Cabin Safety Bulletin No. 5 - Seating allocation of disabled passengers
Who does this bulletin apply to?
This document applies to all operators of Australian registered aircraft and should be read in conjunction with Civil Aviation Order's 20.16.3. and 20.11.
What is the purpose of this bulletin?
The purpose of this document Is to provide guidance to operators on the seating requirement for passengers with a disability.
ICAO Annex 9 defines a person with disabilities as "any person whose mobility is reduced due to physical incapacity (sensory or locomotor), an intellectual deficiency, age, illness or any other cause of disability when using transport and whose situation needs special attention and the adaptation to the person's needs of the services made available to all passengers."
No two people are the same and this equally applies to people with a disability and each person has differing capabilities. Some disabled passengers may travel alone or with a carer, assistant or a travelling companion who provides aid and support the disabled passenger. Consideration needs to be given to the individual needs of the disabled passenger and how to best accommodate those needs while maintaining regulatory compliance.
Categories of passenger with reduced mobility
There are three broad categories of passengers with reduced mobility (PRMs) which identifies how passenger needs may vary:
- Various levels of physical disability (which may range from total dependence on a wheelchair to a slight walking difficulty). This category would include the IATA codes 'WCHR', 'WCHS', and 'WCHC'.
- The WCHC category includes a wide range of disabled passengers, from those whose disability affects only the lower limbs and who require assistance to embark, disembark and to move inside the aircraft, up to those who are completely immobile and require assistance at all times.
- Those with a sensory impairment (which may range from profound deafness or total blindness to some degree of vision loss or hearing loss); this category would include IATA codes 'Blind', 'Deaf' and 'Deaf/Blind'.
- Those with a cognitive impairment, learning disability or mental health problem that can range across a wide spectrum from total independence to high dependency on others. These would be encompassed by the IATA code 'DPNA'.
The extent to which people in any one of these three categories will need special assistance will also vary considerably according to the individual's needs, as well as the aircraft type and configuration.
Operators should ensure that the staff performing the checking in of disabled passengers are aware of and appropriately trained in the company's seating policy in relation to passengers with a disability. This may be the first opportunity an operator has to address an inappropriate seating allocation.
When accepting groups of passengers with a disability, the operator should assess each situation individually and determine how they can mitigate any identified safety risks to the individual and all passengers and crew on board.
Boarding of disabled passengers
Where it is practicable, consideration should be given to pre-boarding passengers with a disability (and their assistant if they are accompanied by one). Pre-boarding will allow the disabled passenger to settle into their seat, put away their in-cabin baggage and receive a predeparture briefing.
Disabled passenger briefings
A general safety briefing is given to all passengers prior to departure. This points out the location of the emergency exits and provides information on using life jackets, brace positions and oxygen masks.
Civil Aviation Order (CAO) 20.11 section 14.1.2 requires an individual briefing is provided to the person with the disability and their assistant.
The briefing should be appropriate to the needs of the disabled person in the event of an emergency evacuation of the aircraft. Ideally the person providing the briefing should be one of the crew designated to assist the person in an emergency evacuation. Tools such as braille books and safety demonstration equipment may be used to help deliver the individual briefing.
The briefing should include:
- which emergency exit to use and an alternative exit if the first exit is unavailable
- when to move towards the exit in an emergency evacuation
- how best to assist the person in an emergency evacuation.
The content of each briefing should be documented in the operator's operations manual. Additionally, the operator's cabin crew training programme should address the content and conduct of these briefings.
Regulations for seating disabled passengers
Civil Aviation Order 20.16.3 section 14.2 states that the operator and pilot in command of an aircraft must ensure that any person, due to sickness, injury or disability, is not seated where he or she could obstruct or hinder access to an emergency exit. The common interpretation is to exclude disabled passengers from seating in emergency exit row seat.
Emergency exit row seating
Emergency exit rows differ depending on the aircraft configuration. Operators are required to nominate their emergency exit rows in their operations manuals and ensure their crew are appropriately aware and trained in emergency exit row seating requirements. People who declare or are identified by the operator as suffering from a sickness, injury or have a disability that could obstruct or hinder access to an emergency exit are not permitted to be seated in an emergency exit row.
Non-exit row seating
In addition to the requirement not to seat disabled passengers in emergency exit rows, CAO 20.16.3 section 14.2 requires that these passengers need to be seated in a manner which would not hinder or obstruct access to emergency exits generally for all other passengers and crew. Passengers with a disability should be assessed on a case by case basis to determine the best seating allocation, ensuring there is no impact on the safety of the person or others on board.
This requirement becomes particularly relevant when seating passengers in narrow body aircraft.
Any decision by an operator to seat a passenger outboard (window or middle seat) of a person with a sickness, injury or disability seated inboard (aisle adjacent) needs to take into consideration the abilities and/or limitations of all passengers in that row. It is important to ensure that all passengers seated in the same row as the person with a disability do not have their ability to exit impeded by the person seated in the aisle seat. However, passengers travelling as an assistant to the disabled passenger may be seated next to the disabled passenger.
Operators are asked to review and consider their seating policy for disabled passengers to ensure that their seating policy complies with the requirements of CAO 20.16.3 Section 14.2 and where applicable ensure the policy is appropriately communicated and trained to the appropriate employees.
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If you have an inquiry please contact the cabin safety team on 131757 and ask to speak to a cabin safety inspector or email email@example.com.
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