Aircraft passengers tend not to worry about the in-flight safety of their children, says Lucille Fisher, whose job is writing and rewriting safety requirements for business aircraft owners and operators. But, she adds, the truth is they should.
First of all, she explained, FAA requirements for child restraint systems are minimal. Second, those airline seats designed to withstand a 16-g impact were created around adult biometrics and do not account for those of infants or small children. And finally, no child sitting in an adult’s lap is truly safe.
While the FAA does not mandate use of a child seat or restraint system, in its guidance to employees it emphasizes “the safest place for your little one during turbulence or an emergency is in an approved children restraint system (CRS) or device, not on your lap.”
What the agency recommends is a hard-backed safety seat approved by the government for use in both motor vehicles and aircraft. In addition, the agency has approved a harness-type restraint appropriate for children weighing between 22 and 44 pounds.
CRSs, according to Part 135 regulations, should have a solid back and seat and should not be confused with “booster” seats that are defined by federal motor vehicle standards as not having a back. The FAA also notes that some aviation-approved CRSs are actually labeled and sold as “booster” seats. A CRS “should have internal restraint straps installed to securely hold the child to the CRS.”
Whether it is a Part 91 or Part 135 operation, the CRS–rear-facing or forward-facing–must be “properly secured” in a forward-facing seat or berth, and the weight of the child may not exceed the specific weight for the restraint system being used.
The FAA recommends use of a rear-facing child restraint system for children weighing less than 20 pounds, and a forward-facing system for children weighing between 20 and 40 pounds.
Regardless of age, children weighing more than 40 pounds, says the FAA, should use the standard lap belt that is part of every aircraft seat.
While this is the FAA’s official stance, there are some who disagree, among them Manfred Groening, CEO of Innovint Aircraft Interior in Hamburg, Germany. Despite the 40-pound cutoff weight for children in CRS seats, he noted that the design of today’s aircraft seat is based on adult biometrics, and turbulence or impact will have a different effect on a child’s body, particularly with regard to the older 9-g seats in which the seat-back will fold forward on impact.
Fisher, president of Quality Resources, a Lyndhurst, Ohio-based aviation management consulting firm, believes that lap children should be prohibited in the cabin. However, she acknowledges that this is something the FAA is unlikely to require, considering the financial cost to the carriers.
She puts responsibility for the safety of children in the cabin squarely on the pilot-in-command. This is the individual, she says, who should ensure that a CRS meets regulatory requirements and that children are properly restrained.
As for the FAA regulations, both Part 91 and Part 135 require that a parent, guardian or attendant appointed by the child’s parent or guardian, should be responsible for the child’s safety, regardless of the child’s age. Further, the regulations require that a child in an approved CRS be accompanied by a parent, guardian or attendant approved by the child’s parent or guardian.
The regulations go on to say that the CRS may not be placed so that it blocks access to an emergency exit aisle, and it should be placed so that the accompanying adult can quickly release the child if an emergency evacuation should be necessary. An exception is made to allow a CRS to be placed in an emergency exit aisle if there is no other forward-facing seat. Under no circumstances may a child restrained in a CRS be placed in a side-facing seat or divan.
Also not approved by the FAA for child use are the vest-type restraint systems or “belly belt” extenders that attach both the adult and child in the same seat. Such devices that typically attach a child to an adult can contribute to injuries when the adult rotates over his or her seat belt during a sudden deceleration.
Fischer said it is interesting that the FAA requires that such hard and heavy objects as coffee pots be secured during takeoff and landing. In case of sudden deceleration or impact, says the administration, such objects could become deadly projectiles. “Without doing the calculations,” said Fisher, “it is obvious that a 23-month-old child who weighs 32 pounds would be no less a danger to the cabin’s occupants than a coffee pot; not to mention the danger to the child thrown violently about the cabin.”
Those inclined to disregard Fisher’s advice might consider the 24 seconds of sudden in-flight upset that killed seven passengers in the cabin of a Falcon 900. The incident occurred in September 1999 as the aircraft was descending from 15,000 feet in Romanian airspace.
When the pilot attempted to bring the nose of the airplane up without first disengaging the autopilot, the airplane experienced a series of violent oscillations that resulted in the death of Greek foreign affairs deputy minister Giannos Kranidiotis and six others in the cabin, none of whom was belted into his or her seat.
“Try to imagine the fate of a lap child under those conditions,” said Fisher.
Jan Brown, the chief flight attendant on American Airlines Flight 232, which crashed attempting to land with disabled flight controls at Sioux City Gateway Airport on July 19, 1989, doesn’t have to imagine. She remembers there were four lap children on that flight, and that as the aircraft neared the runway, minutes before the DC-10 with 296 people aboard hit and broke up, she was, as required by FAA regulations, telling those with lap children to place them on the floor between their legs and cushion them as well as possible with blankets and pillows.
