U.S. Department

of Transportation

Federal Aviation

Administration

Advisory

Circular

Subject: Use of Child Restraint Systems on 

Aircraft

Date: 9/24/15 AC No: 120-87C

Initiated by: AFS-200 Change:

1. PURPOSE. This advisory circular (AC) provides information and practices regarding the 

use of child restraint systems (CRS) on aircraft. The Federal Aviation Administration (FAA) 

intends for operators to use this as a resource during the development, implementation, and 

revision of an air carrier’s standard operating procedures (SOP), Web sites and training programs 

regarding the use of CRSs.

a. FAA Initiatives. This AC is one of several FAA initiatives designed to address safety 

concerns of the National Transportation Safety Board (NTSB). It is a part of the FAA’s ongoing 

commitment to educate and inform aircraft operators, crewmembers, and airline passengers 

regarding the use of CRSs on aircraft in order to encourage and increase the use of approved 

CRSs. For more information, refer to the following FAA Web site: 

http://www.faa.gov/passengers/fly_children/.

b. Regulatory Requirements. In addition, this AC provides information to air carriers 

conducting Title 14 of the Code of Federal Regulations (14 CFR) part 121 operations about the 

requirement to make available on their Web sites the width of the narrowest and widest 

passenger seats in each class of service for each make, model, and series (M/M/S) of airplane 

used in passenger-carrying operations. If an air carrier does not have a Web site, the air carrier is 

not required to establish a Web site in order to comply with this regulation.

2. CANCELLATION. AC 120-87B, Use of Child Restraint Systems on Aircraft, dated 

September 17, 2010, is cancelled.

3. RELATED REGULATIONS. Title 14 CFR part 21, § 21.8; part 91, §§ 91.107 and 

91.1035; part 121, §§ 121.311 and 121.583; part 125, § 125.211; and part 135, § 135.128.

4. RELATED FAA GUIDANCE (CURRENT EDITIONS). This AC provides information 

and suggested practices regarding the use of CRSs on aircraft. This AC also supplements and 

contains information previously published in the documents listed below.

• AC 91-62A, Use of Child Seats in Aircraft;

• Information for Operators (InFO) 11007, Regulatory Requirements Regarding 

Accommodation of Child Restraint Systems – Update;

• FAA Office of Aerospace Medicine Technical Report FAA-AM-78-12, Children 

Restraint Systems for Civil Aircraft;
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• FAA Office of Aerospace Medicine Technical Report FAA-AM-94-19, The Performance 

of Child Restraint Devices in Transport Airplane Passenger Seats; and

• Order 8900.1 Volume 3, Chapter 33, Section 6, Operations—Cabin Safety.

5. AUDIENCE. Air carrier personnel involved in the development of aircraft SOP and training 

programs, as well as crewmembers, engineers, Web site designers, and others involved in flight 

operations under part 121, should be familiar with the contents of this AC. This AC may also be 

valuable to others associated with operations under parts 91, 125, and 135.

6. HISTORY OF CRS REQUIREMENTS AND APPROVAL STANDARDS.

a. Civil Air Regulation (CAR) Section 40.174. The permissive language that does not 

require children under the age of 2 to be restrained can be found in the 1964 CAR, § 40.174, 

which stated in part that “A seat and an individual safety belt are required for each passenger and 

crew member excluding infants, who are in other than a recumbent position.”

b. Federal Motor Vehicle Safety Standard (FMVSS) No. 213. In 1982, the Department of 

Transportation (DOT) had two standards for CRSs. CRSs for use in motor vehicles were 

required to be certified as complying with the requirements of FMVSS No. 213. CRS for use in 

aircraft were required to be certified as complying with the requirements of FAA’s Technical 

Standard Order (TSO)-C100c, Aviation Child Safety Device (ACSD). In early 1983, the NTSB 

considered the safety problems posed for young children traveling in motor vehicles and aircraft 

and urged that a variety of actions be taken to promote increased use of CRSs. One of those 

recommendations was that DOT simplify its two different standards and set forth requirements 

for CRSs by combining the standards. The FAA and the National Highway Traffic Safety 

Administration (NHTSA) agreed upon a single government performance standard that would 

satisfy both aviation and highway safety requirements for CRSs. The agencies proposed NHTSA 

as the sole agency responsible for administering the new FMVSS No. 213, which would be 

applicable to CRSs designed for use in motor vehicles and CRSs designed for use in aircraft 

