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Advisory Group Punts on ‘Lap Children’ in Airliners

Sat, Jan 29, 2011 — David Evans

Articles, Featured

For a toothless and feel-good safety recommendation, look no further than the recent recommendation submitted by an advisory panel to Transportation Secretary Ray LaHood, to the effect that more education is needed to educate the flying public about the dangers of flying with lap children.

The Future of Aviation Advisory Committee (FAAC) submitted 23 recommendations 15 December 2010 on the future challenges facing the airline industry. These findings are covered separately (see Aviation Safety Journal, “Safety Recommendations Fall Short”). The last recommendation, number 23, is the shortest and has the look of an afterthought; maybe it was added after the National Transportation Safety Board (NTSB) held a public forum 9 December 2010 on child passenger safety in airplanes and automobiles. The NTSB took the occasion to once again to call for an end to the dangerous practice of “lap children” in airliners.

The FAAC language at least held out the hope for regulatory action to end the practice of lap children, but the specific wording of its recommendation was awfully weak:

“The Secretary [of Transportation] should:

1. Utilize the full resources of his office to continuously educate the flying public about the dangers of flying with lap children.

2. Update the economic and safety data concerning families travelling with small children, including incidents and accidents involving injuries and deaths [and]

3. Based on the information provided by these finding, the Secretary should take necessary action, which may include a rulemaking or other appropriate next steps.”

The giveaway words here are “may include a rulemaking.” As written, it is just as likely the Secretary of Transportation will cave to airline industry pressure and may not institute rulemaking. The words “or other appropriate next steps” are imprecise and just guarantee that the whole subject of lap children will be dragged to oblivion.

The FAAC could just as easily — and with thorough documentation to make its case — recommended:

“Given the inherent dangers of unrestrained lap children, the Secretary should institute rulemaking within three months, with the intent of ending this hazardous practice within 18 months of publishing the Notice of Proposed Rulemaking (NPRM).”

In response to an NTSB recommendation, the Federal Aviation Administration (FAA) published in the Federal Register in 1998 an Advanced Notice of Proposed Rulemaking (ANPRM) proposing that all lap children would have to be restrained in a separate safety seat (not an adult’s lap), fitted and fixed in the adult-size passenger seat. Of the 6,000 public comments submitted in response to that ANPRM, about 95% were overwhelmingly positive.

Here are four comments typical of the support for infant safety seats:

— Joseph Zanga, M.D., president, American Academy of Pediatrics:

“On behalf of 53,000 primary care pediatricians, pediatric medical specialists, and pediatric surgical specialists … all children should be properly restrained.”

— Kathleen Weber, director, child passenger protection research program, University of Michigan:

“I have worked in the field of child occupant protection for nearly 20 years and have always found the FAA policy of exempting children under two years old from impact and turbulence protection to be unsupportable …”

— Francis Wokes, cabin safety standards, Transport Canada:

“Passenger injuries regarding the use of child restraints on board aircraft are directed to my office. It is worthy to note that in the last 5 years there have been numerous passengers who have contacted this office in an attempt to obtain more information about how they can ensure their infant’s safety, and not one single one wanting to hold their infants.”

— Phyllis Ohlemacher, a member of the public:

“I find it aggravating to sit next to an embarrassed parent holding a squirming child for several hours. Help the parents do the right thing by requiring them to buy a seat! I don’t even have to mention the safety aspects – babies can’t even come home from the hospital unless they are in a child seat. This should have been the law on airplanes many years ago.”

Nevertheless, the FAA ended its rulemaking venture, withdrawing the ANPRM in 2005. The FAA argued that requiring parents to purchase a ticket for their infants would discourage them from flying and force families to drive, which is a more hazardous form of transportation. The FAA nicely muddied the waters by equating a private form of transportation (automobiles) with a highly regulated form of public transport (airline travel) where the FAA is in a position to oversee application of its rule among individual airlines. The NTSB removed its “Most Wanted” recommendation for child restraints as a result of the FAA’s unwillingness to move forward with rulemaking.

