Slide 1:
Welcome to the AccessibilityOnline Webinar Series
A collaborative program between the ADA National Network and the U.S. Access Board
The Session is Scheduled to begin at 2:30pm Eastern Time
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Slide 2:
Webinar Features
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Slide 3:
Webinar Features (con’t)
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Slide 4:
Webinar Features (con’t)
Resize the Whiteboard (where PowerPoint slides are shown): It can be resized using the drop down located in the Whiteboard area. (The default is “Fit Size”).
Emotions:  Please refrain from using the emoticons, hand-raising and polling features during this session unless directed to do so by the presenter.

Slide 5:
Presenter
Earlene Sesker

Slide 6:
Proposed Guidelines for Medical Diagnostic Equipment
Session Agenda

 Background
 Organization of Proposed Rule
 Proposed Technical Criteria
 Major Issues
 Next Steps

Slide 7:
Background
Section 4203 of Patient Protection and Affordable Care Act (Public Law 111-148, 124 Stat. L. 119)
Section 510 of the Rehabilitation Act of 1973

Slide 8:
Federal Partners
U.S. Food and Drug Administration, Department of Health and Human Services
Disability Rights Section, Department of Justice 
Department of Veterans Affairs

Slide 9:
Barriers Affecting Accessibility and Usability of Medical Diagnostic Equipment
•	75% - examination tables moderately difficult to impossible to use
•	68% - radiology equipment moderately difficult to impossible to use
•	53% - weight scales moderately difficult to impossible to use
•	50 % - examination chairs moderately difficult to impossible to use 

Slide 10:
Background
ANSI/AAMI HE75 – 2009 Human Factors Engineering – Design of Medical Devices
Chapter 16 – Accessibility Considerations

Slide 11:
ADA and ABA Accessibility Guidelines

Slide 12:
How The Rule is Organized
Preamble
Regulatory Analysis
Text of the Proposed Rule

Slide 13:
How The Rule is Organized
M1 Application and Administration
M2 Scoping Requirements
M3 Technical Criteria
Supine, Prone, or Side Lying Position
Seated Position
Seated in Wheelchair
Standing Position
Communication
Operable Parts

Slide 14:
Definitions
Enforcing Authority – An agency that adopts the standards as mandatory requirements for entities subject to its jurisdiction.
Medical Diagnostic Equipment – Equipment used in or in conjunction with medical settings by health care providers for diagnostics purposes.

Slide 15:
Definitions
Operable Parts – A component of diagnostics equipment that is used by the patient to activate, deactivate, or adjust the equipment.
Transfer Surface – Part of diagnostic equipment onto which patients who use mobility devices or aids transfer when moving onto and off of the equipment. 

Slide 16:
Supine, Prone, or Side-Lying
Picture of a Magnetic Resonance Imaging Machine
Picture of a Bone Densitometry (Dual Energy X-ray Absorptiometry – or DEXA machine
Picture of an Exam table with raised back support, transfer support, stirrups and foot pedal attached to raise or lower table.
Picture of an echo scan table.

Slide 17:
Supine, Prone, or Side-Lying Position
•	Transfer Surface
•	Supports
•	Lift Compatibility 

Slide 18:
Transfer Surface:
•	Height
•	Size
•	Transfer Sides
Picture of Executive Director and Board Members looking at imaging equipment

Slide 19:
Supine, Prone, or Side-Lying Position
Supports
Transfer Supports
Stirrups
Head and Back Support
Image of a reclined exam table with transfer supports and boot stirrups

Slide 20:	
Lift Compatibility
Drawing showing a portable lift being used to transfer a man to movable exam table.  Two other people assist with the transfer and operate the lift.  

Slide 21:
Specifications for clearance around base:
6 inches high min. clear above finished floor.
Clearance must extend 36 inches deep from the edge of the examination surface.
Base is permitted to increase in width at a rate of 1 inch in width for each 3 inches in depth within clearance. 
Clearance Around base-6 inches high min. clear above finished floor within clearance.  44 inches width minimum. 36 inch minimum or extend full depth

Slide 22
Seated Position
Photograph of an exam chair with stirrups and other attachments.
Photograph of a typical powered exam chair.
Photograph of a dental chair.

