U.S. Department of Transportation Federal Aviation Administration 

# Advisory Circular

Subject: Use of Child Restraint Systems on Aircraft Date: XX/XX/XXXX Initiated by: AFS

- 200 AC No: 120

- 8 7 C Change:
1. PURPOSE

. This advisory circular (AC) provides information and practices regarding the use of c hild r estraint s ystems (CRS) on aircraft

. We intend for operators to use this as a resource during the development, implementation, and revision of a n air carrier ’ s standard operating procedures (SO P ) , websites and training programs regarding the use of CRS s

. This AC is one of several Federal Aviation Administration (FAA) initiatives designed to address safety concerns of the National Tra nsportation Sa fety Board (NTSB). This AC provides information to air carriers conducting domestic, flag, and supplemental operations that must make available on their websites the width of the widest passenger seat in each class of service for each make, model and serie s of airplane used in passenger

- carrying operations. If an air carrier does not have a website, the air carrier is not required to establish a website in order to comply with this regulation. In addition, it is a part of the FAA ’ s ongoing commitment to e ducate and inform aircraft operators, crewmembers, and airline passengers regarding the use of CRS s on aircraft in order to encourage and increase the use of approved CRS s

. For more information, s ee the following FAA Web site: http://www.faa.gov/passengers /fly_children/crs/.
2. CANCELLATION

. AC 120

- 87 B , Use of Child Restraint Systems on Aircraft, dated September 17, 2010 , is cancelled.
3. RELATED REGULATIONS

. Title 14 of the Code of Federal Regulations (14 CFR) part 21, § 21.305; part 91, §§ 9 1.107 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 CRS s on aircraft

. This AC also supplements and contains information previously published in the documents listed below.

• AC 91

- 62, Use of Child Seats In Aircraft,

• FAA

- AM

- 78

- 12, Child Restraint Systems for Civil Aircraft ,

• FAA

- AM

- 94

- 19, The Performance of Child Restraint Devices in Tra nsport Airplane Passenger Seats, and

• Order 8 900.1 , V olume 3, C hapter 33 , S ection 6, Operations

- Cabin Safety

. 5. AUDIENCE. Air carrier personnel involved in the development of aircraft standard operating procedures ( SOP ) and training programs, as well as crewmembers , enginee rs andAC 120

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Page 2 Par 6 website 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 associa ted with operations under parts 91, 125, and 135

. 6. HISTORY OF CRS REQUIREMENTS A ND APPROVAL STANDARDS.

a. Civil Air Regulations (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 1953 CAR , § 40.174, which stated in part that “A seat and an individual seatbe lt are required for each passenger a nd crewmember excluding infants. ”
b. Federal Motor Vehicle Safety Standard (FMVSS) No. 213

. In 1982, the Department of Transportation (DOT) had two standards for CRS

. CRS for use in motor vehicles were required to be certif ied 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) C100

. 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 CRS

. One of those recommendations was that DOT simplify its two different standards and set forth requirements for CRSs by com bining the standards

. The FAA and the National Highway Traffic Safety Administration (NHTSA) agreed upon a single g overnment performance standard that would satisfy both aviation and highway safety requirements for CRS s

. The agencies proposed NHTSA as the sole agency responsible for administering the new FMVSS No. 21 3, which would be applicable to CRS s 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 Standards or Approval by a Foreign Government. On October 15, 1992, the FAA broadened the categories of CRS s allowed to be used on aircraft to include CRSs meeting the standards of the United Nations 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 c ategories of CRSs that aircraft operators may furnish for use on aircraft to include CRS s approved by the FAA through TC, STC, or TSO (70 FR 50902).

e. FAA Approval through Section 21.305(d), or TSO C

- 100b, 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 C

- 100b, Child Restraint System, or a later version (71 FR 40003).
7. FAA APPROVAL PROCESSES USED FOR APPROVED CRSs ON AIRCRAFT

. The TC, STC, TSO, and § 21.305(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 is9/17/10 AC 120

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Par 7 Page 3 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 u sed 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 asso ciated 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 notic e 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 ins talled and used without creating safety concerns

. See 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 minimu m 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 Un ited States

. TSO C

- 100b contains minimum performance standards for the testing and evaluation of CRS

. The minimum performance standard references Society of Automotive Engineers (SAE) Aerospace Standard (AS) 52761

. It also requires the ma nufacturer to prov ide operating instructions, equipment 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 C100b provides more realisti c 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 perform ance sta ndards contained in TSO C

- 100b

. d. Section 21.305(d) Process. (1) Under the FAA ’ s certification rules, § 21.305(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 i ncluded this provision in § 21.305 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 § 21.305(d), the FAA must ensure the CRS meets an equival e nt level of safety (ELOS) to other approval processes

