 SECA 656 SECA 676 SECA 684 $3,033

$3,350 $3,750 $3,950 $4,950 Wheelchair digital scales with a ramped platform typically have a weight capacity ranging from 800 to 1,000 pounds. Some products have standard or optional handrails for use as a stand

- on bariatric scale. Wheelchair Digital Scales with Flush Platform in Floor

Lower Cost Products $3,300 MSRP

- Higher Cost Products $6,500 MSRP SR Scales SR463 SR Scales SR463

- 3 Detecto FH133

- 11C Detecto FH143

- 11C Detecto FH164

- 11C $3,306 $4,140 $5,242 $5,498 $6,522 Wheelchair digital scales with a flush platform in the floor typically have a weight capacity of 1,000 pounds. Some products have standard or optional handrails for use as a stand

- on bariatric scale.Attachment B: Web Site Sources (Last Visited November 21, 2011)

The Access Board and Eastern Research Group did not evaluate these products for conformance with the proposed standards and do not endorse any of the products.

Brewer Company Treatment Tables (9 Products ) http://www.brewercompany.com/Products/Medical/Exam

- Tables/Element

- Treatment

- Table.htm
2010

– MSRP $730 http://www.quickmedical.com/brewer_company/exam_tables/2010

- element

- treatment

- table

- flat

- top.html
2030

– MSRP $850 http://www.quickmedical.com/brewer_company/exam_tables/2030

- element

- treatment

- table

- flat

- top

- adj.html
2240

– MSRP $1,438 http://www.quickmedical.com/brewer_company/exam_tables/2240

- element

- treatment

- frame

- shelf

- drawers

- pillow

- top

- adj.html Manual Tables (4 Produc ts ) http://www.brewercompany.com/Products/Medical/Exam

- Tables/Basic

- Exam

- TableUpdated.htm http://www.brewercompany.com/Products/Medical/Exam

- Tables/Access

- Exam

- TableUpdated.htm
4000

– MSRP $1,728 http://www.quickmedical.com/brewer_company/exam_tables/4000_4001_pelvic_tilt_drawer_warmer.html
5000

– MSRP $2,260 http://www.quickmedical.com/brewer_company/access/5000_5001.html Power Tables (4 Products ) http://www.brewercompany.com/Products/Medical/Power

- Tables.htm
6500

– MSRP $8,536 http://www.quickmedical.com/brewer_company/access/highlow_specs.html
7000

– MSRP $14,198 http://www.quickmedical.com/brewer_company/assist/7000.html
7500

– MSRP $16,798 http://www.quickmedical.com/brewer_company/assist/7500

- power
- procedure

- table.html
Clinton Industries

Treatment Tables

- ETA Alpha Series (4 Products ) http://www.clinton

- ind.com/medical

- tables/eta

- alpha/index.htm
3010

– MSRP $380http://www.quickmedical.com/clinton/medical

- tables/eta

- alpha

- straight

- line

- steel

- treatment

- table

- 3010.html

3020

– MSRP $482 http://www.quickmedical.com/clinton/medical

- tables/eta

- alpha

- straight

- line

- steel

- treatment

- table

- 3020.html
3013

– MSRP $892 http://www.quickmedical.com/clinton/medical

- tables/eta

- alpha

- straight

- line

- steel

- treatment

- table

- 3013.html
Treatment Tables

- ETA Class ic Series (4 Products ) http://www.clinton

- ind.com/medical

- tables/eta

- classic/index.htm
1010

– MSRP $417 http://www.quickmedical.com/clinton/medical_tables_cabinets/classic_line.html
1020

– MSRP $497 http://www.quickmedical.com/clinton/medical

- tables/eta

- classic

- straight

- line

- treatment

- table

- 1020.html
1013

– MSRP $963 http://www.quickmedical.com/clinton/medical

- tables/eta

- classic

- straight

- line

- treatment

- table

- 1013.html
Treatment Tables

- ETA Style Line Se ries (4 Products ) http://www.clinton

- ind.com/medical

- tables/eta

- style

- line/index.htm
9001

– MSRP $432 http://www.quickmedical.com/clinton/medical

- tables/eta

- style

- line

- straight

- line

- treatment

- table

- 9001.html
9013

– MSRP $1032 http://www.quickmedical.com/clinton/medical

- tables/eta

- style

- line

- straight

- line

- treatment

- table

- 9013.html
Treatment Tables

- Style Line Full Cabinet (4 Products ) http://www.clinton

- ind.com/medical

- tables/eta

- style

- line/index.htm
9070

– MSRP $910 http://www.quickmedical.com/clinton/medical_tables_cabinets/style_line.html
Treatment Tables

