1 

Update of Safety Benefits & Tradeoffs Related to Requiring the Use of Child 

Restraint Systems on Aircraft for Children Less Than Two Years of Age

Office of Accident Investigation and Prevention 

Federal Aviation Administration, 

December 2011 

This paper updates and confirms the FAA’s position that requiring the use of child restraint 

systems (CRS) in FAR Part 121 operations would result in a significant net increase in total 

transportation fatalities. This update concludes that requiring the use of CRS would increase 

total transportation deaths by 72 over 10 years and by 115 deaths over 15 years. 

Part 1: Outline of the FAA Position

FAA has long agreed that an infant is safer in a properly secured safety seat and FAA continues 

to encourage adults traveling with young children to use such seats when traveling by air. The 

virtues of using proper child restraint systems are not at issue. Rather, the issue is the unintended 

consequence of requiring their use: a net increase in transportation deaths. 

FAA’s position is based on two fundamental premises plus the empirical evidence, which shows 

no preventable infant deaths in air carrier operations for more than 17 years. The first premise 

holds that price matters; it affects consumer decisions, including modal choice for family travel 

within competitive distances. Requiring CRS would significantly increase the price of family air 

travel for a small, targeted population, who would bear the entire cost of the requirement. The 

cost of a trip by air would double for one adult traveling with an infant. Cost would increase by 

half for a party of two plus an infant, and by one-third for a party of 3 plus an infant. Parties who 

travel by air with infants average 2.2 persons plus the infant.1 That average party would have to 

purchase 3.2 tickets and would incur an average cost increase of 45 percent per trip by air.

Families’ responses to such price increases would vary, depending on trip distance, the urgency 

of a trip, and household income. Many families would choose to continue their trips as planned 

and purchase an extra ticket, and some families would simply cancel their trips. However, many 

families would choose to drive to the same destinations or, for more discretionary trips such as 

vacations, they might choose different locations and travel by road. 

The second fundamental premise holds that the Nation’s highway system, which would capture 

virtually all of the family travel that price might divert from the air transport system, is less safe 

than the air carrier system. This remains true despite recent improvements in highway fatal 

accident rates. Consequently, the diverted travel would impose higher risks on the entire travel 

party and, to some degree, on other drivers. The net effect would be an increase in total 

transportation deaths. 

 

1 U.S. Department of Transportation, Federal Aviation Administration, Report to Congress, Child Restraint Systems, 

May 1995
2 

To reach any other conclusion, FAA must argue that price is irrelevant in family travel decisions, 

and therefore would not divert any trips, or that highway travel and air travel impose equal risk 

of fatality to infants and to other family members. Neither argument would be credible. 

Part 2: Preventable Infant Deaths in the Air Carrier Industry

Part 91.107 of the Federal Aviation Regulations requires that each person on board a U.S.-

registered civil aircraft certified after November 1, 1987 “must occupy an approved seat or berth 

with a safety belt, and if installed, shoulder harness, properly secured about him or her during 

movement on the surface, takeoff, and landing.” However, “a person may . . . be held by an 

adult who is occupying an approved seat or berth, provided that the person being held has not 

reached his or her second birthday.” A child who has reached his or her second birthday must be 

in his or her own seat. Therefore the issue of requiring the use of a CRS is limited to infants 

(children less than 2 years of age). Benefits would accrue only when the CRS could prevent 

fatalities or injuries to infants. 

A review of airline accidents from fiscal year (FY) 1980 (October 1979) through August 2011 

shows that CRS would have prevented 3 fatal injuries to infants over 32 years. 2

 The 3 fatalities 

that could have been averted occurred at Denver in November 1987, at Sioux City in July 1989, 

and at Charlotte in July 1994. No preventable fatalities have occurred since Charlotte, more than 

17 years ago. In short, the empirical evidence is limited to 3 “saves” over 32 years and none in 

the past 17 years. The NTSB agrees that this is the extent of the empirical evidence. 