. For a CRS, the FAA ’ s technical experts lo ok at the benchmark (current edition of TSO C

- 100b ) and identify safety

- critical features . The technical experts ensure that each of these features meet an ELOSAC 120

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Page 4 Par 8 adequately

. This ensures a CRS approved by the FAA under § 21.305(d) will meet a high level of safety regarding testing, quality, and performance standards.
8. AVIATION CHILD SAFETY DEVICES (ACSD)

.

a. Avoiding Consumer Confusion

. The FAA recognizes that the term “ c hild r estrai nt
s ystem” 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 “ c hild r estraint s ystem ” to describe any appr oved 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 CRS s meeting the requirements of FMVSS No. 213 ( safe for use in motor vehicles ) and CRSs designed only for use in aircraft (not safe for use in motor vehicles) , the FAA has introdu ced a new term referring to CRSs only approved for aviation use

. The FAA will call these aviation

- only restraints Aviation C hild Safety Devices (ACSD)

. Regu lations regarding the use of CRS in aircraft also apply to ACSDs. Below is an example of an ACSD (also shown in paragraph ( 13 ) )

.

Example of a CRS (ACSD)

b. Warning Label

. ACSDs only meeting the aviation peformance standards contained in T SO C

- 100b or app roved under § 21.305(d) are not safe for use in motor vehicles

. The FAA worked closely with NHT SA to ensure that labeling on ACSD s clearly illustrate that ACSDs are not safe for use in motor vehicles. The FAA also plans to require a similar warning label o n ACSDs approved by the FAA through the STC process.
FIGURE 1. REQUIRED WARNING LABEL FOR AVIATION CHILD SAFETY DEVICES WITHOUT FMVSS NO. 213 APPROVAL9/17/10 AC 120

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Par 8 Page 5 

## WARNING! NOT SAFE FOR USE IN MOTOR VEHICLES Could result in serious injury

c. Consumer Education. The FAA is ta king steps to educate consumers regarding the difference between devices safe for use in both motor vehicles and aircraft vs. 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/crs/ ) , 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 A ttendants (F/A) , to take adva ntage 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 informa tion regarding CRSs and pertinent regulations also apply to ACSDs.
9. LABELING ON CRS s APPROVED FOR USE DURING GROUND MOVEMENT, TAKEOFF, AND LANDING

. Current operating rules in parts 91, 121 , 125, and 135 require that CRS s used on aircraft during ground movem ent, 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 “Th is 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

. The following is an example of this required labeling:

b. Approval Label s . The CRS must bear either a label showing approval of a foreign g overnment or a label showing that the CRS was manufactured under the standards of the United Nations

. The following is an example of the required labeling for a CRS manufactured under the
s tandards of the United Nations (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 count ry that has granted approval):AC 120

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Page 6 Par 9 c. FAA Approval Label. The CRS must bear a label or markings showing FAA approval through an STC

. The following is an example:

d. TSO Label. CRS s approved under TSO C

- 100b , must be permanently and legibly marked “TSO C

- 100b.”

e. Approval under § 21.305(d) Label. The CRS must be cle arly marked showing FAA approval under § 21.305(d) and bear the label “FAA Approved in Accordance with 14 CFR § 21.305(d).” The following is an example:

10. REGULATORY REQUIREMENT S REGARDING THE USE OF CRS s ON AIRCRAFT

.

a. Children Under the Age of Two. Under the provisions in parts 121, 125, and 135 d uring 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 pers on 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 fo rward

- 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. FAA APPROVED IN ACCORDANCE WITH 14 CFR 21.305 (d) APPROVED FOR AIRCRAFT USE ONLY Conforms To: PAT NO. STC STO10781LA

APPROVED FOR AIRCRAFT USE ONLY9/17/10 AC 120

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Par 1 0 Page 7 c. CRS Restrictions. No aircraft operator may permit a child to occupy a booster

- type, vest

- type, harness

- type, or lap

- he ld CRS during takeoff, landing, and movement on the surface, except when the CRS has been approved by the FAA through a TC, STC, TSO, or under § 21.305(d)

. Booster

- type, vest

- type, and harness

- type CRS s approved by the FAA through a TC, STC, TSO, or under § 21.305(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

. (Certificat e holders are encouraged to allow the use of empty seats to accommodate CRS ; h owever, they are not required to allow unticketed 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 a ppropriate forward

- facing passenger seat location, consid ering 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 accom modate the CRS. (2) An aft