- Style Line Specialty (7 Products ) http://www.clinton

- ind.com/medical

- tables/style

- line

- specialty/index.htm
9133

– MSRP $1,345 http://www.quickmedical.com/clinton/medical

- tables/style

- line

- specialty

- laminate

- treatment

- table

- stool

- 9133.html
Treatment Tables (1 Product ) http://www.clinton

- ind.com/medical

- tables/family

- practice/index.htm
8870

– MSRP $863 http://www.quickmedical.com/clinton

- medical

- exam
- table

- cabinet

- style.html
Power Tables

- Open Base (6 Products ) http://www.clinton

- ind.com/power

- tables/open

- base

- power
- tables/index.htm80100

– MSRP $1,653

http://www.quickmedical.com/clinton

- open
- base

- power
- table.html
80200

– MSRP $1,793 http://www.quickmed ical.com/clinton

- open
- base

- power
- table.html
80220

– MSRP $1,793 http://www.quickmedical.com/clinton

- open
- base

- power
- table

- with

- drop

- section.html
80330

– MSRP $1,918 http://www.quickmedical.com/clinton

- open
- base

- power
- table

- with

- drop

- section.html
80360

– MSRP $2,214 http://www.quickmedical.com/clinton

- open
- base

- power
- table

- with

- drop

- section

- and

- stirrups.html
Power Tables

- Shrouded Base (6 Products ) http://www.clinton

- ind.com/power

- tables/shrouded

- power
- tables/index.htm
81100

– MSRP $2,337 http://www.quickmedical.com/clinton

- shrouded

- power
- table.html
81200

– MSRP $2,447 http://www.quickmedical.com/clinton

- shrouded

- power
- table.html
81220

– MSRP $2,447 http://www.quickmedical.com/clinton

- shrouded

- power
- table

- with

- drop

- section.html
81330

– MSRP $2,621 http://www.quickmedical.com/clinton

- shrouded

- power
- table

- with

- drop

- section.html
81360

– MSRP $2,917 http://www.quickmedical.com/clinton

- shrouded

- power
- table

- with

- drop

- section

- and

- stirrups.html
Hausmann Industries Treatment Tables (35 Products ) http://www.hausmann.com/product_pages/treatment_tables.html
4002

- 030

– MSRP $457 http://www.quickmedical.com/hausmann

- h

- brace

- treatment

- table.html
4043

- 030

– MSRP $1,039 http://www.quickmedical.com/hausmann

- cabinet

- exam
- table

- shelf

- divider.html Manual Tables (5 Products ) http://www.hausmann.com/product_pages/examination_tables.html4420

– MSRP $1,754

http://www.quickmedical.com/hausmann

- cabinet

- exam
- table.ht ml

4423

– MSRP $1,946 http:/ /www.quickmedical.com/hausmann

- pneumatic

- medical

- exam
- table

- 4423

- 4424.html
4400

– MSRP $2,258 http://www.quickmedical.com/hausmann

- pneumatic

- medical

- exam
- table.html Power Tables (3 Products ) http://www.hausmann.com/product_pages/examination_tables.html
4430

– MSRP $3,672 http://www.quickmedical.com/hausmann

- econo
- line

- exam
- table.html
4440

– MSRP $5,776 http://www. quickmedical.com/hausmann

- powermatic

- power
- exam
- table.html
4460

– MSRP $6,034 http://www.quickmedical.com/hausmann

- wheelchair

- accessible

- exam
- table.html
Midmark Corporation Treatment Tables (2 Products ) http://www.midmark.com/en

- us/MedicalProducts/ManualExaminationTables/Pages/default.aspx#
Ritter 95

– MSRP $561 http://www.anthonyproducts.com/store/p

- 287

- ritter

- 95

- treatment

- table.aspx Manual Tables (2 Products ) http://www.midmark.com/en

- us/MedicalProducts/ManualExaminationTables/Pages/default.aspx#
Ritter 204

– MSRP $1,845 http://www.medicalresources.com/shopping/proddisplay.asp?catalogid=8351
Midmark 604

