# Presentation: 920526

## CHILD RESTRAINT IN VIRGIN ATLANTIC AIRWAYS

- Mary Gooding
-   Cabin Safety Officer

**Notes:**
Good ...... ladies and gentlemen.

First I would like to thank the National Transportation Safety Board (NTSB) for convening this meeting and for inviting me to speak on behalf Virgin Atlantic Airways - as the first, and I believe still the only airline to offer child restraint seats as part of our product and service to our customers.

## INTRODUCTION

- Brief history of Virgin Atlantic
- UK Child Restraint Regulations
- Influences on Virgin’s policy to provide child restraint seats
- Operational experiences
- Where to next?

**Notes:**
In order to put our experiences into context:

-  I’ll give you a brief history of Virgin Atlantic, 

- I’ll then cover the timescales of how child restraint regulations have evolved in the United Kingdom (UK),

- The effects these had on determining Virgin’s child-seat policy

- Our operational experience .........and finally

- Where do we go from here?

## BRIEF HISTORY OF VIRGIN ATLANTIC AIRWAYS 

- Privately owned, UK registered commercial airline
- Established in June 1984 using one B747-200
- Richard’s original values:                                                  “to make flying enjoyable again” by...
- being caring and honest
- providing value for money
- making it fun
- being innovative

**Notes:**
Virgin Atlantic is a privately owned, UK registered, commercial airline - and to coin an often used safety phrase - ”in the unlikely event” that you haven’t heard of the airline, I think you’ve probably heard of our daredevil owner Richard Branson.

He established Virgin Atlantic in May 1984 with one B747-200 operating on one route London Gatwick/Newark - because he wanted “to make flying enjoyable again”.  His values then, remain the Company’s values today, and although they are all as important as each other, we have to achieve then all innovatively - how else could we different and the best?

##   VIRGIN ATLANTIC’s HISTORY (cont.) 

- 10 in USA
- 					- Athens, Greece
- 							 -  3 in Far East
- 			- 3 in Caribbean
- 					- 2 in South Africa

-   VIRGIN ATLANTIC’s HISTORY (cont.)

- Operate from 3 UK airports to
-      19 destinations worldwide:

**Notes:**
Virgin has expanded rapidly in its 15.5 years of existence and we now fly from 3 UK airports to 19 destinations worldwide, on a fleet of 26 wide-bodied aircraft and one A320.

(OPTIONAL: 10 B742s, 6 B744s, 10 A340s  - 10 destinations in the USA, 3 in the Caribbean, 2 in South Africa, 3 in the Far East and to Athens, Greece)

## EVOLUTION OF U.K. CHILD RESTRAINT REGULATIONS

- 1984
- The only approved restraint was the supplemental loop for infants under 2 years.  Use recommended
- 1986
- Air Navigation Order (ANO) requires their use
- 1990
- CAA issues exemption to ANO permitting the optional use of car-type seats for same ages as loop belt
- 4 ‘acceptable’ UK manufactured seats listed
- All FAA approved seats also ‘acceptable’
- Use dependant on complying with Operational Conditions

**Notes:**
So there we were, a fledgling airline looking for a foothold in the market.   At the same time, UK child restraint regulations were evolving:

- When Virgin was established in 1984, the supplementary loop belt was recommended by the UK Civil Aviation Authority (CAA) as the restraint for infants from 0 up to less that 2 years old.

- In 1986, this recommendation became UK law and the use of the supplementary loop belt became a requirement.

- In 1990, the CAA issued a general exemption to the ANO permitting the optional use of car-type seats as a restraint for the same age group of infants and the ‘acceptable’ seats were listed. 

## CAA’s PRESS RELEASE MARCH 1990 

- Advises the public of the acceptance of car-type seats as an optional infant restraint.   It adds:
- “ ...airlines may consider that it is better if only one type of seat is used, with which cabin staff are totally familiar, and which is provided by the airline so that its condition is known to be satisfactory.”

**Notes:**
In its 1990 Press Release the CAA also issued the following statement:

“....airlines may consider that it is better if only one type of seat is used, with which cabin staff are totally familiar, and which is provided by the airline so that its condition is known to be satisfactory.”

As you will see later, this statement had a major influence on Virgin’s child restraint policy.

