Project CS 12/23 - Review of the carriage of Infants and Children in Aircraft
Project closed 20 October 2015.
Certification consideration complete - no changes to aircraft certification requirements are being proposed.
Unlike the restraint of adult occupants, the method of carrying infants and small children in aircraft has not really changed since the start of aviation. For other modes of transport, particularly motor vehicles, there have been great advances in the effectiveness of child restraint systems. Some advances that have occurred in aviation restraint have not been documented in CASA guidance material.
Aviation is a safe form of transport, however accidents do occur and aircraft are fitted with occupant protection devices. One societal view is that an equal level of protection should be offered to children and infants as that offered to adults. Research and accident history suggests injury is likely to be more severe for (restrained or unrestrained) lap-held infants and their nursing care-giver in any particular accident, than that to a properly restrained non-nursing adult.
Additionally, there is research evidence to suggest an infant or small child seated individually in an aircraft seat may not be appropriate. The overall risk however is mitigated somewhat by the lower participation rate of this passenger group in air travel.
Passengers in general and some aircraft operators are unaware of appropriate methods of restraint for small children. This is complicated by the fact that the appropriate method changes multiple times with the increasing size of the child. Some perceptions of safe restraint employed by operators have been proven by research to be inappropriate and dangerous. Sometimes these situations arise out of a lack of guidance material or by out-dated regulations.
Notice of Proposed Rule Making (NPRM) 9809RP -Proposed Regulations relating to Passenger and Crew Member Safety released in 1998, proposed, amongst a range of occupant restraint safety measures, that all occupants would have individual use of a seat. CASA received comments in support of the proposal but also received substantial comment against it based principally on economic and logistical arguments. Another problem with this proposal is that without also defining and requiring suitable restraints for infants (less than 2 or 3 years), an aircraft seat and seat belt/harness is not much more appropriate than being restrained on a nursing adult's lap.
CASA has been working with Standards Australia on the next revision of AS/NZS 1754 'Child restraint systems for use in motor vehicles'. The proposal is for manufacturers of forward and rearward facing automotive child restraints to include optional requirements that consider the fitment to aircraft. Proposed changes for inclusion in the standard include a dedicated dynamic test in an aircraft like test fixture, dimensional restrictions, and the prescription of fitting procedures on-board aircraft in the instruction booklet and on the child restraint itself. Manufacturers choosing to certify their automotive child restraint to the optional aviation criteria will be eligible to mark the child restraint and packaging with a decal indicating its acceptability for use in aircraft. The new standard is proposed to become effective in Quarter 4 of 2012 to Quarter 1 of 2013.
Additionally, new Aviation based child restraints have been developed and approved. CASA also knows of new built-in and add-on aviation specific child restraints that are in development. CAAP 235-2(1) needs revision to incorporate these developments.
A public review on contentious child restraint methods in aircraft and new technology availability is recommended. A dedicated and complete consultation will provide definition on the issue. As a result of this consultation, a proposal as to whether to revise regulations can be considered. Regardless, guidance material should be rewritten that appropriately reflects those (new or unchanged) regulations, provides industry with an improved level of guidance, and updates existing information particularly in relation to new products.
The following objectives will be done concurrently:
1. Generate a Discussion Paper (DP) seeking industry and public comment on the merits and current relevance of:
- CAO 20.16.3 Paragraph 13.1 that allows two children to sit in one seat, and
- CAO 20.16.3 Paragraph 13.2(1) with respect to lap-held children.
2. Generate a revision to CAAP 235-2(1) by providing updated and expanded guidance regarding the carriage of infants and children as required by CAO 20.16.3 Paragraph 13 (and the proposed CASR 91.600/605). The CAAP/AC should include guidance on:
the new AS/NZS 1754 standard and its relationship to aircraft use,
- availability of aviation based child restraints,
- children and airbags; and best practices, including:
- Restraint of children in aircraft seats,
- Fitment of AS/NZS 1754 Child restraints to the aircraft and their use in flight,
- Fitment of Aviation based restraints and their use in flight; and
- Detail any variation to guidance depending of the type and class of aircraft being used, i.e. transport category aeroplanes versus general aviation or rotorcraft.
This project was approved by Peter Boyd, Executive Manager Standards Division on 15 May 2012.
One project objective complete. CAAP 235-2 was revised and published on 20 Jan 2014.
CAO 20.16.3 and CAAP 235-2
Standards Consultative Committee (SCC)
|Consultation updates in 2015|
|Project CS 12/23 - Review of the carriage of Infants and Children in Aircraft||This project is now closed
Refer to the project closure notes for further information.
|20 Oct 2015|
|Consultation updates in 2014|
|DP 1301CS - Carriage of Infants and Children||Comment period now closed.||15 Sep 2014|
|DP 1301CS - Carriage of Infants and Children||Comments on this DP are to be forwarded to the Project Leader, Mark Bathie by close of business 11 September 2014.||14 Jul 2014|
|CAAP 235-2(2) - Carriage and restraint of small children in aircraft||This CAAP has been published.||20 Jan 2014|
|Consultation updates in 2013|
|DRAFT CAAP 235-2(2) – Carriage and restraint of small children in aircraft||Comments on the draft CAAP closed for comment 11 November 2013.||12 Nov 2013|
|DRAFT CAAP 235-2(2) – Carriage and restraint of small children in aircraft||Comments on this draft CAAP are to be forwarded to the Project Leader, Mark Bathie by close of business 11 November 2013.||28 Oct 2013|
|Consultation updates in 2012|
|Project CS 12/23 - Review of the carriage of Infants and Children in Aircraft||Project approved||18 May 2012|