(Title 49 of the Code of Federal Regulations (49 CFR) part 571, § 571.213).

c. United Nations (UN) Standards or Approval by a Foreign Government. On October 

15, 1992, the FAA broadened the categories of CRSs allowed to be used on aircraft to include 

CRSs meeting the standards of the UN or approved by a foreign government (57 Federal 

Register (FR) 42662).

d. FAA Approval Through a Type Certificate (TC), Supplemental Type Certificate 

(STC) or TSO. On August 26, 2005, the FAA once again broadened the categories of CRSs that 

aircraft operators may furnish for use on aircraft to include CRSs approved by the FAA through 

TC, STC, or TSO (70 FR 50902).

e. FAA Approval Through § 21.305(d) (2010 ed.) (i.e., AmSafe Child Aviation 

Restraint System (CARES), Part No. 4082), 14 CFR § 21.8(d), or TSO-C100b, or a 

Later Version. On July 14, 2006, the FAA further broadened the categories of CRSs that both 

passengers and aircraft operators may furnish and use on aircraft to include CRSs approved 

under § 21.305(d) or TSO-C100b, Child Restraint System (CRS), or a later version 

(71 FR 40003). On October 16, 2009, the FAA published a final rule entitled, Production and 
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Airworthiness Approvals, Part Marking, and Miscellaneous Amendments (74 FR 53368). In this

final rule, the FAA amended its certification procedures and identification requirements for 

aeronautical products and articles. As a result of this amendment, § 21.305 was redesignated as 

§ 21.8, effective April 14, 2010. On May 20, 2014, the FAA amended the provision in § 121.311 

relating to the label required for FAA-approved CRSs onboard aircraft to reflect this 

redesignation of § 21.305 to § 21.8 (refer to 79 FR 28811). The May 20, 2014 amendment also 

corrected minor technical errors in the codified regulations. The technical amendment ensures 

that CRSs previously approved under § 21.305(d) (2010 ed.) (i.e., CARES, Part No. 4082) can 

continue to be used and CRSs approved under § 21.8(d) may also be used.

f. TSO-C100c. Additionally, the FAA published TSO-C100c, effective April 6, 2012. 

Therefore, approvals under § 21.8(d) would use TSO-C100c as the basis for approval.

7. FAA APPROVAL PROCESSES USED FOR APPROVED CRSs ON AIRCRAFT. The 

TC, STC, TSO, § 21.305(d) (2010 ed.), and § 21.8(d) approval processes address differences in 

CRS design and performance as follows:

a. TC Process. A TC is an FAA design approval in which an applicant applies for, and if 

approved, receives a TC for a product or a major design change to a product. A product is 

defined as an aircraft, an aircraft engine, or an aircraft propeller. The TC process is appropriate if 

a CRS is incorporated into the original design of the aircraft.

b. STC Process. The STC process allows a specific CRS meeting FAA-established testing 

and evaluation criteria to be used on a specific type of aircraft.

(1) Under the STC process, a CRS manufacturer would submit an application for his or 

her product to be used on specific type of aircraft. This allows the FAA to deal with novel and 

unusual design features associated with any new type of CRS not addressed by current 

regulations and safety standards. The STC process is appropriate for a CRS not meeting FMVSS 

No. 213.

(2) When the FAA considers granting an STC for a CRS, it may publish proposed special 

conditions in the FR for notice and comment. These proposed special conditions discuss the 

additional safety standards the FAA deems necessary for the CRS to comply with existing 

regulations. It also discusses the required performance of the CRS and the capability of the CRS 

to be installed and used without creating safety concerns. Refer to 70 FR 18271, for an example 

of special conditions that were part of an STC which the FAA granted to a manufacturer for a 

CRS.

c. TSO Process.

(1) A TSO is a minimum performance standard issued by the FAA for specified 

materials, parts, processes, and appliances used on aircraft. These minimum performance 

standards must be used for an applicant to receive TSO authorization or a letter of design 

approval (LODA) in the case of manufacturers located outside the United States. TSO-C100c 

contains minimum performance standards for the testing and evaluation of CRS. The minimum 

performance standard references Society of Automotive Engineers (SAE) Aerospace Standard 

(AS) 5276/1. It also requires the manufacturer to provide operating instructions, equipment 
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limitations, installation procedures and limitations, as well as instructions for continued 

airworthiness (ICA) and maintenance of the CRS.