## EVOLUTION OF U.K. CHILD RESTRAINT REGULATIONS (cont)

- 1991
- This exemption was amended to permit their use for children 6 months to less than 3 years old (9 to 18kg - approx. 20 to 40lbs)
- 8 UK manufacturers’ seats now listed
- 1992
- Exemption amended again to approve optional use of CareChair and other purpose built child seats
- Acceptability Criteria introduced for all child seats

**Notes:**
- In 1991, as a result of continuing child restraint tests at Cranfield Impact Centre, this exemption was amended and the new  approved age limits for use of car-type seats  were “from 6 months to less than 3 years.”  It also now listed 8 UK-manufactured car-type seats which were acceptable.

- In 1992, the exemption was again amended to approve the optional use of the ‘Carechair’ and other purpose built child seats...

- However the Operational Conditions and Acceptability Criteria placed, in Virgin’s view, placed unrealistic responsibilities on the operators -  and I’ll cover some of these later.

## CURRENT CHILD RESTRAINTS REGULATIONS ON UK REGISTERED AIRLINES

- 0 to less than 2 years
-  supplemental loop only
- 6 months to less than 2 years
- supplemental loop _or_ exempted car-type seat _or_ approved CareChair
- 2 years to less than 3 years
- exempted car-type seat _or_ approved CareChair _or_ aircraft seat
- 3 years or more
- aircraft seat only

**Notes:**
 So since 1992, the regulations by which UK registered airlines have operated are:

- Infants from 0 to less than 2 years must use the supplemental loop only

- Those between 6 months but less than 2 years can choose either the supplemental loop or an exempted car-type seat or an approved purpose built seat like the CareChair.

- Toddlers from 2 years to less than 3 years have the option of either the exempted car-type seat or an approved purpose built seat (CareChair) or an aircraft seat.

- Those who are 3 years or more must sit in an aircraft seat only

## OPERATIONAL CONDITIONS (OCs)

- Airline responsible for ensuring proper installation
- Manufacturers’ instructions must be available *on board* to ensure proper use
- Commander responsible for ensuring ‘location, security and general condition is satisfactory.’ (ANO Art 37)

**Notes:**
Now to some of the Operational Conditions and the Acceptability Criteria which formed part of the exemptions, and the difficulties Virgin felt we would have with compliance:

-  The airline was made responsible for ensuring proper installation.

-  The manufacturer’s instructions had to be available on board to ensure proper use, and......

-  It made the Commander responsible for ensuring ‘location, security and general condition is satisfactory.’ (ANO Art 37)

## 
How could we ensure manufacturer’s instructions were always available for each seat? 
Would parents remember to travel with them?
Without these how could we ensure proper installation?
Even with them would they be understood?
Could be depend on the parent’s ability to fit the seat effectively?

- How could we ensure manufacturer’s instructions were always available for each seat?
- Would parents remember to travel with them?
- Without these how could we ensure proper installation?
- Even with them would they be understood?
- Could be depend on the parent’s ability to fit the seat effectively?

**Obstacles to compliance with Ocs****INSTALLATION INSTRUCTIONS:**

**Notes:**
With regards to the installation instructions:
With so many ‘acceptable’ seats, how could we ensure manufacturer’s instructions were always available for each type? 

- Would parents remember to travel with them?

- Without these how could we ensure proper installation?

- Even with them would they be understood?
(OPTIONAL: Have you ever tried to follow any manufacturer’s instructions?)

- Could we depend on the parent’s ability to fit the seat effectively, bearing in mind the airline’s legal responsibility for its proper installation?

## Obstacles to compliance with OCs (cont)ENSURING SATISFACTORY CONDITION

- How could the commander (or his rep) ensure the satisfactory condition of the seat?
- Many car-seats are passed on, the current owner may not even be aware they are damaged/unsafe.
- Time required to conduct inspection could result in delays to departure schedules

**Notes:**
How could the Commander ensure the satisfactory condition of the seat?

- Many car-seats are passed on, the current owner may not even be aware they are damaged/unsafe.  This increases the need to check their condition.

- The time required to conduct inspections could result in delays to departure schedules.

