InFO Information for Operators

U.S. Department InFO 15013

of Transportation DATE: 9/27/15

Federal Aviation

Administration Flight Standards Service

Washington, DC

http://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info

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.

Subject: Regulatory Requirements Regarding Accommodation of Child Restraint Systems

Purpose: This InFO cancels InFO 11007, clarifies regulations regarding accommodation of a Child 

Restraint System (CRS), and updates cross-references to certification requirements regarding the approval 

of materials, parts, processes and appliances. In addition, information is given regarding the requirement 

for Title 14 of the Code of Federal Regulations (14 CFR) part 121 air carriers to make available on their 

Web sites the width of the narrowest and the widest passenger seats in each class of service for each

make, model and series of airplane used in passenger-carrying operations.

Discussion: Per §§ 121.311 (b)(2)(i), 125.211(b)(2)(i), 135.128(a)(2)(i), no operator may prohibit a child 

(an individual who has not reached his or her 18th birthday) from using an approved CRS when a seat is 

purchased for the child, the child is accompanied by a parent or guardian and the child is within the 

weight limits for the CRS. If an approved CRS, for which a ticket has been purchased, does not fit in a 

particular seat on the aircraft, it is the responsibility of the aircraft operator to accommodate the CRS in 

another seat in the same class of service. The following are examples of design variations where 

accommodation is required. 

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 in the same class of 

service.

2) An aft-facing CRS that cannot 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 in the 

same class of service.

3) A harness-type CRS (approved under § 21.305(d) (2010 ed.) (i.e., CARES, Part No. 4082) or

approved under § 21.8(d)) with an upper strap that is not able to encircle some sleeper seats or 

very large first class seats can be moved to another seat that can accommodate the strap in the 

same class of service.

4) There are some aft-facing CRS that have a detachable base that may keep the CRS from fitting 

properly in the seat. The following visual cues will assist the passenger and the aircraft operator to 

determine if the detachable base is necessary.

Distributed by: AFS-200 OPR: AFS-220
a) If there is no belt path on the aft-facing CRS, then it must be used with the detachable base on 

aircraft. 

b) If there is a belt path on the aft-facing CRS, and the CRS is properly labeled, then it does not 

need to be used with the detachable base on aircraft. 

c) FMVSS-213 labeling standards do not require labeling on the detachable base.

Consistent with the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012, 

§ 121.311(k) requires air carriers conducting part 121 operations to make available on their Web sites the 

width of the narrowest and the widest passenger seats in each class of service for each airplane used in 

passenger-carrying operations. This rule facilitates the use of a CRS onboard an airplane and provides 

greater information to assist a caregiver to determine whether a particular CRS will fit in an airplane seat. 

“Class of service” is the most relevant break point for information disclosure as it remains the prevailing 

terminology used to distinguish seat products, including the seat size variations and amenities that are 

associated with those products. Under 14 CFR 250.1 the Department of Transportation (DOT) defines 

“class of service” to mean: seating in the same cabin class such as First, Business, or Economy class, or in 

the same seating zone if the carrier has more than one seating product in the same cabin (such as. 

Economy and Premium Economy class); or seats that are wider or have more legroom that are available at 

a higher cost to passengers. Further, because no certificate holder may prohibit a child from occupying a 

CRS if the child holds a ticket for an approved seat, the aircraft operator need only accommodate the CRS 

in another seat in the same class of service. 

An operator may have policies based on safe operating practices that establish certain seat locations for a 

passenger who uses a CRS on a specific aircraft. Even if a certain seat in another location in the same 

class of service can accommodate an approved CRS, an operator does not have to permit the CRS in that 

location if the operator’s policies disallow the CRS in that seat. However, prohibiting the use of a CRS (if 

a ticket has been purchased) when there are seats on the aircraft, in the same class of service where the 

CRS could be used safely is not consistent with the requirements stated in parts 121, 125 and 135. As an 

operator determines how best to meet the statutory requirement of § 121.311(k), it would be beneficial to 

the air carrier, and would help facilitate the use of a CRS onboard an airplane, if the air carrier only 

provides seat widths for seats that an air carrier allows for CRS use.

Recommended Action: Directors of safety, directors of operations, directors of marketing and customer 

service, training managers and crewmembers should understand regulations in parts 121, 125 and 135 

regarding the use of approved CRS and should revise their procedures, manuals, Web sites and training 

programs accordingly. 

Contact: Questions or comments regarding this InFO should be directed to the Policy Integration Branch, 

AFS-270, at 202-267-8166.

Distributed by: AFS-200 OPR: AFS-220