Mandate for Child Restraint System in Aircraft is Still Up in the Air

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In 2015, the Transportation Safety Board (TSB) of Canada asked Transport Canada and the aviation industry to develop a restraining system for children equivalent to the level of safety for adults travelling on commercial aircraft.  This recommendation stemmed from an investigation of Perimeter Aviation Flight 993, where a Fairchild Metro twin-engine turboprop crashed at Sanikiluaq Airport in Nunavut in December 2012.

Fairchild aircraft crashed December 2012 at Sanikiluaq Airport in Nunavut killing an unrestrained six-month-old child. Photo courtesy of the Transportation Safety Board of Canada.
Fairchild aircraft crashed December 2012 at Sanikiluaq Airport in Nunavut killing an unrestrained six-month-old child. Photo courtesy of the Transportation Safety Board of Canada.

After an unsuccessful attempt to abort the landing, the aircraft came in too high and too fast, hitting the ground 525 feet past the end of the runway, investigators reported.  Two crewmembers and six adult passengers, restrained properly with seatbelts, suffered minor to serious injuries but a six-month-old baby boy ejected from his mother’s arms suffered multiple trauma and succumbed to his injuries.  He was found unresponsive under the captain's rudder pedals.

Car seats on aircraft have been permitted in Canada since 1990, but they are not mandatory.

“Children under two years of age may be held in a passenger’s arms.  Section 705.43 of the Civil Aviation Regulations requires that a passenger travelling with an infant receive a safety briefing from a member of the flight crew on the appropriate methods of holding the infant during take-off and landing,” said Marie-Anyk Côté, Acting Manager of Media Relations for Transport Canada.

“Following the publication of Transportation Safety Board of Canada Aviation Investigation Report A12Q0216, Transport Canada began to explore ways to increase the range of child restraint systems that parents or guardians can use on Canadian aircraft.  The intent was to identify those child restraint systems approved under United Nations standards or by a foreign government that will be deemed acceptable for use on board Canadian aircraft,” said Côté.

“As an interim measure, a national exemption was issued to permit passengers to use a child restraint system meeting certain specified foreign design standards.  The intent is to promote seamless international operations and provide an acceptable level of safety,” Côté added.  

In 2018, Transport Canada launched a review that included public and stakeholder consultations to consider the risks and benefits of making child restraint systems (car seats) mandatory on board commercial flights for children under two-years-of-age.  At present, this review is still ongoing.

International Civil Aviation Organization (ICAO)

The ICAO ‘Manual on the Approval and Use of Child Restraint Systems (Doc 10049), published under the authority of the Secretary General, included a study conducted by TÜV Rheinland Kraftfahrt GmbH, Team Aviation, by order of the European Aviation Safety Agency (EASA).

“A lap-held infant acts as an energy absorption element for the adult when both share a seat.  The infant does not have his or her own survival space.  During an accident sequence, the crash loads are reduced for the adult.  However, for the infant they increase significantly.

“It is not possible for a parent to physically restrain an infant or child, especially during a sudden acceleration or deceleration, unanticipated or severe turbulence, or impact.  The use of CRS provides an equivalent level of safety to infants and children as that afforded to adult passengers wearing seat belts.”

International Civil Aviation Organization
Doc 10049, Manual on the Approval and Use of Child Restraint Systems

In such instances, the infant is additionally loaded by the pressure of the downward movement of the adult’s upper torso and his or her femurs hitting upwards.  Therefore, the study concluded that the transport of lap-held infants secured with or without a supplemental loop belt does not provide any protection to the infant.”  ~, excerpt from International Civil Aviation Organization, Doc 10049, Manual on the Approval and Use of Child Restraint Systems

The ICAO further states that, “In emergency landings, as required by the certification process, an infant weighs at least sixteen times more than he or she normally weighs.  In turbulence, upward accelerations in an aircraft can reach up to 6G.” 

American Airlines Investigated for Violating Regulations

American Airlines is being investigated by the FAA for allegedly violating federal air regulations for the second time in less than a year.  A flight attendant refused to let a parent board an airplane with an FAA approved safety seat for her one-year-old child even though she purchased a ticket.  The parent was given no other option other than to hold her child on her lap.  Many parents have experienced the same situation.  Federal regulations state that airlines are required to allow a parent who has purchased a seat for his/her child to use an approved child restraint in that seat. 

We are not allowed to hold anything in our laps during take off and landing: no purses, no laptops, no devices – and yet, for some reason, it’s still acceptable for children to be held in the arms of a parent or guardian. 

The most vulnerable person to travel on an airplane is a lap child.”

Stephanie Shaw,
Safety Advocate for the National Transportation Safety Board in Washington, DC

I spoke with Stephanie Shaw, Safety Advocate for the National Transportation Safety Board (NTSB) in Washington, DC, and she said, “It is our recommendation that all children under the age-of-two have their own seat on an airplane and be properly restrained in an approved CRS for aircraft.

“For decades we have stood firm that no matter what mode of transportation parents are choosing for travel, the best and safest way is to have their children properly restrained,” added Shaw.

