Mandating child restraint systems in commercial aircraft

Transport Canada is conducting a review to consider the risks and benefits of making Child Restraint Systems (CRS), such as car seats, mandatory on board commercial flights for children under 2 years old. This document provides background information and history of the issue, and aims to invite stakeholder and public feedback.

Background

Seats and lap belts on board today’s commercial aircraft are not well suited to safely restrain infants or children under a certain weight and/or height. Adults travelling with an infant or child may choose to restrain them in a CRS such as car seats designed for use on board an aircraft. Although not mandatory, their use has been permitted in Canada since 1990.

After a landing accident at the Sanikiluaq airport in Nunavut in December of 2012, in which a lap-held infant died, the Transportation Safety Board’s June 2015 report recommended that Transport Canada work with industry to:

  • Develop age and size appropriate CRS for infants and young children travelling on commercial aircraft, and
  • Require their use to provide a level of safety comparable to that of adults.

In September 2015, Transport Canada said it would explore ways to increase the types of CRS it approves for use on Canadian commercial aircraft. The department issued a national exemption to give travelers a range of options for restraint systems they can use for infants and children when flying within Canada and abroad in the same trip. Transport Canada also launched an awareness campaign aimed at the aviation industry so carriers would inform ground agents, crew members and the travelling public about ways to keep children and infants safe during flight.

Considerations

In 1994, the Federal Aviation Administration (FAA) published a study “The Performance of Child Restraint Devices in Transport Airplane Seats”. It affirmed:

  • Adults cannot always properly restrain children in their laps by holding onto them
  • The regular adult seat belt does not properly restrain a child
  • Infants could be injured when they are seated on an adult’s lap

The Australian Transportation Safety Board and European Aviation Safety Agency produced similar findings in their studies on the issue.

Transport Canada used the results of these studies as the basis for allowing for CRS labeled for use in Canada. For more info, please see Taking children on a plane.

Relevant accident statistics

Over the last 30 years, there have been four aircraft accidents in Canada and the United States where a requirement to use car seats may have prevented five infant deaths, or increased their chance to survive and one incident where a 3 year old in a CRS was the sole survivor in the plane crash.

Commercial aviation accidents and fatalities in Canada and United States (1987 – 2017)

Canada United States
Total amount of accidents 269 2556
Total amount of fatal accidents 86 397
Fatal accidents where a CRS may have helped 1 (0.0037%) 3 (0.0075%)
Total fatalities 510 3452
Total infant fatalities (based on Total Fatalities) 1 (0.0019 %) 3 (0.0008 %)

Canada has one of the best aviation safety records in the world. Our average fatal accident rate was 0.61 per 100,000 aircraft movements within the last decade. This record is built on many levels, starting from well-established regulations, improved technologies, safer designs, thorough flight crew training and dozens of other operational requirements that focus on making aviation safer.

Examination – potential unintended consequence of mandating

Following the accident at the Sanikiluaq airport, Transport Canada conducted a comprehensive examination of mandating Child Restraint Systems and found that:

  • There is very low probability of an infant death on a commercial aircraft in Canada, measured at 1 fatality per 646,558,889 passenger boardings (2012-2016).
  • Making car seats a requirement when flying could raise air fare prices by 45% according to an FAA study. In Canada, this would affect just under 4 million families with small children. Because family travel is among the most price sensitive, families would choose to drive to their destination rather than pay for a seat for their young child to be in a mandatory aircraft CRS.
  • Parents choosing to drive would add 164 million more vehicle kilometers of highway travel per year on Canadian roads. This would translate into at least 10 premature highway deaths in the next decade in Canada, but might save one infant life by air.

International policy comparisons

The International Civil Aviation Organization, a specialized agency of the United Nations, has not set an international standard requiring the use of car seats for infants or children. It has, however, adopted the position that the safest way for an infant or child to travel on an aircraft is in the right sized, State-approved car seat for the infant or child, in a dedicated seat.

The United States determined that a policy for CRS on commercial airlines would result in a shift by the public in the mode of transportation they take when travelling, increasing their risk of serious injury or death.

The European Aviation Safety Agency - Since 2008, the European Union law says that children under 2 years of age must be secured by an approved CRS when flying with European Union airlines. This can either be a child seat or a 'loop belt', which is attached to the seat belt of the adult who is holding the child on his/her lap.

The Civil Aviation Authority of New Zealand is re-examining how best to secure babies and children during flight, following research by the International Civil Aviation Organization. New Zealand’s current Civil Aviation Rules require that, as a minimum, a child under 2 is held by an adult, and secured by a safety belt attached to the adult’s safety belt (Supplemental Loop Belt). The Civil Aviation Authority of New Zealand also notes that international crash studies indicate that there are safer options than the Supplemental Loop Belt in the event of severe turbulence, or an accident and that ideally children should be in a seat of their own, held in an approved restraint.

Consultation

Transport Canada is inviting Canadians to share their comments until April 30, 2018.

Interested parties are encouraged to register and participate in the online engagement discussion forum Let’s Talk Car Seats on Planes.

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