International policies regarding the use of child restraint systems

Many jurisdictions (e.g., European Union, Australia, New Zealand) permit, or even require, lap-held infants to be restrained with a supplementary or a belly loop belt, which attaches to the adult’s seatbelt and goes around the infant’s abdomen. Canada and the United States do not allow the supplementary loop belt because research has shown that infants so restrained fare worse than unrestrained infants because of the adult’s forward movement during severe impact and the concentrated forces of the supplementary loop belt on the infant’s abdominal region.

A 2004 Australian study found that, although the infant anthropomorphic dummy attached with a supplementary loop belt was restrained during dynamic testing, it underwent significant forward excursion resulting in severe impact of the infant dummy’s head with the forward seatback. In addition, the adult dummy folded over the infant dummy trapping and crushing it in the process. A comprehensive review of the scientific literature on child restraint systems (CRS) in aviation, specifically that addressing the protection from injuries in survivable aviation occurrences for children under 2 years old, as well as accident reports, concluded that in order to provide safety equivalent to that of adult passengers, infants “should be seated in a suitable CRS on a seat of their own.” The report authors further conclude that, “the transport of lap-held infants secured with or without a loop belt does not provide any protection to the infant.”

Previous recommendations for child restraint systems

National Transportation Safety Board

The U.S. National Transportation Safety Board (NTSB) has issued several recommendations on the subject of the mandatory use of CRS for infant passengers, the appropriate use of safety harnesses for children, and educating the public on the risks associated with not using a CRS for children under the age of 2.

The NTSB’s Child and Youth Transportation Safety Initiative promotes child occupant safety in all modes of transportation with a focus on educating parents and caregivers about ways to keep children safe when travelling. The NTSB declared 2011 the Year of the Child and initiated a study on children involved in general aviation (GA) accidents and incidents. During 2011, the NTSB collected data on 19 GA accidents and incidents, which included 39 children who were 14 years old and younger. In total, 26 children sustained fatal injuries, 2 sustained serious injuries, 5 sustained minor injuries, and 6 sustained no injuries. All of the children under 2 years old were restrained in a CRS and sustained no injuries in the accidents.

The NTSB has also put forward the argument that, although passengers are required to securely stow all carry-on baggage during takeoff and landing because of the potential risk of injury to other passengers in the event of an unexpected hazardous event, passengers continue to be permitted to hold a child of equal size and weight in their lap. When children under the age of 2 are not required to be restrained for their own safety, the safety of other passengers also becomes an issue.

Additionally, the NTSB has highlighted several occurrences where crew, passengers and children have sustained injury during unexpected moderate-to-severe turbulence and described how lap-held infants and children would have likely survived the occurrences or suffered less severe injury had they been properly restrained.

The most recent sudden in-flight turbulence event happened on 17 February 2014, when a Boeing 737-700 encountered sudden severe turbulence while on descent to land in Billings, Montana. A flight attendant was critically injured. A lap-held infant flew out of its mother’s arms to land in an empty seat 2 rows away; the infant was not injured. A total of 3 flight attendants and 2 passengers were taken to hospital.

European Union Aviation Safety Agency

The European Union Aviation Safety Agency (EASA) conducted a study on CRS in 2007. Phase II of the study, involving the evaluation of available solutions for restraining infants and children, states that the standard lap belt is not suited for a safe restraint of infants/children. The iliac crest of infants/children is not yet fully developed and, therefore, there is a danger that the lap belt will slip into the infant/child abdominal region in an accident or turbulence, resulting in severe internal injuries. In addition, tests revealed that in the dynamics of a crash, the upper torso of an infant/child can hit against the femurs. The head can hit against the seat in front or the structure of its own seat. The study concludes by stating that:

Child seats must be adapted to the infant /child development in order to provide safe restraint. Child Restraint Device136 requirements must include (in part):

• Infants up to a weight of approx. 9 kg must be transported backward-facing in a CRS.
• Forward-facing CRD must be equipped with restraint systems which are appropriate for children, i. e. either with a belt restraint system or with an impact shield. A belt restraint system which is appropriate for children restrains the pelvis and the upper torso safely in an accident and is adaptable to the infant’s / child’s size. In an impact shield system, the infant’s / child’s pelvis and thorax (sternum) are supported by the impact shield
• The belt restraint system of forward-facing CRD must be equipped with an additional crotch belt preventing the infant/child from slipping under the lap belt.