Slide 23:
Seated Position
Transfer Surface
Supports
Lift Compatibility
Photograph of person using a wheelchair preparing to transfer onto an exam chair.

Slide 24:	
Lift Compatibility Exception
Where diagnostic equipment meets the requirements of M303 (seated in a wheelchair) and provides a folding seat, the equipment shall not be required to comply with the lift compatibility provisions.
Photograph of a weight scale with an integral seat that folds down onto the standing surface.

Slide 25:
Seated in a Wheelchair
Illustration of a woman using a manual wheelchair pulled up underneath the breast platform of a mammography machine and positioning at the equipment.
Illustration of a man using a power wheelchair positioned on the raised platform of a weight scale.

Slide 26:
Seated in a Wheelchair
•	Wheelchair Spaces
•	Entry
•	Components

Slide 27:
Seated in a Wheelchair
Wheelchair Spaces:
•	Orientation
•	Width
•	Depth
•	Knee Clearance
•	Toe Clearance
Photograph of a woman using a wheelchair positioned underneath optometry equipment.  The chair typically used for eye examinations has been removed to permit the woman to position at the equipment.

Slide 28:
Seated in a Wheelchair
Entry:
Vertical
Beveled
Ramped
Photograph of a woman using a wheelchair positioned on a raised weight scale platform.

Slide 29:
Seated in a Wheelchair
Components
Photograph of an example of scanning equipment that a person using a wheelchair could pull up underneath.
Photograph of an example of scanning equipment that a person using a wheelchair could pull up underneath.
Photograph of an example of scanning equipment that a person using a wheelchair could pull up underneath.

Slide 30:
Seated in a Wheelchair
Components
Height of the breast platform = 30 inches minimum and 42 inches high maximum when in use by a patient seated in a wheelchair.
Illustration of a woman using a manual wheelchair pulled up underneath the breast platform of a mammography machine and positioning at the equipment with the assistance of medical staff.

Slide 31:
Standing
•	Standing Surface
•	Standing Supports 
Illustration of a man standing on weight scale holding onto the standing supports to each side of the raised platform. Illustration of a man standing on weight scale holding onto the standing supports to each side of the raised platform.

Slide 32:
Supports
•	Transfer
•	Standing 
Photograph of a close in view of a hand gripping the support rail along the edge of an exam table.

Slide 33:
Technical Criteria Across Equipment Types
•	Communication 
•	Operable Parts 
Photograph of a close in view of the bore opening of a scanning machine.

Slide 34:
Example of Application Document
Sample page from the Example Applications of the Proposed Medical Diagnostic Equipment Accessibility Standards document.
Cover page of the  Example Applications of the Proposed Medical Diagnostic Equipment Accessibility Standards document.

Slide 35:
Responses to NPRM
46 questions were posed in the preamble
51 commenters 
Range of comments

Slide 36:
Major Issues
•	Transfer Surface Size and Height
•	Transfer Surface Obstructions
•	Transfer Support Location and Configuration
•	Depth of Wheelchair Spaces

Slide 37:
Transfer Surface Height 
Illustration of an exam table with the transfer surface highlighted showing the 17 inches minimum and 19 inches maximum height above the floor.
Slide 38:
Transfer Surface Height
Illustration of an exam chair with the transfer surface highlighted showing  the 17 inches minimum and 19 inches maximum height above the floor.

Slide 39:
Transfer Surface Height
Adjustable Height
a) Types of equipment currently height adjustable?
b) Types of equipment not height adjustable?
c) Equipment that cannot be height adjustable?
d) Intermediate heights? 

