**Minority Report**  The Brewer Company, LLC 01

- Oct

-2013 Final Report Medical Diagnostic Equipment Accessibility Standards Advisory Committee Section 5.1.3 Transfer Surface Low Height **R ecommendation**  **for 1 9** **” Low Height**
The final report titled Advancing Equal Access to Diagnostic Services: Recommendations on Standards for the Design of Medical Diagnostic Equipment for Adults with Disabilities (Report) created by the Medical Diagnostic Equipment Accessibility Standards Advisory Committee (Committee) dated October 2, 2013 includes S ection 6 which discusses the committee’s inability to reach consensus on the recommended lowest height for adjustable height transfer surfaces. As a potential resolution to this issue, Section 6.3 invites Committee members to submit their views regarding the low height specification in the form of a Minority R eport

. As discussed in Section 6 of the Report, the Committee reached consensus on a high height speci fication of 25”. They also reached consensus on the need for continuous increments for the low to high height adjustment. Low height specifications of 17”, 18”, and 19”were considered but no consensus could be reached. This Minority Report, submitted by Committee member Jack DeBraal on behalf of The Brewer Company, LLC, ( Brewer) provides rationale for a 19” low height specification. We request the Access Board to consider the following points in favor of the 19” low height : 1) The S ubcommittee on Tables and C hairs convened by the U.S. Access Board’s Medical Diagnostic Equipment Technical Advisory Committee discussed the issue of transfer surface heights . Low height options of 17, 18 and 19 inches were discussed. After considering the available data along with the full Committee discussions, the S ubcommittee concluded with a majority recommendation that examination tables and chairs shall have a l ow height of 19 inches

.2) The U.S. Access Board issued a Notice of Proposed Rule Making (NPRM) dated

February 9, 2012 for accessible medical equipment. The proposed rule recommended that the height of the transfer surface during patient transfer shall be 17 inches minimum and 19 inches maximum measured from the floor to the top of the transfer surface

. The Access Board based its proposal on provisions in the 2004 ADA and ABA Accessibility Guidelines for architectural features that involve transfers (e.g., toilet seats, shower seats, dressing benches). This is significant because : i) According to these guidelines, a transfer surface with a fixed height of 19 inches meets the definition of accessibility. ii) Therefore, adjustable height examination tables with a low height of 19 inches would also meet the defi nition of accessibility. Furthermore, toilet seats, shower seats, and dressing bench es remain at their fixed height for both transfer and normal use

. Adjustable height m edical examination tables available today can be lowered to 19 inches to facilitate transfer, and can then be raised above 25 inches (the minimum high height recommended by the Committee) to facilitate the exam or procedure by the medical clin ician. 3) The Committee attempted to determine the optimal accessible transfer surface height based on available data

. In particular, the Advisory Committee spent a great deal of time discussing the Anthropometry of Wheeled Mobility (AWM) Project

. This study measured the physical characteristics of people who use wheeled mobility devices and some of the characteristics of those devices. However, because the project only studied static positioning of users in their devices, it did not identify optimal transfer surface heights, and did not assess the ability of wheeled mobility device users to transfer ind ependently onto an examination table or chair. In addition, t he AWM Project measured the rear compressed seat height of the wheeled mobility device with the user seated in it. For transfer purposes, however, the most relevant height is the wheelchair front edge. The height of the front edge of the seat or cushion is important because the user will shift to the front of the seat to avoid having to lift over the side wheel to complete the transfer. Unfortunately, the AWM Project did not measure the front edge height

. Consequently, the AWM Project data cannot be used to conclusively determine the transfer surface height required to accommodate independent wheelchair transfer

.4) Brewer has been manufacturing adjustable height examination tables since

2002

. These tables were designed specifically for wheelchair accessib ility by meeting the 19 inch height referenced in the ADA/ABA Accessibility Guidelines

. Brewer is ISO 13485 certifi ed. ISO requires a robust method for re cording customer, end user, and clinician feedback . In the 1 1 years we have been selling adjustable height examination tables we do not have a single complaint on record regarding the accessibility of our 19” low height tables. There have been no requests for a lower height. In addition, market growth of adjustable height tables with 19 inch low heights (section 2.4.1 of the Report) provides further evidence that these tables are meeting the accessibility needs of patients requiring independent wheelchair transfer. 5) Brewer concurs with the cost versus benefit conclusion discuss ed in Section 8.4 of the Report

. The benefits and effectiveness of any new accessibility standards should be quantified

. As the cost associated with the implementation of new accessibility standards increases, the offsetting benefits should increase in equal proportion. It is certain that t he addition of transfer supports and leg supports will add to the product cost. H oweve r, m aintaining the current 19 inch low height will mitigate any additional costs that would be incurred with redesign of the lifting structure. T he costs required to redesign existing adjustable height tables that already meet a 19 inch low height is difficult to rationalize without any tangible offsetting benefits. As section 8.4 states, research on the costs and benefits of improving accessibility requires further attention.

In conclusion , T he Brewer Company, LLC as a manufacturer of adjustable hei ght tables, w ill make a significant investment to comply with the new requirements for transfer surface size, transfer supports, and leg supports . These changes have been well justified in the Report and are supported by Brewer. However, there is no quanti fiable data that justifies a revision to the currently acceptable low height range of 17 to 19 inches required by existing accessibility standards. An adjustable height table achieving a low height of 19 inches is considered accessible by these standards. There are no quantifiable benefits associated with a low height below 19 inches, although the re would be a significant investment to redesign the lift structure and anticipated add itional product cost

.