The latest recommendation from the FAAC perpetuates the do-nothing approach.

NTSB Chairman Deborah Hersman issued a statement the same day the FAAC report was released, indicating her disappointment with the weak recommendation:

“We appreciate the FAAC acknowledging the dangers associated with children flying on their parents’ laps, but we would have preferred to see the FAA be mandated to require that every person including our youngest children be restrained appropriately for their age and size. We know that the safest place for children younger than age two traveling on airplanes is in an appropriate child safety seat. The era of the lap child on airplanes should come to an end.”

Herman’s statement was a laudable exercise in restraint, given that the NTSB has investigated a number of cases where lap children were injured or killed, had included child restraints in its “Most Wanted” safety recommendations, and was frustrated by the FAA’s unresponsiveness to its recommendation to have infants properly restrained, as the FAA requires on takeoff, landing, turbulence, etc. of galley coffee pots and laptop computers.

By ending the vulnerability of lap children, the NTSB was seeking to protect the littlest, most defenseless passengers just as adults in their lap belts. (See Hersman’s opening statement at the child passenger forum, Aviation Safety Journal, “Child Safety Is Needed – Not a Statistical Stalemate on Diversion”)

In the sudden and high G-forces of a runway overrun, inflight turbulence, or a crash landing, parents holding the infants will find them ripped from their arms and hurled to their injury or death. The sudden G-forces are too strong to be countered by a determined grip. Moreover, a lap child who is fortuitously held in place is likely to suffer serious crushing injury as the belted adult lurches forward and strikes the seat back in front of him or her. For these reasons, some airlines recommend placing lap children on the floor in the moments before impact – a practice that practically guarantees that these infants will, under the forces of deceleration, quickly slip out of their parents’ grasp and become little cartwheeling flying missiles inside the cabin – dangerous to themselves and others.

Significantly, of the four types of restraint now used in jetliners, infants are not required to have a junior version of any of them:

5-point restraints: for the pilots only, these restraints consist of a lap belt, two shoulder belts, and a crotch strap to ensure that the wearer remains properly seated (e.g., does not “tunnel under” the lap belt. The 5 points are the mountings for the lap belt (2), the mountings for the shoulder belts (2), and the mounting for the crotch strap (1). This restraint system, or the 4-point system described immediately below, is found in infant restraint seats used in automobiles.

4-point restraints: these consist of the lap belt and left/right shoulder belts; they are typically found on flight attendant jump seats.

3-point restraints: consisting of a lap and single shoulder belt (like an automobile), these restraints are found on a limited number of first and business-class seats where the occupant must be protected from obstacles ahead that, without the shoulder belt, would be struck.

2-point restraints: the lap belt for passengers.

Lap children have no restraints, and parents in accidents/incidents have been horrified to see their infants hurled out of their arms and to certain injury.

NTSB forum logo

NTSB forum logo

At the 9 December forum on child restraints, Patricia Friend, president of the Association of Flight Attendants (AFA), gave an impassioned plea for action:

“On the aircraft, flight attendants make multiple announcements to passengers regarding compliance with safety standards in preparation for the ‘unexpected.’ We are required to secure all items in the cabin, galley and lavatories, from carry-on bags to coffee pots, to comply with federal regulations intended to ensure safety in an emergency, when loose items can become missiles. In fact, an unsecured lap child is one of those ‘loose items’ that may not only suffer serious injury, but may also injure others. Flight attendants should not have to look a parent in the eye and instruct them to continue to hold the lap child when we know there is a very real possibility that child may not survive an emergency landing without proper restraints. And yet our members have had to do this.

“There were two airplane accidents in which children died that began to focus AFA on the necessity for child restraint systems [CRS]. United Airlines flight 232, en route from Denver to Chicago on July 19, 1989, experienced a loss of hydraulic pressure. At the time of the accident the crash-landing brace position at United Airlines for lap children was to have parents place their small children on the floor at their feet and hold them there while the parents assumed the protective brace position. One child died of asphyxia secondary to smoke inhalation. Five years later, on July 2, 1994, another child died on US Airways flight 1016. Investigative reports filed for both of these accidents described the difficulties faced by parents and their inability to hold onto their children.