Slide 40:
Transfer Surface Height
Patients
Height is a major concern
Range of users accommodated

Slide 41:
Transfer Surface Height
Manufacturers 
Seat profile
Components beneath transfer surface
Span between the lowest transfer height and optimal caregiver height
Cost and redesign

Slide 42:
Transfer Surface Height
Photograph of a bone density scanning machine showing imaging and machinery components beneath the examination surface.
Equipment Design Concerns

Slide 43:
Transfer Surface Size
Illustration of an exam table with the transfer surface highlighted showing 30 inches wide minimum and 15 inches deep minimum

Slide 44:
Transfer Surface Size
Illustration of an exam chair with the transfer surface highlighted showing 21 inches wide minumim and 15 inches deep minimum.

Slide 45:
Transfer Surface Size
Question 15 
Supine, Prone, or Side-Lying Position
a) Is proposed size sufficient? (30” by 15”)
b) Support surface width > transfer surface?
c) Alternate dimensions?
d) Permit expandable surface (e.g., extendable platform)
e) If required to be provided at more than one location where should transfer surface

Slide 46:
Transfer Surface Size
Question 16
Seated Position:
a) Is proposed size sufficient?
b) Alternate dimensions? (21” wide and 15” deep) 
Illustration of person using a wheelchair executing a parallel transfer onto an exam table.
Illustration of person using a wheelchair executing a perpendicular transfer onto a an exam table.

Slide 47:
Responses to NPRM Questions
Patients
•	Space for transfer
•	Repositioning after transfers
•	Range of body sizes 
•	Ergonomics

Slide 48:
Response to NPRM Questions
Manufacturers
•	Use of supports
•	Corner shape on transfer sides
•	Relationship to base design
•	Equipment proportions
•	Redesign and costs
•	Impact on exam room layouts

Slide 49:
Transfer Surface of Size
Photograph of the bore opening of a scanning machine, the exam surface runs through it.
Equipment Design Concerns

Slide 50:
Transfer Surface Size
Diagnostic Equipment Used by Patients in Supine, Prone, or Side-Lying Position
Width: increase to 35 to 36 inches
decrease to 25 to 28 inches 
Same requirement for Equipment Used by Patients in Seated Position 

Slide 51:
Transfer Surface Size
Diagnostic Equipment Used by Patients in in Seated Position 
Alternate dimensions – 17 inches minimum depth 
Relationship to size requirement

Slide 52:
Permanent Obstructions to the Transfer Surface
Illustration of person using a wheelchair executing a parallel transfer onto an exam table.
Illustration of person using a wheelchair executing a perpendicular transfer onto an exam chair.
Same issue for equipment used by patients in a supine, prone, or side-lying and equipment used in a seated position 

Slide 53:
Transfer Sides
Transfer Sides - Located to provide options to transfer from a mobility device onto one short side (depth) and one long side (width) of the surface. Each transfer side to provide unobstructed access to the transfer surface.
EXCEPTION: Temporary obstructions shall be permitted provided that they can be repositioned to permit transfer.

Slide 54:
Permitted Obstructions
Question 17
Transfer Sides:
a)	3 inches maximum extension beyond the edge of the transfer sides 
b)	Redesign requirements
Close in photograph of the side of an exam table showing the railing and support fittings protruding from the equipment base and exam surface.

Slide 55:
Permitted Obstructions
Illustration of a person in a wheelchair seated directly beside an exam table.  A red line is drawn between the chair and the person in wheelchair showing that there is no gap between the two.
Illustration of a person in a wheelchair seated beside a exam table that has an 3 inch protrusion beyond the surface of the table.  Two red lines drawn between person and table highlighting the 3 inch maximum gap. 

Slide 56:
Permitted Obstructions
Equipment Components That Extend Beyond Exam Surface 
Photo of a Doctor standing beside dexa scan with patient lying on scan table
Photo of a Person in wheelchair positioned beside exam table.  Table has bar extensions that cause a transfer over a gap

Slide 57:
Permitted Obstructions
Figure 608.2.2 from ADA and ABA Accessibility Guidelines showing a roll-in shower.
Figure 610.3 from ADA and ABA Accessibility Guidelines rectangular shower seat.  Red arrow highlighting 3 inches gap allowed between the shower entry and the seat.
Shower seat edge is permitted to be 3 inches max. from shower entry 
Slide 58:
Responses to NPRM Questions
Patient Use – If Gap is Permitted
Concerns about safety of transfers across a gap to exam surface
Patient may not be in optimal health
Equipment parts that extend beyond surface should not be permanently mounted 