(2) A TSO is a minimum performance standard similar to FMVSS No. 213. However, 

TSO-C100c provides more realistic CRS testing regarding performance in an aviation 

environment. The TSO process is appropriate if a CRS is similar in design to a CRS meeting 

FMVSS No. 213 requirements, as well as designed to meet the specific aviation performance 

standards contained in TSO-C100c.

d. Section 21.8(d) Process.

(1) Under the FAA’s certification rules, § 21.8(d) allows a material, part, process, or 

appliance to be approved in any manner approved by the Administrator. One of the reasons that 

the FAA included this provision in § 21.8 was to address the unique challenges presented by 

certain types of equipment for use on aircraft.

(2) When approving a CRS under the provisions of § 21.8(d), the FAA must ensure the 

CRS meets an equivalent level of safety (ELOS) to other approval processes. For a CRS, the 

FAA’s technical experts look at the benchmark (current edition of TSO-C100, Child Restraint 

Systems) and identify safety-critical features. The technical experts ensure that each of these 

features meets an ELOS adequately. This ensures a CRS approved by the FAA under § 21.8(d) 

will meet a high level of safety regarding testing, quality, and performance standards.

8. AVIATION CHILD SAFETY DEVICE (ACSD).

a. Avoiding Consumer Confusion. The FAA recognizes that the term “child restraint 

system” was originally used to refer to child restraints meeting the requirements of FMVSS No. 

213 and designed to perform effectively in motor vehicles. However, in recent rulemakings, the 

FAA uses the term “child restraint system” to describe any approved seat or device used to 

restrain children on aircraft regardless of whether or not it complies with the requirements of 

FMVSS No. 213. To reduce consumer confusion between a CRS meeting the requirements of 

FMVSS No. 213 (safe for use in motor vehicles) and a CRS designed only for use in aircraft (not 

safe for use in motor vehicles), the FAA has introduced a new term referring to a CRS only 

approved for aviation use. The FAA will call these aviation-only restraints an ACSD. 

Regulations regarding the use of a CRS in aircraft also apply to an ACSD. Figure 1 is an 

example of an ACSD (also shown in paragraph 13).
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FIGURE 1. EXAMPLE OF A CRS (ACSD)

b. Warning Label. An ACSD only meeting the aviation performance standards contained 

in TSO-C100c previously approved under § 21.305(d) (2010 ed.), or meeting the aviation 

performance standards contained in TSO-C100c and approved under § 21.8(d) is not safe for use 

in a motor vehicle. The FAA worked closely with NHTSA to ensure that labeling on an ACSD 

clearly illustrates that an ACSD is not safe for use in motor vehicles. The FAA also plans to 

require a similar warning label on ACSDs approved by the FAA through the STC process.

FIGURE 2. REQUIRED WARNING LABEL FOR AVIATION CHILD SAFETY 

DEVICES WITHOUT FMVSS NO. 213 APPROVAL

c. Consumer Education. The FAA is taking steps to educate consumers regarding the 

difference between devices safe for use in both motor vehicles and aircraft versus those safe only 

for use in aircraft. The FAA revised the information on its Web site for passengers traveling with 

children (http://www.faa.gov/passengers/fly_children/), and put additional educational material 

on the site to remind people that ACSDs are not safe for use in motor vehicles. The FAA also 

encourages airline personnel, especially flight attendants (F/A), to take advantage of 

opportunities to educate parents and guardians who use ACSDs on aircraft regarding the 

differences between those “aviation only” ACSDs and devices that can be used safely in both 

aircraft and motor vehicles.

NOTE: Unless indicated otherwise, any information regarding CRSs and 

pertinent regulations also apply to ACSDs.
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9. LABELING ON A CRS APPROVED FOR USE DURING GROUND MOVEMENT, 

TAKEOFF, AND LANDING. Current operating rules in parts 91, 121, 125, and 135 require 

that a CRS used on aircraft during ground movement, takeoff, and landing meet one of the 

following labeling or marking requirements:

a. Required Labels. The CRS must bear two labels. However, typically the text for these 

two required labels is merged onto one label. The labeling must include the text “This child 

restraint system conforms to all applicable Federal Motor Vehicle Safety Standards” and 

“This Restraint is Certified for Use in Motor Vehicles and Aircraft,” in red lettering. Figure 3 is 

an example of this required labeling.