“These two accidents should be reason enough to require the use of CRS for all small children traveling on commercial airplanes. However, the aftermath of an aviation accident isn’t our only concern regarding child safety. In preparation for this forum, we surveyed our flight attendant members to find out what was actually happening in the cabin regarding lap children and the use of child restraint systems. Just over 600 flight attendants completed the survey …

“One consistent response from our members: If a CRS did not have a placard approving it for use aboard aircraft, or if it was a booster seat without a hard back and internal restraint, then the use of the CRS was not allowed. However, with respect to all other questions regarding carrier policies, procedures and training related to lap children and CRS, survey responses were confused and contradictory … as seen in the data for two questions summarized in this slide:

afa-survey

“Also apparent from the survey … was frustration among the more than half of survey respondents who feel they are either not allowed to question parents about a child’s age, or not encouraged by their employer to ask the age of the child even when the flight attendant suspects the lap child is above 24 months of age …

“One member who responded to our survey summed it up quite nicely:

‘Some lap children are as big as any 4 year old. It’s tricky because I have to tell some passengers that they cannot hold their laptop [computer] on their lap, however a … wiggly, 20 lb human is allowed.’

“This inconsistent application of safety standards occurs because federal regulations do not require parents show proof of, or airlines otherwise verify, a lap child’s age …

“The FAA has contended and continues to argue that if airlines were to require the purchase of a seat and the use of a child restraint system people who would otherwise fly would use cars. Since highway travel is inherently less safe than air travel, they argue, such a shift would result in the loss of additional lives on the nation’s highways. As AFA has said in the past, this is a flawed, unproven argument …

“With no change in the regulations, no matter how much education the public receives … one level of safety is still not afforded to our most precious passengers, children traveling in laps.”

At least one foreign airline has taken steps to properly secure infants and small children. Since at least 1999, Virgin Atlantic Airways has provided restraint seats for small children. According to Mary Gooding, cabin safety officer for the airline, parents of small children are offered fares that are 50% to 75% of the adult fare so their infants and small children can have a seat of their own. The amount of discount depends upon the destination and fare. These adult seats are then fitted, before boarding, with either a forward or rear facing CRS provided by the airline. Parents who show up at the airport with an automobile safety seat will have it consigned to checked baggage at no charge.

va

Virgin uses its own CRS specifically designed for use in aircraft seats. Cabin crews are trained in their correct installation and use. According to Gooding, three CRS are carried on board every B747 and two on every A340.

va2

The seats are deep cleaned every 8 weeks unless reported soiled in a shorter timeframe by the cabin crew in the Cabin Defects Log.

In October 2010, more than 1,000 of the CRS were used on Virgin’s fleet of 12 B747s and 23 A340s.  On Virgin’s A340-600, aircraft certified “infant cradles” are also available for use during turbulence.

Infant cradles are available on Virgin's A340-600s

Infant cradles are available on Virgin's A340-600s

Lawrence Decina, who also spoke at the NTSB child passenger forum, is a child passenger researcher at TransAnalytics of Quakerton, PA. “We want kids in their planes in their own [safety] seats,” he said. He ticked off at least four reasons for doing so:

1. A CRS is used for the ride to and from the airport.

2. The CRS means the infant/child is secure during turbulence.

3. The infant/child is more comfortable on the plane in a familiar seat.

4. The infant/child behavior on the plane is better.

Hersman was right to call attention to the weak recommendation from the Future of Aviation Advisory Committee, which has really punted on the matter of child safety on airliners – despite its charter to ensure safety in aviation. Given the laudable can-do example provided by Virgin Atlantic, one hopes Transportation Secretary LaHood will demand, nay require, airlines to figure out how to safely transport infants and small children. In the arms of a parent is not safe; only a child restraint system will do.


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