GAO-12-804R Delayed Baggage

United States Government Accountability Office

Washington, DC 20548

June 14, 2012

The Honorable John D. Rockefeller IV

Chairman

The Honorable Kay Bailey Hutchison

Ranking Member

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable John L. Mica

Chairman

The Honorable Nick J. Rahall II

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

Subject: Delayed-Baggage Trends and Options for Compensating Passengers

This letter formally transmits the enclosed briefing in response to Section 407 of the FAA 

Modernization and Reform Act of 2012,1

 1

Pub. L. No. 112-95. 126 Stat. 11, 87 (2012).

which directs the Comptroller General to (1) examine 

delays in the delivery of checked baggage to passengers of air carriers and (2) assess the 

options for and examine the impact of establishing minimum standards to compensate a 

passenger in the case of an unreasonable delay in the delivery of checked baggage. To conduct 

this work, we interviewed officials from the Department of Transportation (DOT) and 

representatives of airline and consumer organizations, analyzed DOT mishandled-baggage data 

for January 2004 through March 2012, and reviewed pertinent DOT regulations and proposed 

rules relating to delayed baggage. Our focus was limited to domestic air transportation. To 

assess the reliability of DOT’s mishandled-baggage data we interviewed officials in DOT’s 

Office of the Secretary and the Bureau of Transportation Statistics, reviewed DOT’s data 

collection and quality control procedures, and reviewed information collected from prior GAO 

reports. We determined that these data were sufficiently reliable for presenting the numbers of 

mishandled-baggage reports filed by passengers over the time period of our analysis. We 

conducted this performance audit from March 2012 through June 2012 in accordance with 

generally accepted government-auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit objectives.

 
Page 2 GAO-12-804R Delayed Baggage

In summary, we found that DOT’s data do not distinguish between delayed baggage and other 

types of mishandled baggage, such as those that are lost, damaged, or pilfered. DOT includes 

all of these types of occurrences in its definition of “mishandled baggage.” Using DOT’s data, 

we found that the number of mishandled-baggage reports2

We also describe three options (slides 9-12) for compensating passengers for delayed and 

other types of mishandled baggage and the impact of implementing new minimum 

compensation standards. The options are for DOT to (1) keep current regulations, which, 

among other things, require compensation for reasonable expenses that result because of delay 

in the delivery of baggage, (2) reimburse passengers for the checked baggage fee if the bag is 

delayed, or (3) implement compensation standards based on the length of delay. We note that 

implementing minimum compensation standards could provide transparency and consistency 

among the airlines, but would require an administrative structure and entail costs that are likely 

to be passed on to passengers. We are not making any recommendations for congressional 

consideration or agency action.

has decreased since 2008, when 

airlines first began charging for the first checked bag (see slide 6). There are a number of 

factors that could contribute to this decline in the number of mishandled-baggage reports, such 

as a decline in the number of bags checked and improved baggage handling processes.

However, because of limitations to DOT’s baggage data, an assessment of baggage delays—a 

subcategory of mishandled baggage—cannot be conducted. DOT has proposed a change to 

airline-reporting requirements designed to improve its ability to measure airline performance 

regarding mishandled bags, but the change would not distinguish among the types of 

mishandled baggage (lost, delayed, damaged, or pilfered).

DOT provided technical comments, which we incorporated as appropriate. As DOT suggested, 

we clarified that the scope of our work was limited to domestic air transportation and clarified the 

agency’s reason for including all types of mishandled baggage in a single category.

We are sending copies of this report to the appropriate congressional committees. We are also 

sending copies to the Secretary of Transportation. This report will also be available at no charge 

on our Web site at http://www.gao.gov. Should you or your staff have questions concerning this 

report, please contact me at (202) 512-2834 or dillinghamg@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the last page of this 

report. Key contributors to this report were H. Brandon Haller, Assistant Director; Martha Chow; 

Colin Fallon; Geoffrey Hamilton; and Jessica Wintfeld.

Gerald L. Dillingham, Ph.D.

Director

Physical Infrastructure Issues

Enclosure

 2

A “mishandled baggage” report is a report filed with a carrier by or on behalf of a passenger who claims loss, delay, 

damage, or pilferage of baggage. A mishandled-baggage report may represent one or more mishandled bags.
Page 3 GAO-12-804R Delayed Baggage

Enclosure I

Delayed Baggage Trends and 

Options for Compensating 

Passengers

Mandated by Section 407, 

FAA Modernization and Reform Act of 2012

(Pub. L. No.112-95)

For more information, contact Dr. Gerald Dillingham, dillinghamg@gao.gov Page 1
Page 4 GAO-12-804R Delayed Baggage

Mandate

Section 407, FAA Modernization and Reform Act of 2012 directs 

the Comptroller General of the United States to:

(1) examine delays in the delivery of checked baggage to 

passengers of air carriers; and 

(2) assess the options for and examine the impact of 

establishing minimum standards to compensate a 

passenger in the case of an unreasonable delay in the 

delivery of checked baggage. 

In conducting the study, the Comptroller General shall take 

into account the additional fees for checked baggage that are 

imposed by many air carriers and how the additional fees 

should improve an air carrier’s baggage performance.

Page 2
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Research Questions

• What is known about delays in the delivery of checked baggage 

to airline passengers?

• What are some options for establishing minimum standards to 

compensate passengers when there is an unreasonable delay 

in the delivery of checked bags? 