The 3 preventable infant deaths occurred in an 8-year span, which constituted an unusual spike 

for this issue even in that era of much higher accident rates. In those 8 years (1987 through and 

including 1994), U.S. air carriers had a rate of 25 fatalities per every 100 million occupants. In 

the past 4 years the rate has fallen to 0.3 per 100 million occupants. As major accidents become 

increasingly rare, opportunities for additional saves also will become increasingly rare. 

Yet FAA recognizes that the risk of incurring a preventable infant death is greater than zero, and 

therefore the possible benefit of requiring the use of CRS remains greater than zero. 

Nevertheless, given the experience of the past 17 years and the substantial and continuing 

reduction in fatality rates among passengers on air carrier aircraft, we can not assume more than 

1 possible save every 10 to 15 years. 

Part 3: Size of the Affected Travel Population & Trip Distance

In 2010, airlines carried 675.5 million ticketed passengers on domestic routes. FAA forecasts 

call for an average annual growth rate of 3.7 percent in ticketed domestic passengers from 2011 

through 2015, followed by an annual average growth rate of 2.5 percent for the following 15 

 

2 FAA implemented FAR Part 119 in spring 1997. Prior to that rule, scheduled passenger operations in aircraft from 

10 to 30 seats were regulated under FAR Part 135 (commuter) rules. As of spring 1997, FAR 119 placed scheduled 

passenger operations in those aircraft under the more demanding FAR Part 121, which had regulated all passenger 

operations in larger aircraft. The review of accidents cited here includes pre-1997 operations addressed by FAR Part 

119 to ensure a common definition over the study period.
3 

years.3

 Those projected growth rates would produce an annual average of 787.3 million 

passengers over the next 10 years and an annual average of 845 million over 15 years. 

Most observers assume that lap infants account for about 1 percent of occupants on air carrier 

aircraft.4 If so, an annual average of 8 million infants will travel in the domestic air carrier 

system over the next decade, with an annual average of 8.53 million over 15 years. With 3.2 

persons per travel party, including infants, a total population of about 25.6 million air travelers 

per year would be affected by a CRS requirement over 10 years and about 27.3 million per year 

over 15 years. 

Highways already dominate inter-city family travel. The National Household Travel Survey 

(NHTS) reports 97 percent of trips of less than 250 miles use private vehicles. NHTS also finds 

that highways account for 95 percent of trips of less than 500 miles. From 500 to 749 miles, 

highways account for a more modest but still dominant 62 percent of trips and 42 percent of trips 

from 750 to 999 miles. Even at distances of 1,000 to 1,499 miles, private vehicles still account 

for 31 percent of all trips. In short, private vehicles remain the mode of choice past 1,000 miles 

and remain competitive through 1,500 miles. 

Table 1 shows airline trips by distance (in statute miles) for the top 1,000 airline city pairs to 

begin identifying the share of families whose travel would be within distances where highways 

compete and even dominate. To avoid over-estimating the population that could be affected by a 

CRS rule, the table accounts for “barrier markets” in which physical barriers eliminate road 

alternatives, such as trips to Hawaii and Puerto Rico, intra-islands trips in Hawaii, travel to, from 

or within Alaska, or trips to the U.S. Virgin Islands. Barrier markets account for 5.8 percent of 

domestic air travelers. However, even after eliminating air travelers whose trips are to or from 

barrier markets, private vehicles remain competitive or dominant in city pairs that capture 74 

percent of domestic air travel.

Many families, as well as other travelers, currently choose private vehicles for multiple reasons, 

including access to multiple or isolated destinations, flexibility, and total cost. Conversely, 

families who chose to travel by air within those distances may do so for reasons of convenience, 

urgency, or safety and risk assessment. Nevertheless, given that highways dominate trips up to 

750 miles and remain very competitive through 1,000 miles, the extra cost of an additional ticket 

for air travel would divert a substantial share of families who now fly. 