FIGURE 3. EXAMPLE OF REQUIRED LABELING

b. Approval Labels. 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 UN. 

Figure 4 is an example of the required labeling for a CRS manufactured under the standards of 

the UN (the “E” is consistently used in the label, but the number to the right of the “E” can 

change because it is the distinguishing number of the country that has granted approval).

FIGURE 4. EXAMPLE OF THE REQUIRED LABELING FOR A CRS 

MANUFACTURED UNDER UNITED NATIONS (UN) STANDARDS

c. FAA Approval Label. The CRS must bear a label or markings showing FAA approval 

through an STC. Figure 5 is an example of this required labeling.
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FIGURE 5. EXAMPLE OF REQUIRED LABELING FOR

CRS APPROVED UNDER AN STC

d. TSO Label. A CRS approved under the current version of TSO-C100 must be 

permanently and legibly marked “TSO-C100” and must include the TSO version under which it 

was approved. For instance, a CRS approved under TSO-C100c must be permanently and legibly 

marked “TSO-C100c.”

e. Label Indicating Approval Under § 21.305(d) (2010 ed.). The CRS must be clearly 

marked showing FAA approval under § 21.305(d) and bear the label “FAA Approved in 

Accordance with 14 CFR § 21.305(d).”

FIGURE 6. EXAMPLE OF REQUIRED LABELING FOR CRS APPROVED UNDER 

14 CFR PART 21, § 21.305(d)

f. Label Indicating Approval Under § 21.8(d). The child restraint device manufactured 

by AmSafe, Inc. (CARES, Part No. 4082) and approved by the FAA in accordance with § 21.8 is 

the only device that may bear a label or markings showing FAA approval in accordance with 

§ 21.8. Figure 7 is an example of an appropriate label for this device.

FIGURE 7. EXAMPLE OF REQUIRED LABELING FOR CRS APPROVED UNDER 

14 CFR PART 21, § 21.8(d)
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10. REGULATORY REQUIREMENTS REGARDING THE USE OF CRSs ON 

AIRCRAFT.

a. Children Under the Age of Two. Under the provisions in parts 121, 125, and 135, 

during takeoff, landing, and movement on the surface, each person on board shall occupy an 

approved seat or berth with a separate seatbelt properly secured about him/her. However, a 

person who has not reached his/her second birthday may be held by an adult occupying a seat or 

berth. During takeoff, landing, and movement on the surface, a child under the age of two may 

be held in an adult’s lap or be placed in a regular passenger seat and use a standard seatbelt.

b. Proper Use of CRS. If a child occupies a CRS, a parent/guardian must accompany the 

child, and the aircraft operator must comply with the requirements that the child is properly 

secured in the CRS, the CRS is properly secured in a forward-facing seat, the child does not 

exceed the weight limits of the CRS, and the CRS is approved and has the proper labels or 

markings.

c. CRS Restrictions. No aircraft operator may permit a child to occupy a booster-type, 

vest-type, harness-type, or lap-held CRS during takeoff, landing, and movement on the surface, 

except when the CRS has been approved by the FAA through a TC, STC, TSO, under 

§ 21.305(d) (2010 ed.), or under § 21.8(d). Booster-type, vest-type, and harness-type CRSs 

approved by the FAA through a TC, STC, TSO, under § 21.305(d) (2010 ed.), or under 

§ 21.8(d), may be used during all phases of flight.

d. Regulations. Under the provisions in parts 121, 125, and 135, no certificate holder may 

prohibit a child from using an approved CRS when the parent/guardian purchases a ticket for the 

child. Certificate holders are encouraged to allow the use of empty seats to accommodate CRS; 

however, they are not required to allow non-ticketed children to occupy empty passenger seats, 

even if the child uses a CRS.

e. Approved CRSs. The regulations allow aircraft operators to provide approved CRSs for 

use.

f. Operators Prohibiting CRS Use. 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 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.
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(3) A harness type CRS (approved under § 21.305(d) (2010 ed.) (i.e., CARES, 

Part No. 4082) or under § 21.8(d)) with an upper strap unable 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.