– MSRP $1,926 http://www.medicalresources.com/shopping/proddisplay.asp?catalogid=8356 Power Exam Tables (4 Products ) http://www.midmark.com/en

- us/MedicalProducts/PowerExaminationTables/Pages/default.aspx#
Ritter 222

– MSRP $5,499 http://www.medicalresources.com/shopping/proddisplay.asp?catalogid=3920
Ritter 223

– MSRP $7,036 http://www.medicalresources.com/shopping/proddisplay.asp?catalogid=5769
Midmark 623

– MSRP $8,081 http://www.medicalresources.com/shopping/proddisplay.asp?catalogid=5759Midmark 625

– MSRP $8,427

http://www.medicalresources.com/shopping/proddisplay.asp?catalogid=14745 Power Procedures Tables (2 Products ) http://www.midmark.com/en

- us/MedicalProducts/PowerProceduresTables/Pages/default.aspx#
Ritter 230

– MSRP $11,551 http://www.medicalresources.com/shopping/proddisplay.asp?catalogid=8448
Midmark 630

– MSRP $12,884 http://www.medicalresources.com/shopping/proddisplay.asp?catalogid=8451
UMF Medical Treatment Tables (4 Products ) http://www.umf

- exam.com/index.php?page=treatment

- orthopedic

- tables
5588

– MSRP $624 http://www.medicaldevicedepot.com/UMF

- H

- Brace

- Treatment

- Table

- 350

- lb

- capacity

- p/5588.htm
5570

– MSRP $1,208 http://www.medicaldevicedepot.com/UMF

- Treatmen t

- Table

- Standard

- Premium

- Top

- p/5570.htm
5560

– MSRP $1,390 http://www.medicaldevicedepot.com/UMF

- 5560

- Treatment

- Table

- Standard

- Premium

- Top

- p/umf

- 5560.htm Manual Tables (4 Products ) http://www.umf

- exam.com/index.php?page=signature

- series

- exam
- tables
5250

– MSRP $1,262 http://www.medicaldevicedepot.com/UMF

- 5250

- Signature

- Series

- Exam

- Table

- p/5250.htm
5290

– MSRP $1,350 http://www.examtablesforsale.com/umf

- 5290.html Power Exam & Procedures Tables (7 Products ) http://www.umf

- exam.com/index.php?page=power

- procedure

- tables
4070

– MSRP $4,373 http://www.medicaldevicedepot.com/UMF

- 4070

- Power

- Hi

- Lo

- Manual

- Back

- Exam

- Table

- p/4070.htm
4040

– MSRP $5,694 http://www.medicaldevicedepot.com/UMF

- 4040

- Power

- Hi

- Lo

- Power

- Back

- Exam

- Table

- p/4040.htm
4010

– MSRP $9,349 http://www.medicaldevicedepot.com/UMF

- 4 010

- Power

- Procedure

- Table

- with

- Hand

- Controls

- p/4010.htmAmCells Corp

http://www.amcells.com/sp/Products1.html
Stand

- On Digital Scales (4 Products , TRS Discontinued)

DRS500

– MSRP $600 http://www.quickmedical.com/amcells/wws.html
WWS500

– MSRP $700 http://www.quickmedical.com/amcells/wws

- 500

- l b

- capacity

- doctor

- scale.html

DRS750

– MSRP $700 http://www.quickmedical.com/amcells/drs

- 750

- lb

- capacity

- doctor

- scale.html
WWS750

– MSRP $900 http://www.quickmedical.com/amcells/wws

- 750

- lb

- capacity

- doctor

- scale.html
Befour 12 http://www.befour.com/products/list.asp?type=club http://www.befour.com/products/list.asp?type=port http://www.befour.com/prod ucts/list.asp?type=long
Stand

- On Digital Scales ( 13 Products )

FS0900

– MSRP $699 http://www.quickmedical.com/befour/0900.html
FS0961 Pro

- BMI

– MSRP $819 http://www.quickmedical.com/befour/0961bmi.html
Stand

- On Digital Scales with Handrails ( 6 Products )

PS8070

– MSRP $957 http://www.quickmedical.com/befour

- high

- capacity

- handrail

- scale

- portable

- ps
- 8070.html

Charder Electronic Co
. http://www.taiwantrade.com.tw/chardermedical/products

- list/en_US/39950/Professional_Care http://www.taiwantrade.com.tw/chardermedical/products