## ACCEPTABILITY CRITERIA

- Where seat has a separate shell and under-structure, they must be securely attached to each other
- Neither should show any obvious signs of having sustained damage
- Harness must be a minimum of 1 inch wide
- Any lift-type adjustors must require a positive angular lift to operate
- The harness release device must not be unreasonably easy to release by the child

**Notes:**
Furthermore, the Acceptability Criteria required checks to ensure that:

- Where the seat has a separate shell and under-structure, they must be securely attached to each other

- Neither should show any obvious signs of having sustained damage

- The harness must be a minimum of 1 inch wide

- Any lift-type adjustors must require a positive angular lift to operate

- The harness release device must not be unreasonably easy to release by the child...., and they go on and on!

## Obstacles to compliance with Acceptability Criteria

- Who would conduct the checks required?
- Check-in?
- Delay in processing customers =                 delay in on time departures
- Cabin crew?
- Too late in the process. Seat becomes a cabin baggage issue if it doesn’t meet the criteria

**Notes:**
With the Acceptability Criteria in mind we asked.....

Who would conduct the checks required?

- Check-in staff? 
Any delay in processing customers could cause a delay in on-time departures

The cabin crew? 
They’re too late in the process.  If, for whatever reason, the car-seat doesn’t meet the criteria, in addition to the annoyance this causes the customer, the car-seat also becomes a cabin baggage issue. 

## VIRGIN’s TESTING OF ACHIEVABILITY OF EFFECTIVE INSTALLATION OF CHILD SEATS Conducted in June 1990

- The 4 originally acceptable UK manufactured car-type seats
- The prototype of Aviation Furnishings International’s (AFI) CareChair (still seeking CAA approval)
- Installed in 3 classes of seats on our aircraft
- Conducted by our Engineering and SEP Training depts.

**Notes:**
Bearing in mind our perceived difficulty in fulfilling the Operational Conditions and meeting the Acceptability Criteria, Virgin decided in 1990 to test the installation of the 4 then acceptable UK manufactured car-type seats and the prototype of the CareChair, which was at this stage still seeking CAA approval.

We installed each of the 5 seats in the 3 classes of seat on our aircraft.

The tests were conducted by the Safety and Emergency Procedures Training Department, who represented the end user, and our Engineering Department for their technical expertise.

## THE ‘CARECHAIR’

- Designed specifically for use in aircraft
- Made of aircraft approved materials
- Fully adjustable five-point harness
- Folds for stowage
- Weighs 13 lbs - lighter than other 4 models tested
- Tested to withstand forward crash load of 16g (subject to host seat)

**Notes:**
Before moving on to the test results, I’ll briefly describe the CareChair.

-  It was designed specifically for use in aircraft, and is .... 

-  Made of aircraft approved materials.

-  Has a fully adjustable five-point harness, and ... 

-  Folds for easy stowage.

-  It weighs 13 lbs - which is lighter than the other 4 models tested, and had been ...

- Tested to withstand forward crash load of 16g (subject to host seat)

## INSTALLATION TEST RESULTS

- Fair amount of forward movement of one of the  car seats
- Difficulty in operating the a/c’s seatbelt buckle as it was fouled by the child-seat’s back
- Front bar of another car seat rested too close to the edge of the a/c seat’s cushion, forward loading resulted in child seat toppling off host seat
- A/c’s seatbelt buckle rested on child seat’s frame - not recommended by manufacturer
- Installation and stowage of Carechair easier than any of the other 4 seats

**Notes:**
The results of these tests showed:

- There was a fair amount of forward movement of one of the car seats, and ...

- It was difficult to operate the a/c’s seatbelt buckle, as it was fouled by the child-seat’s back.

-  The front bar of another car seat rested too close to the edge of the a/c’s seat cushion which resulted in it toppling off the host seat when forward loading was applied.. 

- The a/c’s seatbelt buckle rested on child seat’s frame - something manufacturers warned against, and ...

- The installation and stowage of the Carechair were easier than any of the other 4 seats

## INFLUENCES ON VIRGIN’s POLICY TO PROVIDE ‘CARECHAIRs’

- UK Child Restraint Regulations
- Results of seat installations trials
- Ability to comply with Operational Conditions for car-type seat installation and use
- Ability to comply with Acceptance Criteria
- Customer care influences:
- Effects of  last minute refusal to accept their car seat
- Effects of policy not to offer a service which other airlines did.

**Notes:**
With the UK regulations and these test results in mind, as well as our concern about our ability to comply with the Operational Conditions and the Acceptability Criteria for customers wanting to use their own car-type seats, Virgin then looked at what other factors could influence our child seat policy.  

Of course we had to consider what effect any policy we made would have on our customers.

