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U.S. Access Board Extends Public Comment Period on Final Specification for Low Transfer Surface Height of Medical Diagnostic Equipment

August 2, 2023
Source: U.S. Access Board

The U.S. Access Board has extended its notice of proposed rulemaking (NPRM) on standards for accessible medical diagnostic equipment (MDE) for 30 days. The NPRM addresses one provision on the low transfer surface height for certain types of MDE used by patients in a supine, prone, side-lying, or seated position. Public comments for the NPRM are due by August 31, 2023.

The MDE Accessibility Standards require an adjustable transfer surface height with a high height of 25 inches, a low height range of 17 – 19 inches, and four intermediate heights within the high-low range. The Board created the 17 – 19-inch range for the low transfer surface height due to a lack of consensus on the MDE Advisory Committee and to allow the Board to conduct further research on the issue. Since the publication of the MDE Accessibility Standards, the Board commissioned a statistical analysis of occupied seat heights for manual and powered wheelchair users. In January 2022, the “Analysis of Low Wheelchair Seat Heights and Transfer Surfaces for Medical Diagnostic Equipment” Final Report was published, and the Board invited public comment on the findings in the final report and any new information regarding the low transfer surface height provision. In May 2022, the Board also held a MDE public meeting and accepted written comments to obtain further information on the appropriate low-height specification of transfer surfaces for MDE.

In this NPRM, the Board is proposing to remove the sunset provisions and require a low transfer surface height of 17 inches. The Board seeks information on costs of compliance, time needed to comply, other research studies, and any other resources, data, or information the Board should consider regarding its proposed minimum low transfer surface height requirement of 17 inches. More information can be found in the NPRM published in the Federal Register.

Individuals may submit comments via any of the following methods: 

Office of Technical and Information Services
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111

For background and more information, access the docket via  For further information, contact Bobby Stinnette at 1-202-272-0021 or, or Wendy Marshall at 1-202-272-0043 or

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