Recommendations on Standards for the Design of Medical Diagnostic Equipment for Adults with Disabilities, Advisory Committee Final Report

1.4 Overview of Report

This report presents the recommendations of the MDE Advisory Committee for accessibility standards. The report is organized into eight sections including this introduction. The ensuing seven sections address the following:

• Section 2, Background, describes important contextual issues that guided the thinking of various Committee members about the need for and potential nature of accessibility standards.

• Section 3, MDE Advisory Committee Approach, gives an overview of Committee deliberations (starting with refining the members’ understanding of MDE) and Committee logistics, including the role of six Subcommittees.

• Section 4, Background Information for Broad Equipment Types, provides initial information about the features of the five broad categories of equipment (examination tables and chairs, stretchers, imaging equipment, mammography equipment, and weight scales) the Committee considered in making its accessibility standards recommendations.

• Section 5 presents the recommendations for accessibility standards along with the rationale and comments specific to different equipment categories.

• Section 6 briefly introduces the standard about which Committee members did not reach consensus: the minimum transfer surface height. It refers readers to Minority Reports appended to this report for the unedited perspectives of various Advisory Committee members on the minimum transfer surface height standard.

• Section 7, Diagnostic Imaging Equipment Accessibility Considerations, provides more detail about features of imaging equipment that affect their accessibility and describes a concept developed by some Committee members for “imaging system accessibility configurations” that aim to facilitate access of persons with disabilities to current imaging machines.

• Section 8 concludes by discussing issues that the Committee did not address and concerns that merit future attention.

Finally, although ensuing sections address these issues in greater depth, several key points up front might guide review of this MDE Advisory Committee report. First, by necessity, the Committee could only consider existing medical diagnostic equipment and technologies, such as diagnostic imaging systems. Future technological advances can only be imagined. However, as is clear throughout the report, with some important exceptions, current equipment designs rarely accommodate fully persons with disabilities. Therefore, improving accessibility will require new equipment designs and engineering, as well as perhaps ways of thinking about diagnostic evaluations. The Advisory Committee urges equipment designers and manufacturers to be forward thinking, perhaps pushing aside historical design techniques to devise new methods to best accommodate the growing population of persons with disabilities in the U.S. The Advisory Committee also recommends that equipment designers and manufacturers work closely with persons with disabilities as they address accessibility accommodations. Just as designers and manufacturers seek input from various scientists, engineers, and health care professionals while developing new equipment, individuals with disabilities could offer critical insights about accessibility features.

Second, this rulemaking explicitly excluded pediatric diagnostic equipment, despite the increasing number of children living with disabilities. The Advisory Committee itself decided that it did not have the time, information, or resources to fully address medical diagnostic equipment accessibility standards for a critical subpopulation of individuals with disabilities: adults with severe obesity. Future efforts will need to look in-depth at accessibility standards for this group of people, which is also increasing in numbers in the U.S.

Lastly, the Advisory Committee often did not have specific and credible evidence to guide its decisions. Few studies have addressed explicitly the particular issues raised in this rulemaking. The Committee instead relied upon studies concerning related topics, previous accessibility standards approved by the U.S. Access Board, and the informed opinions of a wide range of individuals who gave presentations to the Committee and then discussed various topics with its members. Importantly, a major source of information for Committee members was the open sharing of views among Committee members, who represented a range of stakeholder perspectives. Across nine months, Advisory Committee members worked collaboratively to develop the standards recommended here, reaching consensus in all but one instance. Thus, the standards recommended by the MDE Advisory Committee represent consensus among members from a range of stakeholder organizations.