- facing CRS that can not 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. (3) A harness type CRS (approved under § 21.305(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. NOTE: An aircraft operator may have policies, based on safe operating practices , that establish certai n 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 where the CRS could be used safely, is not consistent with the requirements i n parts 121, 125 , and 135.
11. g. Seat Dimension Disclosure

. Consistent with the FAA Modernization and Reform Act of 2012 , §121.311(k) requires air carriers conducting domestic, flag, and supplemental operations to make available on their websites the width of the widest passenger seat in each class of service for each airplane used in passenger

- carrying operations. This rule facilitate s the use of CRSs onboard airplanes and provides greater information to caregivers to help them determine whether a particu lar CRS will fit in an airplane seat. WORN OR UNREADABLE LABELS

. When an approved CRS is labeled or marked by the manufacturer, it certifies the CRS meets a set ofAC 120

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Page 8 Par 12 safety standards (FMVSS No. 213, the standards of a foreign g overnment, the standards of th e United Nations, or approval by the FAA through a TC, STC, TSO, or under § 21.305(d))

. Current operating rules require the CRS used on an aircraft during ground movement, takeoff, and landing must bear labels or markings to indicate to the aircraft operat or that the CRS meets safety standards

. 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 (throu gh a detailed description or specific make and model number) to approval for use on aircraft. An o wner ’ s m anual is also acceptable as proof of safety standards, as these booklets contain pictures or illustrations of the CRS and information that the CRS mee ts FMVSS 213

. 12. TYPES OF CRS s MEETING THE CRITERIA OF FMVSS NO. 213, STANDARDS OF A FOREIGN GOVERNMENT, OR STANDARDS OF THE UNITED NATIONS

. Basic design features f or the majority of approved CRS s for use on aircraft have remained fairly constant, although so me changes and i nnovations in the design of CRS s have occurred as a result of FAA approval of CRS s through a TC, STC, TSO, or under § 21.305(d)

. A n aircraft operator ’ s personnel, specifically F/A s, should be aware of the following items pertaining to CRS s meeting the criteria of FMVSS No. 213, the standards of a f oreign g overnment, or the United Nations

. 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.

• The CR S must have a label showing approved for aviation use.

Example of a Forward

- f acing CRS with Internal Harness9/17/10 AC 120

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Par 1 3 Page 9 Example of an Aft

- f acing CRS with Internal Harness
13. TYPES OF CRSs APPROVED BY A TC, STC, TSO, OR UNDER SECTION 21.305(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, CRS s approved by the FAA through a TC, STC, or under § 21.305(d), may contain novel and unusual design features

. In ad dition, the regulations allow the use of booster

- typ e or vest

- and harness

- type CRS s , if the FAA has approved them through a TC, STC , TSO, or under § 21.305(d) (§§ 121.311(b ) (2 ) (ii ) (C ) (3 ), 121.311(b ) (2 ) (ii ) (C ) (4 ) , and 121.311(c ) (1 )

. The aircraft operator i s responsible for ensuring that crewmembers have proper training and information regarding the
us e of CRS s approved for use on aircraft through a TC, STC, TSO, or under § 21.305(d)

. The following is an example of a CRS that has been approved by the FAA thr ough a STC, as well as under § 21.305(d):

Example of a CRS (ACSD) A pproved through STC and under § 21.305(d)
14. CRS s NOT APPROVED FOR USE DURING GROUND MOVEMENT, TAKEOFF, AND LANDING

. In 1994, the FAA issued a study entitled “The Performance of Child Restra int Devices in Transport Airplane Seats.” The research for the study conducted by the FAA Civil Aerospace Medical Institute (CAMI) involved dynamic imp act tests with a variety of CRS sAC 120

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Page 10 Par 12 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

. T he FAA Office of Aerospace Medicine (AAM) r eport, “The Performance of Child Restraint Devices in Transport Airplane Passenger Seats,” may be found at: http://www.faa.gov/library/reports/medical/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 attac hed 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, fol lowed 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 f urther 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 seats may expose the child occupant to potential abd ominal injury due to the combined effects of these forces.
d. Prohibition. Except for ACSDs approved by the FAA through a TC, STC, TSO, or under § 21.305(d), the following CRS s continue to be prohibited for use during ground movement, takeoff, and landing:

• L ap

- 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 app ropriate labels showing that they meet applicable United Nations standards or are approved by a foreign g overnment)

. 15. FAA BOOSTER SEAT DEFINITION. The FAA defines booster seats as those that are a raised platform base on which the child sits

. A front shiel d, 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.9/17/10 AC 120

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Par 1 6 Page 11 Example of a Backless Booster Seat
16. CRS MANUFACTURERS ’ BOOSTER SEAT DEFINITION