Proponents of a CRS rule assert that the airlines could manage those increased costs through a 

variety of strategies, including variable pricing, free seats on city pairs with low load factors, 

frequent-flyer benefits, spreading the costs across all tickets, etc. Some price competition for 

infant tickets could occur at the margins, but with load factors at 83 percent system-wide, and 

higher on densely traveled city pairs, most families would have to absorb the full cost of a ticket, 

or an average cost increase of 45 percent for an average party of 3.2 people, of whom one now 

travels free. 

 

3 FAA Aerospace Forecasts FY 2011-2031, Federal Aviation Administration, Table 5, and Table 8 for trans-border 

traffic to Canada. 4 U.S. Department of Transportation, Federal Aviation Administration, Report to Congress, Child Restraint Systems, 

May 1995. 
4 

Though the precise level of inter-modal elasticity is not well established, empirical evidence 

shows that competition among air carriers is intensely price-sensitive. A review of the literature 

on price elasticity in aviation shows that elasticity is strongest in short-haul markets, at -1.74 for 

the first quartile of trip distance, which captures the competitive trip distances. 5 In fact elasticity 

among air carriers remains quite strong at any distance. 

Since many parents of infants have yet to reach peak earning years, sensitivity to the cost of an 

extra air ticket will be substantial among these consumers. Diversion could easily reach onethird for trips up to 500 miles. Since 95 percent of all travelers currently choose private vehicles 

for such trips, one-third may err on the low side. For trips from 500 to 749 miles, highways’ 

dominance drops from 95 to 62 percent. If we reduce the assumed diversion rate 

proportionately, we can assume 22-percent diversion from 500 to 749 miles. A similar pro-rata 

reduction in the assumed rate of diversion for long trips produces an assumed diversion rate of 

15 percent from 750 to 999 miles. For trips of 1000 to 1,499 miles, where private vehicles still 

capture 31 percent of all inter-city trips, this analysis assumes a diversion rate of just 5 percent. 

Table 2 summarizes these assumptions and the vehicle miles of travel (VMT) that would be 

generated by diverted trips. Over 10 years, these assumptions would divert 11.3 million family 

trips to highways and 18.1 million family trips over 15 years. 

 

The above assumptions may err on the low side. Nevertheless, they produce a total of 6.4 billion 

VMT over 10 years and 10.2 billion VMT over 15 years. The remaining issues for this analysis 

are: (1) the level of risk to which travelers would be exposed if they diverted to highways; and 

(2) the number of fatalities that risk would produce. 

Part 4: Highway Volume and Accident Rates 

This analysis uses a consciously conservative fatal accident rate for highways, based on the 

reasoning outlined below. The highway data supporting this reasoning is shown in Table 3. 

1. Diverted family travel would be limited to passenger vehicles on the Interstate 

System. This excludes accidents that involve only motorcycles or trucks and captures 

only automobiles, SUV’s and some other 4-tired, light vehicles.

2. All diverted travel is assumed to use inter-city highways, where design characteristics 

reduce the fatal accident rate. Rural Interstate mileage typically is used to represent 

rates for inter-city travel. Rural Interstates in 2008 and 2009, the 2 most recent years 

for which highway data is available by functional system, produced a fatality rate for 

family vehicles, as defined above, of 14.2 fatalities per billion VMT. However, a 

more balanced assessment must recognize that inter-city trips in fact also use urban 

Interstate mileage, where fatal accident rates are much lower than on the Rural 

Interstate, at 5.5 fatalities per billion VMT. 

 

5 “Air Travel Demand Elasticities: Concepts, Issues and Measurement;” David W. Gillen, William G Morrison and 

Christopher Stewart, Wilfred Laurier University, Waterloo, Canada.
5 

3. Assume that inter-city trips on the Interstate use rural and urban mileage in proportion 

to the rural/urban split of all Interstate mileage: 32.6 percent urban and 67.4 percent 

rural as of 2009.6

 Weighting fatality rates by this rural/urban split of Interstate 

mileage yields a fatality rate of 11.4 fatalities per billion VMT for family vehicles.