NOTE: An aircraft operator may have policies, based on safe operating 

practices, that establish certain seat locations for passengers who use a CRS 

on a specific aircraft. 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 in parts 121, 125, and 135.

11. SEAT DIMENSION DISCLOSURE. Consistent with the 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.

a. Class of Service. “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. The 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 (e.g., Economy and Premium Economy class); or seats that are wider or have more 

legroom that are available at a higher cost to passengers. Because no certificate holder may 

prohibit a child from occupying a CRS if the child holds a ticket for an approved seat, the agency 

has stated that the aircraft operator need only accommodate the CRS in another seat in the same 

class of service.

b. Measurement of Seat Width. Section 121.311 includes a definition of seat width 

applicable to seat dimension disclosure requirements. The definition specifies that seat width is 

the distance between the inside of the seat armrests.

c. Accommodation of a CRS. 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 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 part 121. As an operator determines how best to meet the 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.

d. Effective Practices Regarding Air Carrier Information. In addition to the seat width 

information required by § 121.311, the FAA encourages air carriers to include information on 
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their Web sites about their operational policies and limitations regarding the placement of CRS 

in specific seats or locations on their aircraft. For example, if an air carrier prohibits a CRS in 

aisle seats, it would be beneficial to list this on the air carrier’s Web site because it would 

provide greater information to a caretaker when choosing assigned seats and determining 

whether a particular CRS will fit in an airplane seat.

12. WORN OR UNREADABLE LABELS.

a. Regulatory Requirement. When an approved CRS is labeled or marked by the 

manufacturer, it certifies the CRS meets a set of safety standards (FMVSS No. 213, the standards 

of a foreign government, the standards of the UN, or approval by the FAA through a TC, STC, 

TSO, or under § 21.305(d) (2010 ed.) or § 21.8(d)). Current operating rules require the CRS used 

on an aircraft during ground movement, takeoff, and landing bear labels or markings to indicate 

to the aircraft operator that the CRS meets safety standards.

b. CRS with a Worn or Unreadable Labels. 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, as these booklets contain pictures or 

illustrations of the CRS and information that the CRS meets FMVSS No. 213.

13. TYPES OF CRSs MEETING THE CRITERIA OF FMVSS NO. 213, STANDARDS 

OF A FOREIGN GOVERNMENT, OR STANDARDS OF THE UN. Basic design features 

for the majority of approved CRSs for use on aircraft have remained fairly constant, although 

some changes and innovations in the design of CRSs have occurred as a result of FAA approval 

of CRSs through a TC, STC, TSO, or under § 21.305(d) (2010 ed.) or § 21.8(d). An aircraft 

operator’s personnel, specifically F/As, should be aware of the following items pertaining to a 

CRS meeting the criteria of FMVSS No. 213, the standards of a foreign government, or the UN. 

The criteria include:

• The CRS should have a solid back and seat,

• The CRS should have internal restraint straps installed to securely hold the child in the 

CRS, and

• The CRS must have a label showing approval for aviation use.
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FIGURE 8. EXAMPLE OF A FORWARD-FACING CRS WITH INTERNAL HARNESS

FIGURE 9. EXAMPLE OF AN AFT-FACING CRS WITH INTERNAL HARNESS

14. TYPES OF CRSs APPROVED BY A TC, STC, TSO, UNDER SECTION 21.305(d) 

(2010 ed.) OR § 21.8(d). Typically, a CRS approved by the FAA through the TSO process will 

be similar in design to a CRS meeting the requirements of FMVSS No. 213. However, a CRS 

approved by the FAA through a TC, STC, TSO, or under § 21.305(d) (2010 ed.) or § 21.8(d), 

may contain novel and unusual design features. In addition, the regulations allow the use of a 

booster-type or vest- and harness-type CRS, if the FAA has approved it through a TC, STC, 

TSO, under § 21.305(d) (2010 ed.) or § 21.8(d) (§§ 121.311(b)(2)(ii)(C)(3), 

121.311(b)(2)(ii)(C)(4), and 121.311(c)(1)). The aircraft operator is responsible for ensuring that 

crewmembers have proper training and information regarding the use of a CRS approved for use 

on aircraft through a TC, STC, TSO, under § 21.305(d) (2010 ed.) or § 21.8(d). Figure 10 is an 

example of a CRS that has been approved by the FAA through an STC, as well as under 

§ 21.305(d) (2010 ed.).
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FIGURE 10. EXAMPLE OF A CRS (ACSD) APPROVED THROUGH STC AND UNDER 

§ 21.305(d) (2010 ed.)