How would they re-act when faced with a last minute refusal to accept their car-type seat because we felt it didn’t comply with the requirements?

What would their reactions be to a policy of not accepting any car-type seats? Would they understand we felt this was the best way we could ensure their child’s safety, or would they just think we were being difficult, since all other airlines accepted them?

## INFLUENCES ON VIRGIN’s POLICY TO PROVIDE CARECHAIRs (cont.)

- Commercial concerns:
- Possible operational delays resulting from  time spent to check acceptability criteria
- Unhappy customers due to refusal to allow use of their ‘acceptable’ seat
- Commercial problems normally mean lost revenue
- UK Civil Aviation Authority’s (CAA) press release Company’s value to be innovative =
- HOW CAN WE BE DIFFERENT AND DO THE BEST FOR OUR CUSTOMERS AND OURSELVES*?*

**Notes:**
Of course there were also commercial concerns:
- These included possible operational delays resulting from the time needed to check the Acceptability Criteria.

- Unhappy customers due to our refusal to allow use of their ‘acceptable’ seat.  Would they book with us?

As you know...  Commercial problems normally mean lost revenue and often focus the mind!

In addition, the CAA’s 1990 Press Release made us  consider one of our Company’s main values - to be innovative.

HOW CAN WE BE DIFFERENT AND DO THE BEST FOR OUR CUSTOMERS AND OURSELVES?

## EVOLUTION OF VIRGIN’s POLICY TO PROVIDE ‘CARECHAIRS’

- Company policy to refuse optional acceptance of car-type seats on our a/c as these tests showed our non-compliance with Operational Conditions.
- Virgin actively assisted AFI to produce the CareChair as it had performed best in the trials
- By October 1990 the CareChair had passed the required testings at Cranfield Impact Centre

**Notes:**
As this stage, July 1990, and as a direct result of our seat trials, Virgin decided that we would refuse the optional acceptance of car-type seats on our aircraft.

As the CareChair had performed so well in the tests, the Company also decided to actively assist its manufacturer - Aviation Furnishings International (AFI).

In October 1990, the CareChair passed the required testings at Cranfield impact Centre, and.......

## EVOLUTION OF VIRGIN’s POLICY TO PROVIDE ‘CARECHAIRS’ (cont)

- January 1992 - CAA granted approval for the CareChair’s use
- Virgin ordered 30 CareChairs - original cost  about £250 (US$400) each
- Fitted on 16th March 1992
- 3 to be fitted on each B747 (x 8) + spares
- Other fleets?
- A340s carry 2, A320 carries 1

**Notes:**
,,,, In January 1992 the CAA granted approval for the CareChair’s use.

As a result, Virgin ordered 30 at an original cost of about £250 (US$400) each
-  They were first fitted16th March, 1992, 3 on each our by then 8 B747s, plus spares

- When the other aircraft-types joined our fleet in late 1993, the A340s were fitted with 2 and the A320 carries 1.

## OPERATIONAL PROCEDURES

- Booked through Reservations
- Fares: 55% - 75%
- Cabin crew advised at check-in
- Cabin crew fit on boarding a/c
- If not booked, offered at check-in or on boarding.

**Notes:**
Our operational procedures require the CareChair to be booked through Reservations. 

The fares range from 55% to 75%, depending on destination/fare

It is then included on the ‘specials list’ which contains notification of customers needing special care, whether this is because of their age (Unmins), a medical condition, or they are important!

After boarding the a/c, the cabin crew will fit the CareChair to the assigned seat.

If the CareChair was not booked, it will be offered at check-in, especially if the customer has turned up with their own car seat, as this usually means they paid for a seat for the infant.

Even after boarding, as long as an empty seat next to the parent is available, the crew can use their discretion to offer it without charge.

## OPERATIONAL DIFFICULTIES

- Most airlines accept car-type seats:
- Don’t know:
- Virgin do not accept car-type seats
- Our CareChair is bookable
- Don’t want to check their seat as baggage:
- Want to use it as a cot
- Becomes a cabin baggage issue
- OC doesn’t allow its use inflight
- Car-seat needed at destination

**Notes:**
I wouldn’t be honest if I told you it  all works without a hitch; of course we do run into some operational difficulties.   As most airlines accept car-type seats, customers expect that Virgin will as well, so unless the Reservations agent advises them at booking, the customer probably won’t be aware of our policy or that we provide our own child seat.