Travelling by Air is Safer for Children than Travelling by Car

Transport Canada states, “Over the last 30 years, there have been four aircraft accidents in Canada and the United States where a requirement to use car seats may have prevented five infant deaths, or increased their chance to survive, and one incident where a three-year-old in a child restraint system (CRS) was the sole survivor in the plane crash.”                                    

Transport Canada conducted a comprehensive examination of mandating CRS and found that:

  • There is very low probability of an infant death on a commercial aircraft in Canada, measured at one fatality per 646,558,889 passengers (2012-2016).
  • Making car seats a requirement in aircraft could raise airfare prices. In Canada, this would affect just under 4 million families with small children.  Because family travel is among the most price sensitive, families would perhaps choose to drive to their destination rather than pay for a dedicated seat for their young child in a mandatory aircraft CRS.
  • Parents choosing to drive to their destination of choice rather than fly would add 164 million more vehicle kilometres of highway travel per year on Canadian roads. This would translate into at least 10 premature highway deaths in the next decade in Canada, but might save one infant life by air.

Transport Canada states that 80% of car seats are installed incorrectly. 

With the proper installation, child deaths and injuries due to motor vehicle collisions could be prevented. 

Every year in Canada, about 10,000 children (from infancy to 12-years-of-age) are hurt or killed on the roads.  The best thing you can do to prevent this from happening, is to make sure your children are always buckled-up properly.

The FAA stated airfare prices could increase by 45% should CRS be mandated, but this percentage value is speculative.

Transportation Safety Board of Canada's statistical data revealed it is safer for children to travel by air than by car.  Should the aviation industry

mandate the use of child restraint systems, the price of airfare would increase and this cost could deter parents from travelling by air.

“Transport Canada recognizes the importance and complexity of this matter, and takes it very seriously.  Our review of the risks and benefits of making child restraint systems mandatory for children under two is ongoing,” said Côté.

The European Union Aviation Safety Agency (EASA) Approves ‘Loop Belts’

Since 2008, the European Union law states that children under two-years-of-age are allowed to sit on a parent’s lap bust must be secured by a supplementary 'loop belt', which is attached to the seat belt of the adult who is holding the child on his/her lap.  However, to enhance safety of the youngest passengers, EASA strongly encourages that infants and small children be secured in an approved child seat, on a dedicated seat in the cabin. 

The ICAO Does Not Approve ‘Loop Belts’

In 1994, The FAA issued a study entitled, ‘The Performance of Child Restraint Devices in Transport Airplane Passenger Seats’.  The research for this study was conducted by the FAA Civil Aerospace Medical Institute (CAMI), involving dynamic impact tests with a variety of CRS installed in aircraft passenger seats.  The results of this study were used by the FAA as the basis for prohibiting the use of supplemental ‘loop belts’.

“During dynamic testing of supplemental loop belts, the forward flailing of the adult and the child resulted in severe body impacts against the forward row seat.  The child test dummy moved forward to impact the forward row seat back, followed by the adult test dummy torso striking the child test dummy.  Then, the adult test dummy torso continued to move forward after contact with the child test dummy, crushing the child test dummy against the seat back.”

Another study was conducted by TÜV Rheinland Kraftfahrt GmbH, Team Aviation and published in 2008, by order of the European Aviation Safety Agency (EASA).  The study came to the conclusion that the lap-held transport of infants restrained with or without a supplemental loop belt does not provide a safe restraint for them during rejected take-offs, runway excursions, turbulence, emergency landings and other accidents.

ICAO Assesses Safety Issues

The International Civil Aviation Organization (ICAO), a UN specialized agency that works with 191 member states and global aviation organizations to develop international standards and recommended practices, has not set an international standard requiring the use of a CRS for children under the age-of-two.  However, it has adopted the position that “the safest way to secure an infant or child on board an aircraft is in a State-approved CRS, in a dedicated seat, appropriate for that infant or child”. 

The ICAO is still assessing this safety issue and considering the introduction of new regulations in 2020.

Helpful tips from Transport Canada

Canadian Aviation Regulations state that one person can be responsible for one child under the age of two.  If there are two children under the age of two, another passenger must accompany one of the children, even if a seat is purchased for them.  The rows, aisles and emergency exits on an airplane are narrow, and should there be an emergency evacuation, it would be especially difficult and very dangerous for one person to carry two infants.

Aircraft seats are designed to different standards than automobile seats, so restraint devices may work and fit differently.  If you decide to use a car seat, always:

  • Check with your airline for specific CRS policies
  • Follow the manufacturer’s installation instructions
  • Tighten the aircraft seat belt through the correct path on the car seat
  • Secure straps out of the way since tether straps cannot be used on board the aircraft

For more information regarding:

  • approved child restraint systems for aircraft,
  • devices not approved for use as child restraint systems on an aircraft
  • the use of child comfort devices
  • packing, and
  • pre-boarding

please visit: Government of Canada – Taking Children on a Plane

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