4. Unlike aviation, risk in highway travel is essentially linear. Generally, a 500-mile trip 

on an Interstate is about 10 times more likely to produce an accident than is a 50-mile 

trip on the Interstate. 

5. Vehicle occupancy is assumed to average 3.2 for affected families versus a mean 

occupancy of 1.6 for all passenger vehicles on the Interstate. In a serious accident, 

this would increase the average fatality rate proportionately from the above 11.4 per 

billion VMT to 22.8 per billion VMT for inter-city family trips. 

6. However, passengers, especially those in rear seats, are at less risk than are drivers. 

This would lower the effective fatality rate to about 21 persons per billion VMT.

7

 

7. The demographics of the affected drivers would reduce that rate even further, due to 

driver age, lower rates of alcohol involvement when driving with families onboard, 

lower rates of excessive speed with families onboard, etc. Newman, Johnson and 

Grossman estimate a fatal accident coefficient of 0.53 for this group during family 

travel. This reduces the above fatality rate for this analysis, from 21 to 11.13 per 

billion VMT for diverted travelers.

 

8. Fatalities involving passenger vehicles are not limited to people in vehicles. Highway 

data identifies fatalities to cyclists and pedestrians on rural and urban Interstates, but 

does not distribute them by vehicle class. Consequently, those fatalities are 

distributed here in rural and urban areas according to the respective number of 

passenger vehicles involved in fatal crashes as a share of all vehicles involved, 

adjusted for the 0.53 coefficient noted above. This raises the Interstate fatality rate 

from 11.13 to 11.3 fatalities per billion VMT for diverted family trips. This is the 

rate assumed for the calculations that follow.

The 45-percent increase in costs for air travel from a CRS rule would generate 6.4 billion VMT 

over 10 years and 10.2 billion VMT over 15 years, as noted in Table 2, with an occupancy rate of 

3.2 persons and a fatality rate of 11.3 per billion VMT. At these rates, diversion would produce 

72 new fatalities over 10 years and 115 new fatalities over 15 years. 

Table 2 estimated a total of 11.33 million diverted family trips in 10 years among the 80 million 

families who would be traveling by air with infants, or 14.2 percent of all such families. In short, 

with a total diversion of just 14 percent in response to a 45-percent average price increase in net 

 

6 Table HM-220, Highway Statistics (annual), Federal Highway Administration. Three-digit Interstate Spur mileage 

into central cities is excluded (from FHWA Interstate Route Finder). 

7 Newman, Thomas B., MD, MPH, Brian D. Johnson, MD, MPH and David C. Grossman, MD, MPH, “Effects and 

Costs of Requiring Child-Restraint Systems for Young Children Traveling on Commercial Airplanes,” Archives of 

Pediatrics & Adolescent Medicine 157 (October 2003) 969-974 . 
6 

costs for air travel, requiring the use of CRS would lead to 72 additional transportation fatalities 

over 10 years and 115 fatalities over 15 years in the hope of achieving one “save.”

The disparity of serious injuries is much greater than the disparity in fatalities. Data from NTSB 

shows that, from 1980 through and including 2001, Part 121 passenger operations incurred 3.6 

fatalities for every serious injury. With the sharp improvement in Part 121 fatality rates, that 

ratio has changed to 1 fatality per serious injury over the past decade. In highways, the number 

of serious injuries has always and greatly exceeded the number of fatalities. Data from the 

Bureau of Transportation Statistics shows that highway passenger vehicles produced 85 serious 

injuries for every fatality from 2004 through 2009.8

 

If we apply those ratios (1-to-1 versus 85-to-1) to the fatality ratio of 72-to-1 over 10 years, the 

10-year experience produces a fantastic comparison of 6,120 serious injuries in passenger 

vehicles per serious injury in Part 121 passenger operations. Even after accounting for the 

relative safety of the Interstate and the added safety of family drivers, family travel on the 

Interstate would produce a still fantastic 1,400 additional serious injuries over 10 years and about 

2,200 additional serious injuries over 15 years. 

