Monday, December 18, 2017
Transport Canada - Aviation Safety Letter Cabin Safety: Spreading the Word on Aviation Child Restraints

Cabin Safety: Spreading the Word on Aviation Child Restraints

by Erin Johnson, Cabin Safety Project Officer, Cabin Safety Standards, Standards, Civil Aviation, Transport Canada

Whether you are a passenger, crew member or pilot, you may be able to appreciate that travelling with a child can be a daunting experience. Along with concerns over the safety of your child, there are a number of things to consider, such as what to pack and how to keep a child entertained and occupied during flight. Another common concern, and the focus of this article, involves the use of child restraint systems. Questions about age limits, certification, installation and stowage of child restraint systems are often forwarded to Transport Canada.

Use of child restraints for flight is a very important issue to Transport Canada Civil Aviation (TCCA) and to the aviation industry as a whole. The issue has also been a very difficult one at that. Because aircraft seats are designed differently than car seats, not all car seats are compatible in design and function for use on airplanes. There are therefore many operational difficulties associated with the use of car seats on aircraft. As a result, the rules for the use of car seats on airplanes differ. While most parents would never dream of travelling by motor vehicle without their child strapped securely into a car seat, use of child restraints is currently not mandatory under the Canadian Aviation Regulations (CARs). According to the Regulations, children under the age of two may be held securely in the arms of an adult during flight. Nonetheless, Transport Canada highly recommends the use of an approved child restraint for all phases of flight, as such a system provides the greatest degree of protection for the infant or child and will help in unanticipated turbulence.

Types of child restraints and labelling requirements
There are a number of child restraint devices currently on the market; however, not all are permitted for use on board aircraft. An approved child restraint system is one that meets the Canadian Motor Vehicle Safety Standard (CMVSS) 213 or 213.1. To be accepted for use on board the aircraft, the restraint system must bear a Statement of Compliance Label indicating compliance with CMVSS 213 or 213.1.

Types of child restraint systems that may be accepted on aircraft include infant restraint systems, child restraint systems, convertible restraint systems and combination systems.

An infant restraint system is an aft-facing restraint system that is generally restricted to an occupant weight of less than 20 lbs. Weight restrictions are specified on the system and can vary from one system to another. Infant restraint systems are certified to CMVSS 213.1.

A child restraint system is a forward-facing restraint system that is generally restricted to an occupant weight of 20 to 40 lbs. However, some systems can accommodate occupants of greater weight. Weight restrictions are specified on the system and can vary from one system to another. Child restraint systems are certified to CMVSS 213.

A convertible restraint system is a restraint system that can be used as an aft-facing system for infants and as a forward-facing system for children. These restraint systems are certified to both CMVSS 213 and 213.1.

Certain manufacturers are also marketing a combination system, which is a combination of a child restraint system and booster cushion. When used as a child restraint system, the booster cushion will include an internal harness system. The internal harness system must be installed and all labelling requirements for child restraint systems must be met to be acceptable for use in an aircraft. When used as a booster cushion, the internal harness system is removed, and the device is therefore not approved for use in an aircraft. Combination systems are certified to CMVSS 213 and 1`213.2.

The CARES device
Child restraint systems are typically sold in the form of a car seat. However, Transport Canada recently accepted an alternative child restraint device called the Child Aviation Restraint System (CARES). Developed by AmSafe, CARES is a harness-type device that utilizes an aircraft passenger seat belt to secure a child’s upper torso against the aircraft seatback.

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CARES has been certified by the U.S. Federal Aviation Administration (FAA) and is intended for children ages one to four, weighing between 22 and 44 lbs and measuring 40 in. or less in height. The CARES device was examined by Transport Canada, and the test criteria was found to be acceptable for use on Canadian aircraft. This new restraint device weighs one pound, can be easily transported, and offers an alternative method of child restraint to passengers travelling with small children.

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(Images printed with permission from www.kidsflysafe.com/.)

Currently, Transport Canada permits the use of the CARES device for infants on Canadian aircraft through a global exemption and recommends that the CARES device be used within the limitations specified by the manufacturer on the device.

For more information on the CARES device, visit www.kidsflysafe.com/.

Child restraints and carry-on baggage requirements
It is important to note that Transport Canada does not consider a child restraint system, such as a car seat or the CARES device, to be carry-on baggage when it is carried on the aircraft as a means of restraining an occupant. However, if the device is not being used on board the aircraft, it is then considered carry-on baggage and must be stowed accordingly.

Additional information on child restraint systems can be found by visiting Transport Canada’s Aviation Advisory Circular Web site at www.tc.gc.ca/CivilAviation/commerce/circulars/AC0177.htm.

A look ahead…
As Transport Canada continues to respond to questions and concerns about the use of child restraints on aircraft, the message remains the same: a child restraint system provides the greatest degree of protection for an infant or child during all phases of flight.

The Society of Automotive Engineers International (SAE) Aerospace Division has been working hard in the area of aviation child restraint design, taking into account the challenges posed by the particular design and construction of aircraft seats. Likewise, manufacturers have developed various prototypes of aviation child restraints. At the present time, the accepted standard continues to be the CMVSS 213 and 213.1, although ongoing research indicates that this standard may not continue to be appropriate for aviation use in the future.

TCCA is encouraged by emerging technology in aviation child restraints and is hopeful that new aviation child restraint systems will soon be approved for use on all flights in Canada and abroad

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