Of the four lap children, three survived, but it is no thanks to FAA safety regulations in force then or now. Brown later recalled that the mother of the child who died came to her at the crash site and said, “You told me to put my baby on the floor and now he’s gone.”
Since the crash, Brown has been a tireless advocate of FAA regulations requiring approved child-restraint systems and seats and a prohibition on lap-children. Twenty years later, she told AIN, “I am appalled that the FAA has done nothing.”
Child-restraint Systems and Seats Available
What alternatives are there to bringing a little one on a flight as a lap child? The FAA does not require the use of a child restraint system or seat. On the other hand, agency standards clearly state that if a CRS system is approved for use aboard aircraft, it must also be approved for use in motor vehicles as well. There are a number of such systems on the market.
The 25.3-pound SkyKids seat has received EASA approval as a child restraint system, can be installed in a forward- or rear-facing configuration, and meets 16-g standards. The seat itself has an over-the-shoulders belt arrangement. Initially accepted by several airlines, it is now finding favor among private jet owners and operators. According to Manfred Groening, CEO of Innovint Aircraft Interior, Lufthansa Technik has purchased the seats for the owner of an executive Airbus A340 being completed in Hamburg. A number of charter operators, among them PrivatAir, have purchased them for use by clients, as has Swiss air ambulance operator Riga.
In the U.S., the FAA has approved a four-point belt restraint system from AmSafe Aviation of Phoenix, Arizona. Dubbed Cares (child aviation restraint system), it augments the standard seat with a shoulder harness that attaches to a belt wrapped around the center portion of the seatback.
According to the FAA, it is designed for children weighing between 22 and 44 pounds and is “a smaller and lighter alternative to using forward-facing child safety seats.” One of the advantages is that it weighs slightly more than a pound and fits into a six-inch stuff-sack. It lists for $74.99 but sells through Amazon.com for $63.87. It is not approved by the Department of Transportation for use in motor vehicles. It has met 16-g dynamic testing standards.
Astronics DME sells PlaneSeat for infants up to 20 pounds and toddlers from 20 to 40 pounds and up to 40 inches tall. Like the SkyKid, it attaches by way of the standard seat belt and has an over-the-shoulder belt arrangement. The 14.7-pound seat meets requirements for both aviation and motor vehicles, folds for easy storage, meets 16-g standards and can be installed in a forward- or rear-facing position. According to marketing director Carl Cooper, any aviation child-restraint seat that meets motor vehicle requirements also meets aviation’s 16-g standards.
Seats for Younger Children, Allowed By FAA But Not Required
The FAA does have regulations regarding child safety in flight, covering both Part 91 and Part 135 and focused primarily on child restraint systems.
Government-approved child restraint systems commonly known as car seats are allowed–but not required–for younger children. However, such portable CRSs must be properly labeled.
• Seats manufactured to U.S. standards between Jan. 1, 1981, and Feb. 25, 1985, must have a label reading, “This child restraint system conforms to all applicable federal motor vehicle safety standards.”
• Seats manufactured to U.S. standards on or after Feb. 26, 1985, must bear two labels, “This child restraint system conforms to all applicable federal motor vehicle standards” and another in red lettering, “This restraint is certified for use in motor vehicles and aircraft.”
• Child restraint systems bearing a label expressing the approval of a foreign government or a label showing that it was manufactured under United Nations standards are also approved by the FAA.
Kids Need Oxygen, Too
While some progress is being made with regard to safer seating for children on aircraft, the issue of emergency oxygen is occasionally ignored, according to Lucille Fisher, president of Quality Resources of Lyndhurst, Ohio, and author of hundreds of safety manuals.
FAA regulations, she pointed out, require a supplemental oxygen mask for “each occupant” at altitudes above 15,000 feet. That is the minimum mask requirement, and “each occupant” includes all lap children, not merely the same number of adult passengers as there are seats.
In short, every aircraft has one supplemental oxygen mask, plus two, one of which is typically located in the lavatory. Larger business jets may carry three more than required; all with a 10-minute supply of emergency oxygen.
It is not unusual for a private jet with 12 seats to have a passenger manifest of 12 adults and three or four lap-children. The bottom line, she said, is that if that airplane takes off with one more soul aboard than there are supplemental oxygen masks, it is operating illegally.
And Fisher concluded, don’t be misled by the term “supplemental oxygen.” If those masks are needed, she said, surely it will be an emergency.