.

a. Overview. Some manufacturers choose to market and label their approved CRS s 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 interna l 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 CRS s marketed as “boost er 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 CRS s in the following image ( CRS with Internal Restraint Marketed as a “ Booster Seat ” ) would be approved f or use during all phases of flight

.

c. Non

- A pproved “Booster Seat

. ” The CRS in the following image ( CRS without Internal Restraint Marketed as a Booster Seat) would not be approved for use during all phases of flight

.AC 120

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Page 12 Par 14 17. PASSENGER USE OF NON

- APPROVED CRS s O N AN AIRCRAFT

.

a. Regulations. The regulations contained in § 121.311 prohibit the use of certain types of CRS s 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 permit the use of “non

- approved” CRS s during t he cruise portion of the flight

. If an aircraft operator decides to implement a policy to prohibit the use of non

- approved CRSs in

- flight , they have the operational flexibility to do so.
18. PLACEMENT OF CRS ON THE AIRCRAFT

. CRS s must be installed in forward

- f acing aircraft seats, 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 of the child

. A window seat is the preferred location; however, othe r 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 ai rcraft operators to determine the most appropriate passenger seat location for CRS s based on safe operating practices

. In making this determination, an aircraft operator should consider the following

.

a. Aisle Seats

. CRS s 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 impe de F/A s 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 d evelopment of procedures regarding placement of CRS s 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 par ent/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 T ype III exit hatches (as defined in 14 CFR part 23, § 23.807, part 125, § 25.807, a nd part 129, § 29.807) in the row forward or aft of the emergency exit row, the aircraft operator should restrict the placement of CRS s accordingly. (2) Installation of a CRS in the row forward of an exit keeps a seat back from breaking
over

. Aircraft seats a re not required to break over, but if an aircraft operates with this feature and evacuation procedures include breaking over seat back s forward of an exit to create space for a crewmember or to create a wider evacuation path for passengers, the aircraft op erator should restrict the placement of CRS s accordingly.

c. Proper Installation

.9/17/10 AC 120

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Par 19 Page 13 (1) Some CRS s 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) does not fit around some sleeper seats or very large first class seats. (2) Certain airc raft 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 t he tray table to be properly secured during ground movement, takeoff , and landing

. In this case, the strap must be placed completely over both the seat back and stowed tray table during these phases of aircraft operation.
19. 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 s 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/guardian ) 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

. 20. 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 s till have over all 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 (§ 121.31 1(b)(2)(iii) )

. 21. EFFECTIVE PRACTICE S FOR CONSIDER ATION

. 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

.22. 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 )

. 23. USE OF AN APPROVED CRS FOR A CHILD WITH DIS ABILITIES. The majority of individuals using CRS s 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 ord er to travel safely on aircraft

. Aircraft operators should ensure F/A s 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

. In this case, the ai rcraft operator may not prohibit the use of the CRS

. There are several companies manufacturing CRS s approved for use on aircraft specifically designed for larger children who are physically challenged.
24. USE OF A NON

- APPROVED CRS FOR A CHILD, OR A NON

- APPROV ED 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 restr aint system during all phases of flight

. While not required, it has been found to be an effective practice for the individual or the parent/guardian to have a copy of the grant of exemption available for the aircraft operator to review when using a non

- app roved CRS or restraint system on aircraft

. 25. HOW TO PETITION FOR EXEMPTION

. To find out how to submit a petition for exemption, see http://www.faa.gov/regulations_policies/rulemaking/petition/

. To review previously granted exemptions regarding the use of re straint systems, see 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.
26. IMPROVING EMERGENCY EVACUATION CAPABILITIES

. To improve emergency evacuation capabilities, the CRS should r emain attached to the passenger seat during an emergency evacuation, and only the child should be removed from the aircraft

. Researchers from CAMI, AAM

- 600, have completed two studies designed to determine the most favorable methods for the emergency evacu ation of infants from aircraft

. All CAMI Aerospace Medicine Tech nical Reports can be found at: http://www.faa.gov/library/reports/medical/oamtechreports/

.

a. Slide Evacuation. The purpose of the first study, DOT/FAA/AM

- 01/18, was to determine the most favora ble 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 p rogress 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 arm9/17/10 AC 120

- 87B

Par 19 Page 15 (for horizontal positions), keeping the child ’ s arms, le gs and feet enfolded as much as possible by the adult ’ s arms.
b. Overwing Exit Evacuation. The purpose of the second study, DOT/FAA/AM

- 05/02, was to determine the most favorable methods for evacuation of infants through a Type III overwing exit

. The results o f 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 S

. Duncan Director, Flight Standards Service