- list/en_US/39952/Senior_%26_Abled
Stand

- On Digital Scales ( 2 Products )

MS3900

– MSRP $459 http://www.quickmedical.com/summit/s3900

- digital

- column

- scale

- height

- rod.html

12 Befour makes digital wheelchair scales with a ramped platform (6 models) and with a flush platform in floor (6 models). The MSRP for the w heelchair scales were not listed on the manufacturer’s website or medical equipment suppliers’ websites, and they are not included in the sample.MS4900

– MSRP $547

http://www.quickmedical.com/charder

- digital

- column

- scale

- height

- rod

- printer

- ms4900.html
Stand

- On Digital Scales with Handrails ( 1 Product )

MS2500

– MSRP $604 http://www.quickmedical.com/charder

- digital

- handrail

- scale

- 2500.html
Detecto http://www.detecto.com/physicians.htm http://www.detecto.com/bariatric.htm
Stand

- On Mechanical Scales ( 14 Products )

337

– MSRP $538 http://www.quickmedical.com/detecto/physician/337.html
Stand

- On Mechanical Scales with Handrails ( 1 Products )

349

– MSRP $675 http://www.quickmedical.com/detecto/physician/349.html
Stand

- On Digital Scales ( 18 Products )

DR400C

– MSRP $323 http://www.affordablescales.com/scales_category.asp?products=8&Physician_Scales
PD200

– MSRP $372 http://www.quickmedical.com/detecto/fitness/pd200

- professional

- space
- saving

- scale.html
PD300

– MSRP $426 http://www.quickmedical.com/detecto/physician/pd300dhr

- professional

- doctor

- scale.html
DR400

- 750

– MSRP $534 http://www.quickmedical.com/detecto/specialty/dr400_750.html?openTab=Accessories
6437

– MSRP $927 http://www.quickmedical.com/detecto/physician/6437.html
Stand

- On Digital Scales with Handrails ( 5 Products )

6449

– MSRP $1,026 http://www.quickmedical.com/detecto

- high

- capacity

- digital

- physician

- scale

- height

- rod

- 6449.html
6854DHR

– MSRP $2,584 http://www.quickmedical.com/detecto

- high

- capacity

- digital

- handrail

- scale

- heightrod

- 6854dhr.html
HealthoMeter http://www.homscales.com/products/Physician%20Scales/1.aspxhttp://www.homscales.com/products/Physician%20Sca les/2.aspx

http://www.homscales.com/products/Acute%20Care%20Scales/Stand

- On

- Scales.aspx h ttp://www.homscales.com/products/Bariatric%20Scales/1.aspx
Stand

- On Mechanical Scales ( 5 Products )

400KL

– MSRP $228 http://www.quickmedical.com/health_o_meter/beam

- scales/400kl

- physician

- beam

- scale.html
Stand

- On Digital Scales ( 8 Products )

500KL

– MSRP $415 http://www.quickmedical.com/h ealth_o_meter/fitness

- scale

- 500kl.html
Stand

- On Digital Scales with Handrails ( 4 Products )

1100KL

– MSRP $1,725 http://www.quickmedical.com/healthometer

- high

- capacity

- digital

- handrail

- scale

- 1100kl.html
4011

– MSRP $1,838 http://www.scalesonline.com/2520/category/Healthomete r
- 4011

- Handrail

- Scale.aspx
4021

– MSRP $2,075 http://www.scalesonline.com/2522/Health%20O%20Meter/Healthometer

- 4021

- Handrail

- Scale.aspx
SECA http://www.seca.com/english/us/home/products/details/seca/category/column_scales_264/ http://www.seca.com/english/us/home/products/details/seca/category/multifunction_and_wheelchair_scales_267/
Stand

- On Mechanical Scales ( 3 Products )

700

– MSRP $295 http://www.quickmedical.com/seca/scales/700

- mechanical_column_scale_measuring_rod.html
Stand

- On Digital Scales ( 5 Products )

763

– MSRP $1,190 http://www.quickmedical.com/seca/scales/763

- digital

- medical

- scale.html
Stand

- On Digital Scales with Handrails ( 2 Products )

644

– MSRP $2,139 http://www.quickmedical.com/seca/specialty/644.html
SR Scales http://www.srinstruments.com/Scales/Item