• What might be the impact of the implementation of minimum 

standards to compensate passengers in the case of 

unreasonable delays in the delivery of checked bags?

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Scope of the Work and Methods

• Analyzed Department of Transportation (DOT) data on 

mishandled baggage* (which includes delayed baggage) on 

domestic transportation for January 2004 through March 2012

• Reviewed pertinent DOT regulations and various rulemaking 

documents related to mishandled baggage

• Interviewed DOT officials and representatives of airline and 

consumer organizations

• Reviewed previous GAO products and relevant industry 

publications

Page 4

* Please see appendix for relevant definitions. 
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Data Do Not Distinguish Between Delayed 

Baggage and Other Types of Mishandling

• Current DOT regulations define mishandled baggage and require the 

larger U.S. airlines to report monthly the number of domestic 

mishandled-baggage reports filed and the number of enplaned 

passengers

• A mishandled-baggage report is a report filed with the airline by a 

passenger or on behalf of a passenger claiming loss, delay, 

damage, or pilferage of baggage 

• Using this information, DOT calculates a rate based on 

mishandled baggage reports per 1,000 passengers

• A proposed DOT rule seeks to require airlines to report the number 

of mishandled bags and the number of bags checked, allowing for a 

more precise performance measure

• The proposed rule would not, however, distinguish among the 

types of mishandled baggage (lost, delayed, damage, pilfered)

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Mishandled-Baggage Reports Have 

Declined, 2004-2012

Page 6

Mishandled-Baggage Reports Filed (January 2004—March 2012)
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Factors Contributing to the Decline in 

Mishandled-Baggage Reports 

• Improved on-time performance may result in fewer delays and 

transfer mishandling

• According to SITA,* improved processes and infrastructure 

mitigate the conditions that result in mishandled bags

• The decline in the number of bags checked results in fewer 

mishandlings

* Founded as the Société Internationale de Télécommunications Aéronautiques, 

SITA provides global integrated communications and IT services to the aviation 

industry

Page 7
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Data Necessary to Assess Delays in 

Delivery of Checked Baggage

• Because delayed bags are not reported to DOT as a separate 

category, assessing the delays in their delivery is not possible

• A comprehensive assessment of the delays in the delivery of 

checked baggage and their impact on consumers would require 

measures of airline performance and passenger inconvenience, 

including: 

• Number of delayed bags and number of claims made

• Delayed baggage rate per unit of checked baggage

• Cause and length of delay

• Amount of reimbursement, if applicable

• DOT currently does not collect these data because it believes that 

the required reporting of mishandled baggage reflects airlines’ 

performance sufficiently for consumer comparison

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Option 1: Keep current regulations

Current DOT regulations put in place by its 2011 Final Rule require 

airlines to adopt a Customer Service Plan that complies with specified 

minimum standards including:

• Making every reasonable effort to return mishandled baggage within 

24 hours

Current DOT regulations also require airlines to:

• Not limit their liability to less than $3,300 per passenger for domestic 

transportation

• Compensate passengers for reasonable expenses that result from 

delay in the delivery of baggage

• Inform consumers how to file a complaint, acknowledge receipt of 

complaint within 30 days, and send a substantive response within 60 

days of receipt

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Option 2: Reimburse checked baggage fee 

if baggage is delayed

In a 2010 Notice of Proposed Rulemaking, DOT solicited comments 

regarding (1) reimbursement of fees charged to transport a bag if that 

bag is lost or not timely delivered, and (2) the time when a bag should 

be considered not to have been delivered in a timely manner.

• Based on comments, in its 2011 Final Rule, DOT did not require 

airlines to reimburse checked baggage fees for delayed baggage

• DOT stated that transporting baggage is similar to the transport 

of passengers whose fare is not reimbursed if their flight is 

delayed. Although a delay in receiving baggage may be 

inconvenient, once the carrier delivers the bag the service for 

which the passenger paid has been performed. 

• DOT did require airlines to reimburse the checked baggage fee when 

a bag is lost

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Option 3: Implement compensation 

standards based on length of delay

• Standardized compensation system based on the length of time 

to deliver a bag that has been delayed

• DOT would need to address what constitutes an “unreasonable 

delay” which may include the cause of the delay and the 

circumstances of the traveler

• Defining a standard for which airlines should be responsible 

for reimbursement is complicated by the factors that can 

cause a delay, such as late passenger check-in, missed 

transfers, or mistagged baggage

• Such a classification is often contingent on factors in 

addition to length of delay (i.e., problem occurs on outbound 

versus homeward flight, purpose for travel, etc.)

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Impact of Implementing Minimum 

Compensation Standards 

• Could provide transparency and consistency among airlines

• Would require an administrative structure—the cost of which 

would likely be passed on to passengers

• Would require valid and reliable data about delays as a basis 

for developing compensation standards

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Appendix I: Definitions

• Mishandled baggage—As defined by DOT regulations, 

baggage that has been lost, delayed, damaged, or pilfered. 

Delayed baggage is not defined or tracked separately by DOT.

• Mishandled-baggage report—A report filed with an airline by or 

on behalf of a passenger who claims loss, delay, damage, or 

pilferage of baggage. According to DOT officials, a single report 

may represent one or more bags.

• Reporting airlines—U.S. airlines with at least 1 percent of total 

domestic scheduled-service passenger revenues. These 

carriers report data on enplaned passengers and mishandled 

baggage reports, among other things, to DOT.

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Page 14

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