15. CRSs NOT APPROVED FOR USE DURING GROUND MOVEMENT, TAKEOFF, 

AND LANDING. In 1994, the FAA issued a study entitled, The Performance of Child Restraint 

Devices in Transport Airplane Passenger Seats. The research for the study conducted by the 

FAA Civil Aerospace Medical Institute (CAMI) involved dynamic impact tests with a variety of 

CRSs installed in transport category aircraft passenger seats. The results of this study were used 

as the basis for prohibiting the use of the following devices during ground movement, takeoff, 

and landing. The FAA Office of Aerospace Medicine (AAM) Technical Report, The 

Performance of Child Restraint Devices in Transport Airplane Passenger Seats 

(FAA-AM-94-19), may be found at: 

http://www.faa.gov/data_research/research/med_humanfacs/oamtechreports/1990s/media/AM94

-19.pdf. The CAMI study revealed:

a. Belly Belts. These devices attach the child to the accompanying adult. The child is 

restrained by an abdominal belt attached to the adult’s seatbelt. During dynamic testing, the 

forward flailing of the adult and the child resulted in severe body impacts against the forward 

seat. The child Anthropomorphic Test Dummy (ATD) moved forward to impact the forward row 

seat back, followed by the adult ATD torso striking the child ATD. Then, the adult ATD torso 

continued to move forward after contact with the child ATD, crushing the child ATD against the 

seat back.

b. Harness Restraints. The devices tested consisted of a torso harness for the child ATD 

placed in its own seat with the airplane seatbelt routed through a loop of webbing attached to the 

back of the harness. During dynamic testing, the devices allowed excessive forward body 

excursion, resulting in the test dummy sliding off the front of the seat with a high likelihood of 

the child’s entire body impacting the seat back of the seat directly in front of it. Then, elasticity 

in the webbing of the harness and seatbelts pulled the ATD rearward and this rebound 

acceleration presented further risk of injury.

c. Booster Seats. A key concern for backless booster seats used in airplane seats is the 

combined effect of seat back breakover and impact of an adult seated behind the child. Booster 
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seats may expose the child occupant to potential abdominal injury due to the combined effects of 

these forces.

d. Prohibition. Except for ACSDs approved by the FAA through a TC, STC, TSO, under 

§ 21.305(d) (2010 ed.), or § 21.8(d), the following CRSs continue to be prohibited for use during 

ground movement, takeoff, and landing:

• Lap-held child restraint (commonly referred to as a belly belt);

• Vest- and harness-type devices that attach the child to the parent, the parent’s restraint 

system, or to the aircraft seatbelt; and

• Booster-type child restraints (even though they may bear appropriate labels showing 

that they meet applicable UN standards or are approved by a foreign government).

16. FAA BOOSTER SEAT DEFINITION. The FAA defines booster seats as those that are a 

raised platform base on which the child sits. A front shield, over which the lap belts are routed, 

covers the abdominal area of the child. Booster seats do not have a back or side shell. There are 

no integral belts to restrain the child. The use of such automotive booster seats is prohibited by 

the FAA’s operating rules during ground movement, takeoff, and landing. A child large enough 

for a booster seat can also be properly restrained in the normal passenger seat lap belts.

FIGURE 11. EXAMPLE OF A BACKLESS BOOSTER SEAT

17. CRS MANUFACTURERS’ BOOSTER SEAT DEFINITION.

a. Overview. Some manufacturers choose to market and label their approved CRSs with 

backs as “booster seats.” These “booster seats” do not meet the FAA definition of a booster seat. 

However, these “booster seats” fall into two categories, those with and without internal 

restraints. As per FMVSS No. 213, the manufacturer’s labeling will specify that a CRS without 

internal restraints is not certified for use in aircraft. However, 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.

b. Approved “Booster Seat.” The CRSs in the following image (Figure 12, CRS with 

Internal Restraint Marketed as a “Booster Seat”) would be approved for use during all phases of 

flight.
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FIGURE 12. CRS WITH INTERNAL RESTRAINT MARKETED

AS A “BOOSTER SEAT”

c. Non-Approved “Booster Seat.” The CRS in the following image (Figure 13, CRS 

without Internal Restraint Marketed as a “Booster Seat”) would not be approved for use during 

all phases of flight.