- Display.asp?URI=1124
Stand

- On Digital Scales with Handrails ( 3 Products )SR555

– MSRP $1,822

http://www.med icalsolutionsinc.com/ProductsDetails/5/233/218946

- Laboratory%20Equipment.aspx AmCells Corp http://www.amcells.com/sp/Products1.html Wheelchair Digital Scales with Ramped Platform (1 Product )

WHS

– MSRP $1,701 http://www.quickmedical.com/amcells

- wheelchair

- scale

- whs.html

Charder Electronic Co
. http://www.taiwantrade.com.tw/chardermedical/products

- list/en_US/39952/Senior_%26_Abled Wheelchair Digital Scales with Ramped Platform (1 Product )

MS3800

– MSRP $799 http://www.quickmedical.com/summit/s3800

- wheelchair

- scale.html
Detecto http://www.detecto.com/wheelchairs.htm Wheelchair Mechanical Scales with Ramped Platform (2 Products )

485

– MSRP $1,191 http://www.quickmedical.com/detecto/specialty/485.html
495

– MSRP $2,891 http://www.quickmedical.com/detecto/specialty/495.html Wheelchair Digital Scales with Ramped Platform (6 Products )

6500

– MSRP $2,881 http://www.quickmedical.com/detecto

- portable

- high

- capacity

- bariatric

- wheelchair

- scale

- 6500.html
FHD133

- 11

– MSRP $3,033 http://www.quickmedical.com/detecto/specialty/FHD133II.html Wheelchair Digital Scales with Flush Platform in Floor (4 Products )

FH133

- 11C

– MSRP $5,242 http://www.quickmedical.com/detecto

- in

- floor

- medical

- scale.html
FH143

- 11C

– MSRP $5,498 http://www. quickmedical.com/detecto

- in

- floor

- medical

- scale.html
FH164

- 11C

– MSRP $6,522 http://www.quickmedical.com/detecto

- in

- floor

- medical

- scale.htmlHealthoMeter

http://www.homscales.com/products/Acute%20Care%20Scales/Wheelchair

- Scales.aspx http://www. homscales.com/products/Bariatric%20Scales/1.aspx Wheelchair Digital Scales with Ramped Platform (12 Products )

2400KL

– MSRP $1,551 http://www.quickmedical.com/healthometer

- portable

- digital

- remote

- display

- wheelchair

- ramp
- rail

- scale

- 2400kl.html
2700KL

– MSRP $2,449 http://www.quickmedical.com/healthometer

- portable

- digital

- remote

- display

- wheelchair

- ramp
- scale

- 2700kl.html
2600KL

– MSRP $2,888 http://www.quickmedical.com/health_o_meter/2600kl.html
LW Measurements http://lwmeasurements.com/lwclargewheelchairscale/ Wheelchair Digital Scales with Ramped Platform (1 Product )

LWC

– MSRP $900 http://www.affordablescales.com/scales_specs.asp?specs=4830&LW_Measurements_LWC
SECA http://www.seca.com/english/us/home/products/details/seca/category/multifunction_and_wheelchair_scales_267/ Wheelchair Digital Scales with Ramped Platform (5 Products )

674

– MSRP $2,089 http://www.quickmedical.com/seca/specialty/674.html
664

– MSRP $3,350 http://www.quickmedical.com/seca/specialty/664.html
656

– MSRP $3,750 http://www.quickmedical.com/seca/specialty/medical

- stretcher

- scale

- 656.html
676

– MSRP $3,950 http://www.quickmedical.com/seca/specialty/676.html
684

– MSRP $4,950 http://www.quickmedical.com/seca/specialty/684.html
SR Scales http://www.srinstruments.com/Scales/Item

- Display.asp?URI=1129 http://www.srinstruments.com/Scales/Item

- Dis play.asp?URI=1228Wheelchair Digital Scales with Ramped Platform (6 Products )

SR755L

– MSRP $2,358 http://www.quickmedical.com/srscales/sr755.html
SR725L

– MSRP $2,422 http://www.quickmedical.com/srscales/sr725.html Wheelchair Digital Scales with Flush Platform in Floor (4 Products )

SR463

– MSRP $3,306 http://www.quickmedical.com/srscales/sr465.html
SR463

- 3

– MSRP $4,140 http://www.quickmedical.com/srscales/platform

- scales/sr4633

- infloor

- scale

- system.html