|Child Restraint Seats|
Regulations drafted over 50 years ago required individual safety belts for all passengers and crew; excluding infants. The regulation has not changed much since then. Today parents have three choices: hold the child under the age of two on the lap, take a child restraint seat (CRS) and hope there is an empty seat, or purchase a seat for the CRS.
AFA does not believe that allowing a child under two to be held on the lap affords the child the same protections as the other passengers. For that reason AFA has advocated for the use of child restraints during takeoff, landing and turbulence for 15 years. After all, per the Federal Aviation Regulations, everything on board an airplane must be secured or properly stowed for takeoff, landing and often during flight, except children under two years old.
AFA's fight to secure a mandate for safety seats on airplanes for children under two was influenced by two devastating tragedies in which children were lost: the 1989 United flight 232 which crashed in a Sioux City corn field and the 1994 US Airways flight 1016 which collided with trees and a private residence near the airport in Charlotte, North Carolina.
The Federal Aviation Administration (FAA) has argued that requiring CRS will lead to increases in costs, which will lead families to divert to more dangerous modes, resulting in more deaths and injuries. However, a recent National Transportation Safety Board (NTSB) report clearly refutes this argument. AFA has also consistently refuted this diversion argument because it was based on a speculative assumption of behavior. Until the FAA mandates the use of child restraint systems on airplanes, many parents will continue to have a false sense of security that holding their child is adequate.
On August 26, 2005 the FAA withdrew their 1998 ANPRM regarding mandatory use of Child Restraint Systems (CRS) for children under the age of two in aircraft during all phases of flight. They state the reason for withdrawing the ANPRM was that it was not appropriate for the FAA to mandate the use of CRS because carriers may find it necessary to charge for the seat, in turn, forcing adults to drive instead of fly to their destination. The FAA states that statistically driving is more dangerous than flying therefore there would be an increase in infant deaths.
The second item that was published on the same day was a final rule amending the operating regulations to allow the use, on board aircraft, of CRS that are approved by the FAA through a Type Certificate, Supplemental Type Certificate, or a Technical Standard Order. Current FAA regulations do not allow the use of CRSs other than those that meet specific standards for the automobile environment. The intended effect of this regulation is to reduce the regulatory burden to industry while maintaining or increasing safety. They hope this will allow a wider variety of CRS. This final rule is effective from September 26, 2005.
The Air, Safety, Health and Security Department reviewed the materials and submitted comments to the docket on behalf of AFA in a letter dated September 27, 2005.
AFA Activity and Hot Topics
AFA-CWA Advocates for Child Safety
AFA-CWA PUSHES FOR MANDATORY USE OF CHILD RESTRAINT DEVICES ON ALL PASSENGER AIRCRAFT
December 9, 2010, Washington, DC –The Association of Flight Attendants-CWA (AFA-CWA) today participated in the National Transportation Safety Board’s (NTSB) forum on child passenger safety. As a participant on the Aviation Child Passenger Safety panel, AFA-CWA International President Pat Friend reiterated the union’s longstanding call for separate seats and restraints for passengers less than two years of age.
“As flight attendants, we are required to secure all items in the cabin, galley and lavatories; from carry-on bags to coffee pots. We do this because we are trained that in an emergency loose items can be dangerous if flying through the cabin. A lap child has the potential to be one of those ‘loose items’ that may not only suffer serious injury themselves but also injure others,” said Friend.
For over 20 years, AFA-CWA has advocated for the mandatory use of child restraints in aircraft and supported the NTSB’s recommendations that the Federal Aviation Administration require all infants and small children use safety seats during takeoff, landing and turbulence. Unfortunately, the FAA’s decision to continue allowing children under the age of two to be held on a parent’s lap gives many parents the false impression that this practice is safe.
“To achieve one level of safety for our most vulnerable travelers, we must develop a strong regulation and couple it with adequate monitoring and enforcement. It is through agencies like the NTSB making recommendations aimed at protecting children from death and injury in transportation-related crashes that the traveling public has a slightly increased awareness regarding the need to protect infants and small children,” said Friend.
Download: CRS Forum 9Dec2010_Friend_Written.pdf
NTSB Premiers Child Restraint Safety Video
At the December 9, 2010 Child Passenger Safety Forum the National Transportation Safety Board (NTSB) premiered their educational video on the importance of proper child restraint use in airplanes and automobiles through education and advocacy that is aimed toward the caregivers of children and the transportation industry. Another purpose is identifying effective strategies to increase child seat and seat belt usage.
The video and other videos can be viewed on the NTSB's youtube page: http://www.youtube.com/user/ntsbgov
AFA Press Release Aug. 3, 2004: Child Restraint Devices Remain NTSB Priority
AFA Press Release Feb. 26, 2004: Flight Attendants Urge NTSB to Keep Recommendation on Child Restraints
AFA Statement to NTSB: Witkowski Brief to NTSB Feb. 26, 2004
United 232 Flight Attendant/Survivor Statement to NTSB: Jan Lohr Brief Feb. 26, 2004
References to News Articles
Sept. 15, 2005 Air Safety Week: Special Report: Child Safety [reprinted with permission]
BIG ISSUE FOR BABIES: FLIGHT SAFETY [Note: Access to the full article may require a subscription], The Boston Globe, Boston, MA, Sept. 12, 2004: “During takeoffs and landings, federal safety regulations require passengers to buckle in, stow their bags, and place their tray tables in the upright and locked position. Those same passengers, however, are allowed to hold on their laps, without any restraint, an infant or toddler under age 2…”
Child seats urged for air travel, USA Today, Washington, DC, Aug. 3, 2004: “The National Transportation Safety Board on Tuesday renewed its call for mandatory child safety seats on airline flights, calling their absence ‘unacceptable.’ But the agency responsible for investigating aviation accidents can't force airlines to require the restraints.”
NTSB Report, Analysis of Diversion to Automobile in regard to the disposition of Safety Recommendation A-95-51, August 3, 2004
2005 FAA Advance Notice of Proposed Rulemaking, Withdrawal, Child Restraint Systems: AFA Comments
2003 Petition for Exemption JetBlue Airways: AFA Comments
1998 Advance Notice of Proposed Rulemaking 98-2: AFA Comments
Download: Witkowski_Brief_to_NTSB.pdf, Jan Lohr NTSB Brief.pdf, AFA comments 1998.pdf, AFA comments petition 15751.pdf, CRS_wTSOallowed05-16782.pdf, ASW_Sept12_2005_CRSArticle.pdf, FAA-2001-9483-0283.pdf, CRSForum9Dec2010_Friend_Written.pdf