Slide 59:
Responses to NPRM Questions
Equipment – If Gap is Not Permitted
Need to add accessories
Impact on certain equipment types – beds/stretchers and imaging
Capacity of supports to bear weight loads if removable
Redesign likely and associated cost

Slide 60:
Transfer Research
Study: The Impact of Transfer Setup on the Performance of Independent Wheelchair Transfers
120 Subjects capable of independent transfer
Variety of configurations tested – including distance from seat  
set up reflects amusement ride focus 
Shows the initial setup of the custom-built modular transfer station.  The station consists of a height adjustable platform, a fixed backrest, and a lateral grab bar with a fixed height.  Also shown is the optional variable height grab bar in front of the platform.

Slide 61:
Transfer Research
Height adjusted and spacers added at floor level
A manual wheelchair user transferring to the transfer station set at a higher height than a wheelchair.
Shows the custom-built modular transfer station adjusted to a height lower than a wheelchair with spacers added to create a gap.

Slide 62:
Transfer Support Location and Configuration
Illustration of person using a wheelchair executing a parallel transfer onto an exam table.
Illustration of person using a wheelchair executing a perpendicular transfer onto an exam chair.

Slide 63:
Transfer Support Location and Configuration
At least one transfer support provided on the side of the transfer surface (recommended on each side) 
Illustration of an exam table showing the proposed transfer support location at the side and along the transfer surface.

Slide 64:
Transfer Support Location and Configuration
Question 19
a)	Is proposed criteria sufficient?
b)	Can supports on different types of equipment meet proposed criteria?
c)	Redesign costs?
d)	Alternate technical criteria?
e)	Permit angled or vertical supports?

Slide 65:
Transfer Support Location and Configuration
Question 20
Height:
a)	Considering 6 min. and 19 max. above surface. Is height this range usable?
b)	Can supports on different types of equipment meet proposed criteria?
c)	Alternate criteria?

Slide 66:
Proposed Gripping Surface Cross Section
Illustration of a hand gripping a support showing the minimum and maximum diameter of a circular cross section of 1 ¼ to 2 inches. 
Figure from the ADA-ABA 2004 Guidelines showing the minimum dimensions of non-circular cross sections. 

Slide 67:
Armrest on Exam Chairs
Example of a combination exam table and chair with armrest.
Example of an exam chair with armrest.

Slide 68:
Transfer Support Location and Configuration
Question 21
Cross Section of Gripping Surface:
a) Can transfer support meet grab bar specifications in ADA Standard?
b) Can handholds meeting cross section be integrated in cushioned armrest?
c) Alternate designs?

Slide 69:
Proposed Gripping Surface Clearance
Illustration of a hand gripping a support showing the minimum clearance of 1 ½ inches. 

Slide 70:
Transfer Support Location and Configuration
Question 22
Clearance around Gripping Surfaces:
Can transfer supports on different types of equipment provide 1 ½ inches minimum clearance around the gripping surfaces?

Slide 71:
Depth of Wheelchair Spaces
M303 Diagnostic Equipment Used by Patients Seated in a Wheelchair 
Illustration of a woman using a manual wheelchair pulled up underneath the breast platform of a mammography machine and positioning at the equipment.
Illustration of a man using a power wheelchair positioned on the raised platform of a weight scale.

Slide 72:
Depth of Wheelchair Spaces
Diagrams of the size requirements for wheelchair spaces showing the 36 inches minimum width, the 48 inches minimum depth for a rear or front entry, and the 60 inches minimum depth for a side entry. 

Slide 73:
Depth of Wheelchair Spaces
Clear floor space for forward approach 36" wide minimum  because it is obstructed on both sides at least 24 inches; clear floor space for side approach 60" long minimum because it is recessed and obstructed on both sides at least 15 inches.
Based on 305.7 Maneuvering Clearances where space confined on 3 sides (and more than half of space depth confined) 

Slide 74:
Depth of Wheelchair Spaces
Data from wheeled mobility anthropometry  project indicates a 58 inch width minimum for front or rear entry 
Page from Anthropometry of Wheeled Mobility Project Final Report on clear floor spaces.
Diagram of proposed 58 inch deep wheelchair space.

