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

Recommendation for 19” 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 Section 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 

Report. 

As discussed in Section 6 of the Report, the Committee reached consensus on a 

high height specification 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 Subcommittee on Tables and Chairs 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 Subcommittee concluded with a majority 

recommendation that examination tables and chairs shall have a low 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 definition of accessibility.

Furthermore, toilet seats, shower seats, and dressing benches remain at their 

fixed height for both transfer and normal use. Adjustable height medical 

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 clinician. 

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 independently 

onto an examination table or chair. In addition, the 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 accessibility by 

meeting the 19 inch height referenced in the ADA/ABA Accessibility 

Guidelines. Brewer is ISO 13485 certified. ISO requires a robust method for 

recording customer, end user, and clinician feedback. In the 11 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 discussed 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 the addition of 

transfer supports and leg supports will add to the product cost. However, 

maintaining the current 19 inch low height will mitigate any additional costs 

that would be incurred with redesign of the lifting structure. The 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, The Brewer Company, LLC as a manufacturer of adjustable height 

tables, will 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 quantifiable 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 there would be a significant investment to redesign the lift 

structure and anticipated additional product cost.