Safety efforts pertaining to passenger restraint and in-flight turbulence

Transport Canada

In-flight turbulence is the leading cause of injuries to passengers and flight attendants. There have been several accidents and incidents over the years involving clear air turbulence that highlight the importance of keeping loose objects restrained and safety belts fastened throughout a flight. In January 2012, Transport Canada (TC) issued Advisory Circular (AC) 605-004, Issue No. 1 – Use of Safety Belts, in order to emphasize the importance of using the proper restraints during all phases of flight, as sudden, moderate-to- severe turbulence can be the cause of injuries to all on board. It also states that lap-held infants remain subject to injury if not secured during periods of turbulence.

Federal Aviation Administration

In 1995, after several serious and unexpected events of turbulence, the U.S. Federal Aviation Administration (FAA) issued a public advisory to airlines urging the use of seatbelts at all times when passengers are seated. Most airlines now comply, but the requirement does not apply to children younger than 2 years because they are not required to be restrained at any time during the flight.

Following several occurrences involving fatalities and/or injuries during moderate-to-severe turbulence in flight, the FAA issued an Advisory Circular (AC 120-88A) in 2007 addressing the subject of Preventing Injuries Caused by Turbulence. The AC provided information and practices that were known to be effective in preventing injuries caused by turbulence, which includes prompt and clear communication between flight crew and flight attendants, and with passengers on staying seated with seatbelts fastened. It also stressed the importance for flight attendants to secure the cabin equipment so that loose objects will not be thrown about the cabin. The AC also suggested that air carriers develop and implement practices to encourage the use of an approved CRS to secure an infant or a small child that is appropriate for that child’s size and weight; regulations on CRS, however, have not changed. The AC states:

Parents and guardians should be encouraged to have children under 2 occupy an approved CRS any time the fasten seatbelt sign is illuminated. Flight attendants are encouraged to verify that the CRS is secured properly in a forward facing seat and that the child appears to be properly secured in the CRS.

On 17 September 2010, the FAA issued Advisory Circular AC 120-87B – Use of Child Restraint Systems (CRS) on Aircraft. The AC was intended to be a resource for the development, implementation and revision of air carriers’ standard operating procedures and training programs regarding the use of CRS. Although this AC provided considerable information regarding CRS for children over the age of 2, it did not address children under the age of 2. The AC indicated that children under the age of 2 may be held in an adult’s lap during takeoff, landing or movement on the surface. This AC has now been replaced by AC 120-87C {September 2015)

CRS Efforts by the International Civil Aviation Organization

The issue of child safety restraints was recently raised by ICAO member states. ICAO was asked to lead the states on how to best approach the issue. The issue of child safety restraints is included in the 2014-2016 triennium work program for the assigned ICAO Cabin Safety Group (ICSG). The group is composed of 28 participants from various member states, representing various international groups, such as airlines, regulators (including TC), flight attendant respresentatives, and aircraft manufacturers. The working group met in April 2014 to pursue work on the development of guidance on the safety of infants and the use of child restraint systems. Unfortunately, the number of infants and children passengers travelling by air is not available.

The International Transport Workers’ Federation presented a working paper to ICAO for the Assembly – 38th Session Technical Commission, addressing the child restraint issue. The Executive Summary states:

One of the goals of aviation safety is that all reasonable steps be taken to ensure safe air travel for the flying public and crew members. Cabin crew are responsible for the safety, health and security of all occupants in the cabin of commercial airplanes. While fairness dictates that all passengers be afforded the same level of protection, in many countries the youngest and most vulnerable may be allowed to travel on the lap of an adult for taxi, take-off, landing, and during periods of turbulence, if they are under a certain age. In order to ensure that these youngest passengers remain secured during critical phases of flight and turbulence, the exception to international aviation regulations that allows children to travel in the laps of adults must be eliminated.

Related Articles

• In-flight Seat Belt Requirements - with details of regulatory requirements

Further Reading

• Study on Child Restraint Systems, 29 Nov 2008 - study commissioned by EASA.
• FAA AC 120-88A - Preventing Injuries Caused by Turbulence, November 2007.
• FAA Advisory Circular 120-87C Use of Child Restraint Systems on Aircraft, 24 Sep 2015.