Slide 75:
Depth of Wheelchair Spaces
Question 29
a)	What would be the incremental costs for the design or redesign and manufacture of the equipment to provide a wheelchair space that is 58 inches deep minimum?
b)	Are there types of equipment that cannot provide a wheelchair space that is 58 inches deep min. because of the structural or operational characteristics of the equipment?	 

Slide 76:
Depth of Wheelchair Spaces
edge protection – 
some curbs permit wheelchair footrests to extend beyond the raised platform
Exceptions Considered if edge protection permits: 
•	32”width minimum, 36” would be needed for arms and elbows
48” depth minimum
Wheelchair Spaces on Raised Platform 
Illustration of a person using a power wheelchair maneuvering onto a weight scale with curbs providing drop-off protection around the edge of the raised platform.

Slide 77:
Depth of Wheelchair Spaces
a)	How much of 48 min. depth of wheelchair space should be permitted to extend beyond raised platform edge and over edge protection?
b)	Maximum height of edge protection to allow extension beyond platform over edge protection?
c)	Should supports be prohibited from obstructing wheelchair space outside the perimeter of the raised platform above any edge protection?
Slide 78:
Depth of Wheelchair Spaces
Question 32
a)	Raised platforms usable by patients who use scooters?
b)	Should width and depth be changed to accommodate scooters?
c)	Should folding seats be required on raised platforms?
d)	If folding seat provided should platform be able to accommodate scooters?

Slide 79:
Next Steps
•	Comment Analysis 
•	Advisory Committee 
•	Final Rule

Slide 80:
Questions
Highlight “GreatLakes” in the participant list and “right click” on your mouse to send a private message.  Type your message into the chat area that appears.  The question will be viewed by all moderators. (Keyboard - F6, Arrow up or down to locate “GreatLakes” and select to send a message ) 

Adjustable Height
a)	Types of equipment currently height adjustable?
b) Types of equipment not height 	adjustable?
•	Equipment that can not be
      height adjustable?
d)	Intermediate heights? 

Supine, Prone, or Side-Lying Position

a)	Is proposed size sufficient? (30” by 15”)
b) 	Support surface width > transfer surface?
c) 	Alternate dimensions?
•	Permit expandable surface (e.g., extendable
      platform)
e)	If required to be provided at more than one
      location where should transfer surface
      be located?

Seated Position:

•	Is proposed size sufficient?

b) Alternate dimensions?
    (21” wide and 15” deep)

    Transfer Sides:

•	3 inches maximum extension beyond the edge of the transfer sides
•	Redesign requirements 

Question 19
•	Is proposed criteria sufficient?
•	Can supports on different types of equipment meet proposed criteria?
•	Redesign costs?
•	Alternate technical criteria?
•	Permit angled or vertical supports?

Height:
•	Considering 6 min. and 19 max. above surface. Is height this range usable?

•	Can supports on different types of equipment meet proposed criteria?

c) 	Alternate criteria?

Cross Section of Gripping Surface:

a) Can transfer support meet grab bar             specifications in ADA Standard?
b) Can handholds meeting cross section be integrated in cushioned armrest?
c)  Alternate designs?

Clearance Around Gripping Surfaces:
Can transfer supports on different types of equipment provide 1 ½ inches minimum clearance around the gripping surfaces?

Based on 305.7 Maneuvering Clearances where space confined on 3 sides (and more than half of space depth confined) 

•	Raised platforms usable by patients who
       use scooters?

•	Should width and depth be changed
       to accommodate scooters?

•	Should folding seats be required
       on raised platforms?

•	If folding seat provided should
       platform be able to
       accommodate scooters?

Next Steps
Questions?
       U.S. Access Board
Thank you for participating in today’s webinar
Next scheduled session:  
“Accessible Amusement Rides” 
January 3, 2013