FIGURE 13. CRS WITHOUT INTERNAL RESTRAINT MARKETED

AS A “BOOSTER SEAT”

18. PASSENGER USE OF NON-APPROVED CRSs ON AN AIRCRAFT.

a. Regulations. The regulations contained in § 121.311 prohibit the use of certain types of 

CRSs during ground movement, takeoff, and landing. However, during the cruise portion of the 

flight, there is no regulatory prohibition regarding the use of any type of child restraint, including 

those prohibited from use during ground movement, takeoff, and landing.

b. Operational Flexibility. Also, there is no regulatory requirement that an aircraft operator 

must permit the use of a “non-approved” CRS during the cruise portion of the flight. If an 

aircraft operator decides to implement a policy to prohibit the use of a non-approved CRS 

in-flight, the operator has the operational flexibility to do so.

19. PLACEMENT OF CRS ON THE AIRCRAFT. A CRS must be installed in a 

forward-facing aircraft seat, in accordance with instructions on the label. This includes placing 

the CRS in the appropriate forward- or aft-facing direction as indicated on the label for the size 
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of the child. 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 contained in 

§§ 91.107, 121.311, 125.211, and 135.128 allow aircraft operators to determine the most 

appropriate passenger seat location for a CRS 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 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 the 

placement of a CRS 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 (as defined in 14 CFR part 23, § 23.807, part 25, § 25.807, and part 29, § 29.807) 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.

c. Proper Installation.

(1) Some CRSs will not fit into certain aircraft seats. In this instance, the CRS may not be 

used on those seats. Examples of this include:

• When the base of a CRS with a solid back and seat is wider than an aircraft seat 

with rigid armrests or

• When the strap encircling the seat back on a harness-type CRS approved under 

the provisions of § 21.305(d) (2010 ed.) or § 21.8(d) does not fit around some 

sleeper seats or very large first-class seats.

(2) Certain aircraft seat models have a recessed tray table cavity with rigid sides into 

which the tray table fits when closed. If the strap encircling the seat back on a harness-type 

ACSD is installed underneath the tray table, then this seat back design will not allow the tray 

table to be properly secured during ground movement, takeoff, and landing. In this case, the strap 
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must be placed completely over both the seat back and stowed tray table during these phases of 

aircraft operation.

(3) Some seats are equipped with inflatable seat belts. A seat belt extender must always 

be used with a CRS installed in a seat equipped with an inflatable seat belt. The seat belt 

extender will deactivate the inflation component of the seat belt installed in that seat. Not using a 

seat belt extender with a CRS in a seat equipped with an inflatable seat belt can result in death or 

serious injury.

20. TRAVELING WITH MORE THAN ONE CHILD. In the event a parent/guardian is 

traveling with more than one child in a CRS or is traveling with several small children, only one 

of whom is occupying a CRS, good judgment should be used regarding placement of the CRS. 

As long as these conditions below are met, the CRS could be placed in a seat other than a 

window seat. At a minimum:

• The CRS should be placed so it does not block any passenger’s (including the 

parent’s/guardian’s) egress to the aisle used to evacuate the aircraft and

• The CRS should be placed so the parent/guardian can reach the child in the CRS to 

release and evacuate with the child, should an emergency evacuation be necessary.

21. RESPONSIBILITY FOR ENSURING THE PROPER USE OF CRS. If the CRS is 

supplied by the parent or guardian, typically he or she will check to ensure that the CRS is 

approved and that the child is the right size and weight for the CRS. In addition, the parent will 

usually ensure that the CRS is properly installed in a forward-facing passenger seat. However, 

aircraft operators still have overall responsibility to ensure that the CRS is properly secured to a 

forward-facing seat, the child is properly secured in the CRS and does not exceed the weight 

limit for the CRS, and that the CRS bears appropriate labels or markings (§ 121.311(b)(2)(iii)).