This can also cause a problem at check-in because many parents don’t want to check their car-seat as they prefer to use it as a cot inflight and feel that the baby will notice the difference!  It then becomes a cabin baggage issue. - Have you ever tried to stow a car-seat?

Moreover, one of the Operational Conditions requires the child seat to remain attached to the host seat at all times.  Therefore removing the CareChair inflight to allow the parents to use their own seat, is not an option.

Additionally, whether they have booked our child seat or not, many parents  need their car-seat at their destination. To assist them further, we provide a protective cover and check it as hold baggage at no extra cost, as we do not include it in their baggage allowance.

## OPERATIONAL DIFFICULTIES (cont.)

- Parent’s first impression of the CareChair can be disappointing:
- Majority of customers have only car seats as reference for ‘looks’
- Concern that the child’s not ‘cocooned’
- Perceived comfort issue for younger infants - can’t lie down
- Some would prefer to hold their infant

**Notes:**
Another difficulty we sometimes have is parents’ perception of what the CareChair should look like, since their only term of reference is the car-seat.  As a result some customers are disappointed when they first see the CareChair installed. They are often concerned because it doesn’t appear to cocoon the child. 

Furthermore, because the harness holds the child in the sitting position, some parents also perceive this as a comfort problem for smaller infants, as they can’t lie down.

In fact we’ve had parents who would rather hold their child on their lap, and I think this shows us that a great deal of effort must be made to educate the public effectively on child restraints.  

Thankfully our crew usually succeed in convincing the customer of the safer option!

## ENGINEERING LOGISTICS

- Procedures for cleaning
- Maintenance checks
- CareChair requires ‘fit testing’ each time any of the 3 types of a/c seats are changed.

**Notes:**
From the Engineering side, they’ve had to produce procedures to ensure the CareChairs remain hygienic and are maintained in good working condition.

In addition, whenever Virgin decides to change either of our three classes of aircraft seat, we need to conduct ‘fit testing’ to ensure we retain our capability to install the CareChair effectively.

## WHERE TO NEXT?

- New child restraint seat ?

**Notes:**
So where do Virgin go from here?

Since 1992 when we started fitting the CareChair to each a/c, the design of child seats has advanced.  

Although the CareChair continues to serve us adequately, we are currently looking at other seats to see if we can improve the product and service we offer.

## WHERE TO NEXT? (cont.)

- Restraint for disabled children

- Burnett Body Support

**Notes:**
In addition, we continue to show our sincere regard to the importance of child restraint, by again working closely with designers to help develop and provide adequate restraint for those children who, because of a disability are unable to be secured in the normal manner.  Here are two such restraints:

The Burnett Body Support is designed to provide spinal and posture support particularly for sufferers of mutliple sclerosis and cerebral palsy. Vacuum technology enables the support to mould to and hold the user in their desired position.

The MERU seat is designed by a British charitable organisation - the Medical Engineering Research Unit - who are dedicated to applying their engineering skills for the benefit of disabled children.

Both seats are of course secured to the aircraft seat

## Slide 27

**Notes:**
Ladies and gentleman, the motor industry has for many years successfully used safety as a major selling point and educated us at the same time - we all know about airbags, side impact bars and ABS brakes. 

Parents no longer question the need to buy a car seat - it’s on their list of necessities along with diapers and formula.  

Yet the airline industry continues to run shy of mentioning anything to do with safety.  Even when we haven’t got a choice, we still hide behind that well known phrase I used at the beginning of my presentation “in the unlikely event”.

## If they can’t be held in turbulence, how can they be held during an impact?

**Notes:**
I’m proud that Virgin Atlantic was once the only airline to provide defibrillators and the first airline to provide child seats, and I do hope that in the same way many airlines have now followed our defibrillator example, they will also follow our child seat example. 
I realise that it usually comes down to convincing the ‘money men’, and until we can get the airlines’ financial directors to see safety in the same light as the motor industry appears to do, I suggest you try justifying the provision of approved child restraints as a product improvement.
Additionally, I hope the regulators will assist us in our efforts. We keep saying that  we don’t compete when it comes to safety, so let us all insist on and somehow provide the same level of safety for all our customers, no matter what age  - and educate them along the way.

## Thank you!

**Notes:**
Thank you ladies and gentleman for listening. 

I will be available to answer your questions during the discussion period/s.