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

8.3 Alternate Means of Access

As noted throughout this report, MDE Advisory Committee members aimed explicitly to encourage research and innovation to ensure that the next generation of MDE is more accessible than equipment is now. Although current technical requirements may prevent compliance with recommended access standards (see Section 7 for examples), Committee members aimed to encourage manufacturers and developers to consider new and creative solutions to the barriers posed by today’s technologies. As in other areas of technological innovation, the hope is that future MDE developers will aspire to follow universal design principles and enable access for all users.

Nonetheless, MDE Advisory Committee members recognized that certain types of technologies cannot today meet recommended accessibility standards. As discussed in Section 7, this is especially true for some categories of imaging equipment, where specific technological requirements and even laws of physics pose barriers to access with current equipment designs. As noted there, some Committee members recommended “imaging system accessibility configurations” as a relatively expedient way to accommodate persons with disabilities in gaining access to today’s imaging equipment. However, precisely specifying these configurations was beyond the Committee’s statutory authority.

Future rulemaking or standards-setting will need to consider the types of situations where alternate means of access might be allowed and specific provisions for these alternate means. Again, however, the ultimate goal is to encourage innovation to eliminate the access barriers embedded in current technologies. Thus, these future deliberations must also avoid discouraging the pace of innovation.