22. EFFECTIVE PRACTICES FOR CONSIDERATION. Effective practices may include:

• The aircraft operator’s training program and crewmember operating manuals should 

contain information, policy, and procedures regarding CRS use;

• The CRS should be secured to a regular passenger seat at all times or, if not in use, 

stowed as carry-on baggage; and

• The child should always be properly secured in the CRS whenever other passengers are 

required to fasten their seatbelts.

23. AN ADULT AS FOUND IN SECTION 121.311. The word “adult,” as it appears in 

§ 121.311, is used in the ordinary sense of the word to denote a person 18 years of age or older 

(http://www.faa.gov/about/initiatives/cabin_safety/regs/legal/media/age_adult.pdf).

24. USE OF AN APPROVED CRS FOR A CHILD WITH DISABILITIES. The majority of 

individuals using CRSs on aircraft are young children typically weighing 40 pounds or less. 

However, there are some people who, because of physical challenges, need the support and 

security that a restraint system provides in order to travel safely on aircraft. Aircraft operators 

should ensure F/As 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. 
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In this case, the aircraft operator may not prohibit the use of the CRS. There are several 

companies manufacturing CRSs approved for use on aircraft specifically designed for larger 

children who are physically challenged.

25. USE OF A NON-APPROVED CRS FOR A CHILD, OR A NON-APPROVED 

RESTRAINT SYSTEM FOR AN ADULT, WITH DISABILITIES. In the case of a person 

who, because of physical challenges, needs the support and security of a non-approved CRS or 

restraint system, the individual, his or her guardian, or the aircraft operator (on the individual’s 

behalf) may request an exemption to certain operating rules addressing the use of the CRS on the 

aircraft. Upon application, the FAA will determine whether the exemption request will be 

granted in order to allow the use of a non-approved restraint system during all phases of flight. 

As part of the conditions and limitations of granting the exemption, the individual or the 

parent/guardian must advise the air carrier about the contents of the exemption at least 48 hours 

before the date of each flight and have a copy of the grant of exemption available for the aircraft 

operator to review when using a non-approved CRS or restraint system on aircraft.

26. HOW TO PETITION FOR EXEMPTION. To find out how to submit a petition for 

exemption, refer to http://www.faa.gov/regulations_policies/rulemaking/petition/. To review 

previously granted exemptions regarding the use of restraint systems, refer to the FAA’s 

Automated Exemption System at http://aes.faa.gov/. To view previously granted exemptions 

regarding the use of specialized restraint for adults, type “12485,” or “9364” in the “Docket 

Search” field. To view previously granted exemptions regarding the use of non-approved 

restraint for children, type “17184,” “29824,”, “28630” or “8264”, “9834” in the “Docket 

Search” field.

27. IMPROVING EMERGENCY EVACUATION CAPABILITIES. To improve 

emergency evacuation capabilities, the CRS should remain attached to the passenger seat during 

an emergency evacuation, and only the child should be removed from the aircraft. Researchers 

from CAMI, Aerospace Medical Research Division (AAM-600), have completed two studies 

designed to determine the most favorable methods for the emergency evacuation of infants from 

aircraft. All CAMI Aerospace Medicine Technical Reports can be found at: 

http://www.faa.gov/library/reports/medical/oamtechreports/.

a. Slide Evacuation. The purpose of the first study, Aerospace Medicine Technical Report 

DOT/FAA/AM-01/18, was to determine the most favorable methods for the evacuation of 

infants via an inflatable emergency evacuation slide. The results of this study strongly suggest 

that jumping onto the slide should be the favored boarding maneuver, as opposed to sitting down 

and sliding which slows the progress of the evacuation. The carrying position that provides the 

most protection for the child would include cradling the child’s head and neck with the hand 

(for a vertical position) or in the arm (for horizontal positions), keeping the child’s arms, legs and 

feet enfolded as much as possible by the adult’s arms.
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b. Overwing Exit Evacuation. The purpose of the second study, Aerospace Medicine 

Technical Report DOT/FAA/AM-05/2, was to determine the most favorable methods for 

evacuation of infants through a Type III overwing exit. The results of this study suggest that 

carrying the infant vertically should be the favored egress maneuver through the Type III exit, 

as opposed to carrying the child horizontally or passing the child to another passenger on the 

outside of the Type III exit.

John Barbagallo

Deputy Director, Flight Standards Service