Project CS 08/06 - CAO 20.16.3 amendment - No longer permit the carriage of two children in one seat and one harness in aircraft
This project is now closed.
28 Mar 2008
17 Mar 2008
This project has been approved and information is now available.
It is proposed that civil aviation order 20.16.3 paragraph 13.1 be removed. This provision allows the carriage of 2 children in one seat on aircraft, subject to certain conditions. The conditions address the design weight limit for the seat and restraint by lap belt. They do not mitigate a number of other safety risks posed by the provision.
UK CAA report 93013 "dual child occupancy of an aircraft seat" has provided evidence that dual occupants will suffer major injury during a serious but survivable accident. On the basis of this report and associated testing, a proposed JAA regulation to permit dual child occupancy was defeated. No other major national aviation authority permits the carriage of 2 occupants in one seat, other than the infant-on-lap provision.
Aircraft seats and restrains are now subject to TSOs. There is no current TSO which allows 2 occupants to be restrained in one seat and harness. TSO-C22g paragraph 3.1 mandates single occupancy in one harness. Earlier TSOs required a 3000lb rating for dual occupancy, where as the normal single occupancy restraint was rated to 1500lb.
As a standalone regulatory paragraph in an Order, the removal of paragraph 13.1 of CAO 20.16.3 would not require any other regulations to change. There are no implications for operators who do not use the provision. Operators who do use the provision would still be able to submit a safety case to request an exemption from certification and/or CAO 20.16.3 paragraph 3.1 requirements. Operators that are already using the provision will also be required to construct a safety case in order to be permitted to continue.
The current provision contradicts world best practice, conflicts with CASR Part 21 (Automatic acceptance of certification) and opposes engineering advice provided by a recognised aviation authority. There is also concern regarding the perception that the provision effectively 'rewards' operators who do not adhere to certificated standards.
Proposal to delete paragraph 13.1 of CAO 20.16.3 so as to no longer permit the carriage of two children in one seat and one harness on aircraft.
Civil aviation order 20.16.3 deletion of paragraph 13.1
Project cancelled on 28 March 2008.
Project approved by Acting Group General Manager, Air Transport Operations Group, on 5 March 2008.
Project Sponsor: Rob Wight
Project Leader: Rick Leeds
Email: Rick Leeds