Conclusion

The use of child restraint systems could have prevented 3 infant deaths during US air carrier 

operations in the past 32 years, but none in the past 17 years. As major airline accidents become 

increasingly rare, opportunities for additional “saves” also will become increasingly rare. 

Consequently, though the risk of a preventable infant fatality is greater than zero, benefits are 

limited to the possibility of 1 infant “save” over 10 to 15 years. 

However, a CRS rule will impose very substantial cost increases on a targeted population of 

adults traveling with small children. Based on the simple premise that price matters, those cost 

increases will change travel decisions among some traveling families, at least within competitive 

trip distances. Those new consumer decisions will include diversion of trips from air to 

highways. After accounting for recent and impressive improvements in highway fatality rates, 

and after adjusting those rates downward to account for several important factors that make intercity family travel relatively safe, the net effect will be an increase of about 72 additional 

transportation fatalities over 10 years and 115 additional deaths over 15 years. The disparity in 

serious injuries is even greater, on the order of about 1,400-to-1. FAA believes these results are 

conservative. However, even if these estimates were deemed to be overstated by 3-fold or 5-fold, 

the benefit-cost ratios would remain prohibitive. 

 

8 See Bureau of Transportation Statistics, Table 2-21: Passenger Car Occupancy Safety Data.
7 

Table 1: Distribution of Airline Passenger Trips

By One-Way Trip Distances, Top 1,000 Markets, CY 2009 

Trip Distance (Statute 

Miles)

% All Air 

Pax

% of All Air 

Pax in 

Barrier City 

Pairs

Net % 

of All Air 

Pax

0 - 99 0.161 0.161 0.000

100-149 1.002 0.9 0.121

150-199 1.426 0.348 1.078

200-249 2.864 0.398 2.466

250-299 2.976 0.078 2.898

300-349 4.628 0.2 4.405

350-399 3.477 0.0 3.477

400-449 4.168 0.0 4.168

450-499 3.260 0.000 3.260

500-549 2.658 0.0 2.658

550-599 3.412 0.1 3.276

600-649 3.089 0.0 3.089

650-699 2.881 0.0 2.881

700-749 2.777 0.0 2.777

750-999 17.690 0.000 17.690

1000-1499 20.432 0.672 19.760

1500-1999 10.304 0.949 9.355

2000-2499 8.885 0.677 8.208

2500 > 3.910 1.460 2.450

Total 100.000 5.983 94.017

Source: FAA (APO)

Table 2: Assumed Diversion Rates, 

Trips Diverted & VMT Generated

Trip Length in Statute Miles

0-499 500-749 750-999 1,000-1,499 Sub-Tot

% of Air Travel (Minus 

Barrier markets) 21.87 14.68 17.69 19.76 74.00

Current Highway % of 

All Intercity Travel 

(NHTS) 95 62 44 31 59

Assumed Diversion, 

Family Travel, with 45-

% price Increase (in %) 33.3 22 15 5 15.1

Million Family Trips 

Diverted in 10 Years 5.83 2.58 2.12 0.79 11.33

Million Family Trips 

Diverted in 15 Years 9.33 4.13 3.40 1.26 18.12

Median Trip Length, 

Statute Miles (Table 2) 347 618 883 1134 753

Highway VMT (Billions) 

Over 10 Years 2.02 1.60 1.87 0.90 6.39

Highway VMT (Billions) 

