Child Passenger’s Bill of Rights on a Plane

Posted by thecarseatlady on January 7, 2014 · 6 Comments 

For more information, see the following FAA documents pertaining to traveling by plane with children in car seats.

Regulatory Requirements Regarding Accommodation of Child Restraint Systems

FAA Advisory Circular: Use of Child Restraint Systems on Aircraft

If you had a bad experience on a flight, let the FAA know – click here.

If you purchased a ticket for your child, you are entitled to use your child’s car seat.  

FAA sticker on a car seat (will ALWAYS be in RED)

No airline may “prohibit a child from using an approved CRS (Child Restraint System) when the parent/guardian purchases a ticket for the child.” (Section 10-d, page 7)

If your car seat does not fit in your child’s assigned airplane seat, the airline has to try to find a different airplane seat that will accommodate the car seat.

“No aircraft operator may prohibit a child from using an approved CRS when the parent/guardian purchases a seat for the child. If an approved CRS, for which a ticket has been purchased, does not fit in a particular seat on the aircraft, the aircraft operator has the responsibility to accommodate the CRS in another seat in the same class of service. The regulations also permit an aircraft operator to use its discretion in identifying the most appropriate forward-facing passenger seat location, considering safe operating practices. 

For example:

(1) 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.

(2) An aft-facing CRS that can not be installed properly, because of minimal pitch (distance between seats) between rows, can be moved to a bulkhead seat or a seat in a row with additional pitch.” (Section 10-f, page 7)

You may use your car seat rear-facing or forward-facing, depending on your child’s age, height and weight and the car seat’s height and weight limits.

“CRSs must be installed in forward-facing aircraft seats, in accordance with instructions on the label. This includes placing the CRS in the appropriate forward or aft-facing (rear-facing) direction as indicated on the label for the size of the child.” (Section 18, page 11)

This is often misinterpreted by flight attendants – they often understand it to mean that the child’s car seat must face forward. But that is not what this statement means!  The statement means that the airplane seat must face forward (i.e face the front of the plane) – so if you somehow are assigned an airplane seat that faces the back of the plane, you can’t use that seat for the child’s car seat. The direction the child’s car seatfaces – forward or aft (rear) – is based on the age, weight, and height of the child and whether they are within the parameters for rear-facing or forward facing for that particular car seat.

A car seat may be placed in any airplane seat provided that it does not interfere with passengers evacuating the aircraft in an emergency.

“A window seat is the preferred location; however, other locations may be acceptable, provided the CRS does not block the egress of any passenger, including the child’s parent or guardian, to the aisle used to evacuate the aircraft.  The regulations…allow aircraft operators to determine the most appropriate passenger seat location for CRSs based on safe operating practices. In making this determination, an aircraft operator should consider the following. 
 

a. Aisle Seats. CRSs should not be placed in an aisle seat because this placement has the highest risk of slowing down the passenger flow rate during an evacuation. For example, a parent or guardian traveling with the child in a CRS may step out into the aisle to release the child from the CRS or the CRS may impede F/As (flight attendants) who may need to climb over the top of aisle seats to get past passengers in the aisle to reach an emergency exit.

b. Rows Forward and Aft of Emergency Exit Rows. Each aircraft operator’s specific evacuation procedures should be considered during the development of procedures regarding placement of CRSs on aircraft. 
 

(1) In an evacuation, space has to be rapidly cleared forward or aft of the exit row so that no one would be hurt or trapped if the exit hatch was thrown in this area. A delay may occur as a parent/guardian removes a child from a CRS. If the aircraft operator’s crewmember evacuation procedures or instructions to passengers demonstrate the removal and placement of Type III exit hatches …in the row forward or aft of the emergency exit row, the aircraft operator should restrict the placement of CRSs accordingly.

(2) Installation of a CRS in the row forward of an exit keeps a seat back from breaking over. Aircraft seats are not required to break over, but if an aircraft operates with this feature and evacuation procedures include breaking over seat backs forward of an exit to create space for a crewmember or to create a wider evacuation path for passengers, the aircraft operator should restrict the placement of CRSs accordingly.” (Section 18, page 11)
 

You may use a car seat for a child of any age or size, as long as he/she is within the car seat’s height and weight limits.

“Aircraft operators should ensure F/As (flight attendants) are aware that older children (who have not reached their eighteenth birthday) may use a properly approved CRS that is appropriate for that child’s size and weight. In this case, the aircraft operator may not prohibit the use of the CRS.” (Section 23, page 13)

You may use a combination seat (sometimes also called booster seats–these are seats that start off as 5 point harnesses and then turn into booster seats once your child is old/big/mature enough) on an airplane provided the combination seat is used in the 5 point harness mode and is labeled as certified for use in motor vehicles and aircraft.

 

“Some manufacturers choose to market and label their approved CRSs with backs as “booster seats.”… these “booster seats” fall into two categories, those with and without internal restraints….With internal restraints, solid backs, and the proper labeling, these CRSs marketed as “booster seats” will be labeled as certified for use in motor vehicles and aircraft and may be used for all phases of flight.” (Section16b, pages 10-11)Basically, traditional boosters can’t be used on airplanes since boosters need a shoulder belt – and airplanes just have lap belts.  However, if you are using the 5 point harness mode of a combination seat, you absolutely can use it on the airplane.
 

Your car seat is considered “certified for use in motor vehicles and aircraft” if it has that phrase on the label on the seat.  If the label is unreadable or missing, you may bring along your car seat’s owners manual which will contain the same phrase as is on the label.  (If you lost your owner’s manual you can download one from the manufacturer’s website.)  A letter or document from the manufacturer is also acceptable. 
 

“When an approved CRS is labeled or marked by the manufacturer, it certifies the CRS meets a set of safety standards….Current operating rules require the CRS used on an aircraft during ground movement, takeoff, and landing must bear labels or markings to indicate to the aircraft operator that the CRS meets safety standards. When a parent/guardian presents an approved CRS for use on aircraft with a worn off or unreadable label, the CRS must be furnished with a letter or document from the manufacturer that specifically ties the CRS (through a detailed description or specific make and model number) to approval for use on aircraft. An owner’s manual is also acceptable as proof of safety standards….” (Section 11, page 7)
 

You can use a foreign-made car seat on an American-based airline provided the car seat has a label or sticker stating that it is approved by the foreign government for use in aircraft.   

 

“The CRS must bear either a label showing approval of a foreign government or a label showing that the CRS was manufactured under the standards of the United Nations.” (Section 9b, page 5)

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