Memorandum an Affront to Air Safety

For a perfectly useless document, look no further than the latest Information for Operators (InFO) published by the Federal Aviation Administration (FAA).

InFO 11007 issued on 10 March 2011 concerns “Regulatory Requirements Regarding Accommodation of Child Restraint Systems”. The title suggests that the FAA is doing something meaningful about requiring infants and toddlers to have a child restraint system (CRS). As explained acerbically in this publication, coffee pots and laptop computers must be secured for takeoff and landing, by regulation, but children weighing 40 pounds or less can be held on their parent’s lap where there is nothing to restrain them from being hurled about the cabin should anything go wrong.

The National Transportation Safety Board (NTSB) urged the FAA to require a CRS and put an end to lap children. The FAA rejected this entreaty. (See Aviation Safety Journal, January 2011, “Advisory Group Punts on ‘Lap Children’ in Airliners”)

What the NTSB does not want -- lap children

What the NTSB does not want -- lap children

 

Now the FAA has issued this InFO declaring no operator (i.e., airline) may prohibit a child who has not reached 18 years of age from using an “approved” CRS when the child is going to occupy a separate seat and is accompanied by a parent or guardian.

There is no explanation regarding how a teenager is going to be safer in a CRS than in the basic airline seat with a lap belt.

The InFO provides a number of helpful tips which appear to be quite obvious:

“A CRS with a base that is too wide to fit properly in a seat with rigid armrests can be moved to a seat with moveable armrests that can be raised to accommodate the CRS.”

There is not one word in the InFO about how some CRS’s might be suitable for automobiles but are not certified for airplanes. These auto-only CRS’s are not prohibited on airplanes. A baby or toddler could, in fact, be endangered by the use of a non-aircraft certified CRS.

Some airlines do not allow for the use of non-aircraft certified CRS’s, on the grounds that the seats might not stay in place and, therefore, the occupants may be endangered. The InFO takes a step backward for safety by not making any distinction between aircraft-certified and non-aircraft certified CRSs.

If anything, the InFO is likely to add to the confusion concerning CRSs. The InFO goes into detail about harnesses, detachable and non-detachable bases, forward-facing and aft-facing CRSs, but it fails to mention the essential qualifications: a CRS must be approved for aircraft use, and every child 40-pounds or less must be in a CRS – not held on an adult’s lap.

Turbulence -- another reason for having CRS

Turbulence -- another reason for having CRS

The header to the InFO announces this advisory:

“An InFO contains valuable information for operators that should help them meet certain administrative, regulatory, or operational requirements with relatively low urgency or impact on safety.”

To the dismay of the NTSB and child safety advocates, there is no “regulatory” requirement for an airplane’s littlest passengers to be secured in an aircraft-certified CRS. As far as “relatively low urgency”, the need for child restraints was the NTSB’s highest priority, featured for years on its “Most Wanted” list of safety improvements.

What the NTSB wants -- an FAA requirement for all babies and toddlers to be in their own aircraft-qualified CRS

What the NTSB wants -- an FAA requirement for all babies and toddlers to be in their own aircraft-qualified CRS

The InFO, published by FAA’s Flight Standards Service, is not only a shoddy piece of work, but it is also an insult to those who have recommended proper CRSs aboard airplanes for years. This need still exists.