Over 15 Years 3.24 2.55 3.00 1.43 10.22
8 

Table 3: Highway Vehicle Miles of Travel (VMT) and Fatalities

For Passenger Vehicles

2008 2009 Two-Year Total

Rural Urban Total Rural Urban Total Rural Urban Total

Interstate Crashes

Single Pax Vehicle Only 1,079 922 2,001 954 829 1,783 2,033 1,751 3,784

Multi-Vehicle, Pax Vehicles Only 268 354 622 226 327 553 494 681 1,175

Multi-vehicle, Pax & Other Vehicle 421 469 890 367 385 752 788 854 1,642

All Crashes Involving Pax Vehicles 1,768 1,745 3,513 1,547 1,541 3,088 3,315 3,286 6,601

Interstate Fatalities

Single Pax Vehicle Only 1,219 1,006 2,225 1,068 909 1,977 2,287 1,915 4,202

Multi-Vehicle, Pax Vehicles Only 348 407 755 276 395 671 624 802 1,426

Multi-Vehicle, Pax & Other Vehicle 518 531 1,049 469 431 900 987 962 1,949

Interstate Total Involving Pax Veh. 2,085 1,944 4,029 1,813 1,735 3,548 3,898 3,679 7,577

Million VMT, All Pax Vehicles 135,091 335,612 470,703 139,621 334,765 474,386 274,712 670,377 945,089

Fatalities per Billion VMT, Pax Vehicles 

Interstate 15.43 5.79 8.56 12.99 5.18 7.48 14.19 5.49 8.02
9 

Appendix

Air Carrier Accidents Since 1980 in Which Child Restraint Systems Could 

Have Prevented Infant Fatalities

November 15, 1987 Continental DC-9 At Denver

28 fatalities, 28 serious injuries, 25 minor injuries; 1 no injury 

The aircraft remained on the runway for 27 minutes after de-icing in heavy snow. The 

takeoff roll appeared normal, but the crew over-rotated, rolled right and crashed. The 

failure to de-ice again, plus the rapid rotation with ice-contaminated wings led to the loss 

of control. No passengers in left-side window seats from rows 2 through 9 survived and 

occupants in the center of the aircraft died from severe compression. However, the 28 

fatalities included a lap baby in seat 5C (right side). The baby's mother survived, but the 

baby struck the bulkhead and died of multiple blunt trauma injuries. Yet, the only 

passenger to have no injuries was a 6-week-old lap baby in row 24. 

July 19, 1989 United Airlines DC-10 A At Sioux City, IO 

111 fatalities and 47 serious injuries; 138 minor or no injuries. 

During an uncontained engine failure, the fan disk penetrated the aircraft and severed all 

hydraulics systems. Thrust and asymmetric thrust were the only controls available to the 

crew. During an emergency landing at Sioux City, the aircraft banked right just before 

touchdown, cart wheeled and burned. Of 296 occupants, 4 were lap babies, from 7 to 26 

months. Two of the 4 remained secure in the crash sequence and had only minor injuries 

but parents lost control of the other 2 children. Another passenger, who re-entered the 

burning aircraft, rescued one of those 2 children. The other lost child died after impact 

from toxic smoke inhalation (not from blunt trauma on impact). The NTSB found that a 

proper child restraint system would have prevented this fatal injury.

July 2, 1994 USAir DC-9-31 at Charlotte, NC 

37 fatalities, 16 serious injuries and 4 minor injuries.

On descent in heavy daytime rain, with thunderstorms and strong gusts, the crew 

descended through 200 AGL 0.6 miles out, then tried to initiate a go-around but flew into 

severe windshear and crashed half-mile out, a quarter-mile right of the extended runway. 

Of 57 occupants, 2 were lap-babies. Most fatally injured passengers were seated forward 

(all passengers in rows 3 through 10 sustained nonsurvivable blunt trauma on impact) and 

near or over the wing section (where fatalities were caused by thermal injury or carbon 

monoxide). All persons from rows 17 through 21 survived, except for a lap baby. That 

part of the aircraft sustained relatively minor deformation with survivable impact forces. 

However, the baby's parent lost control of the infant upon impact and the child died of 

blunt trauma. A proper child restraint system would have prevented this fatal injury.