Boston Center for ndependent Living, Inc.

September 27, 2013

Mr. Rex Pace

Ms. Earlene Sesker

U.S. Access Board

pace@Access-Board.gov

sesker@Access-Board.gov

Re: Comments on Exam Tables and Chairs Subcommittee Report

Dear Mr. Pace, Ms. Sesker, and Members of the U.S. Access Board:

The following comments are provided regarding the Access Board’s Exam Tables and 

Chairs Subcommittee Report.

The Boston Center for Independent Living (BCIL) was founded in 1974 as the nation’s 

second independent living center, and annually provides services to over 4,000 people with 

disabilities in Greater Boston. It is a civil rights organization led by people with disabilities, 

advocating to eliminate discrimination, isolation and segregation by providing advocacy, 

information and referral, peer support, skills training and personal care attendant (PCA) services 

in order to enhance the independence of people with disabilities. BCIL specifically advocates for 

improved access to public transportation, employment, housing, government services, public 

accommodations, and health care. BCIL maintains an active membership, numbering over 500 

people with disabilities. 

As a member-led organization, with scores who have faced repeated discrimination in 

obtaining health care, BCIL has prioritized efforts to support equal access to health care. We 

have reached binding agreements with Massachusetts General Hospital and Brigham’s and 

Women’s Hospital, with a comparable one pending with the Boston Medical Center, to improve 

access to care and services for people with disabilities and ensure compliance with the 

Americans with Disabilities Act. In this work we have connected with many persons with 

significant physical disabilities who have encountered major barriers to care and services in a 

medical setting, and these persons’ experiences underlay the advocacy efforts that produced 

these agreements.

One of the most frequent concerns of these individuals was their inability to receive 

proper medical exams because they could not get on an examination table or because they were 

transferred to a table in an unsafe way. The consequence of examinations in wheelchairs was 

often second-rate care, undoubtedly resulting in poorer health outcomes in certain instances. In 

addition, even when transfer solutions were offered by medical practitioners, those responses 

often included dangerous and undignified lifting by personnel not trained to carry out the task. 

BCIL members have been unable to have gynecological exams, or have needed to be lifted by a 

husband onto tables, or were lifted, while undressed, by male orderlies or even untrained security 

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guards. As a result, the barrier of inaccessible exam tables has produced another notable 

consequence: it discourages individuals from actually seeking needed care. A close associate has 

endured a year of chemotherapy and surgery for advanced cancer that may have been detected 

had she not avoided a precautionary exam in part because of the anticipated humiliation of 

having to explain—yet again— that as a paraplegic she could not stand to access her 

examination procedure.

Anything that inhibits proper transfers for people with disabilities, and not necessarily

just those using wheelchairs, restricts care— which is both a profound civil rights violation and a 

major impediment to quality delivery of health care. A history of neglect by medical facilities 

regarding the simple aim of access to an exam table has harmed countless people with 

disabilities. A failure to mandate the best-possible access, something that would benefit people 

of short stature, including frail elders, little people, and children with disabilities, is not 

acceptable. The most expansive access possible is needed. For way too long people with 

disabilities have faced unequal access because of calculations made in the name of expediency

and short-term cost savings. 

The data provided to the Examination Tables and Chairs Subcommittee and articulated 

by medical practitioners in meetings and reported in the Examination Tables and Chairs 

Subcommittee report speaks to a low-height requirement of 17 inches for exam tables. BCIL 

strongly supports this, especially as we recall the late Frances Deloatch, a BCIL member who 

was involved in our advocacy work with Brigham and Women’s Hospital. For her, a two-inch 

lower exam table may have been critical. Frances had osteogensis imperfecta and was only three 

feet three inches tall. She once said that if her primary care physician had an exam table that 

lowered, she could transfer to it independently from her wheelchair. However, because of her 

stature, Frances had a child-sized wheelchair, and there is a very good chance that 19 inches 

would have been too high for her to self-transfer. 

We cannot ignore individuals like Frances. A 17-inch height would provide greater 

accessibility and enhance the safety of transfers for small individuals. BCIL encourages you to 

develop the standard that will guarantee access to the greatest number of persons with disabilities 

possible. 

Thank you for considering my comments on behalf of our members and for the board’s

work to achieve equal access. 

Sincerely, 

Bill Henning

Bill Henning

Executive Director