Commercial and Business Aviation Advisory Circulars

Infant Passenger Count

POLICY STATEMENT

This Air Carrier Advisory Circular (ACAC) is intended to provide clarification to air operators regarding the inclusion of infants in the passenger count routinely conducted on board Canadian commercial aircraft.

APPLICABILITY

This ACAC applies to all those air operators operating under Subparts 604, 703, 704 and 705 of the Canadian Aviation Regulations (the regulations).

DEFINITIONS

The definition of "infant", as per the regulations, is "a person under two years of age."

The definition of "passenger", as per the regulations, is "a person, other than a crew member, who is carried on board an aircraft."

The definition of "occupant", as per The Concise Oxford Dictionary of the English Language, is "a person who occupies, resides in or is in a place, etc."

BACKGROUND

There appears to be confusion as to whether an infant is to be included in the passenger count conducted on board the aircraft.

Contributing factors may include, but are not limited to, any number of the following reasons for conducting the passenger count:

• operational procedures, e.g. weight and balance considerations, load control, etc;
  
  
• verification of coupon match with passenger count to ensure security;
  
  
• infants traveling free of charge, included on the parent’s or guardian’s ticket;
  
  
• compliance with regulatory requirements regarding the minimum number of required flight attendants on board an aircraft;
  
  
• compliance with regulatory requirements regarding the maximum number of occupants that may be carried on board an aircraft;
  
  
• compliance with regulatory requirements regarding the securing of an infant passenger;
  
  
• compliance with regulatory requirements regarding oxygen, life preservers, and survival equipment.

Securing the infant appears to confuse the issue of whether or not the infant is included in the passenger count. Infants can be secured by either of two methods as noted below. Paragraphs 605.26(1)(b) & (c) of the regulations state in part,

"(1) Where the pilot-in-command or the in-charge flight attendant directs that safety belts be fastened, every passenger who is not an infant shall ...

2. if responsible for an infant for which no child restraint system is provided, hold the infant securely in the passenger’s arms; and
   
   

3. if responsible for a person who is using a child restraint system, ensure that the person is properly secured."

When the infant is lap-held, secured in the arms of the parent or guardian passenger pursuant to paragraph 605.26(1)(b), he/she occupies the same seat as the parent or guardian passenger and therefore is considered one with the passenger. When restrained in a designated aircraft seat with the use of a child restraint system pursuant to paragraph 605.26(1)(c), the infant is occupying a seat apart from the parent or guardian passenger and therefore is considered a separate person from the parent or guardian passenger.

As a result, the particular seat an infant occupies and the purpose for the passenger count are key factors in determining when an infant is included in the passenger count.

Additional considerations are the regulations regarding lifevests, survival equipment, and oxygen dispensing units which refer to the requirements for each person on board the aircraft.

As an infant is a person on board the aircraft, these requirements apply to each infant carried, whether secured in the arms of a passenger or by way of a child restraint system.

POLICY

In order to ensure a consistent passenger count procedure for infants, the inclusion of infants in the passenger count conducted on board Canadian commercial aircraft is as follows:

• An infant secured in a lap-held position by a parent or guardian passenger is not counted as a passenger for purposes of determining the minimum number of flight attendants required on board an aircraft, and the maximum number of occupants authorized to be on board an aircraft. However, the infant is counted as a passenger for purposes of applying regulatory requirements such as those pertaining to oxygen, life preservers and survival equipment.
   
• An infant secured in a restraint system is counted as a passenger for purposes of determining the minimum number of flight attendants required on board an aircraft, determining the maximum number of occupants authorized to be on board an aircraft, and applying regulatory requirements such as those pertaining to oxygen, life preservers and survival equipment.

CONCLUSION

It is recommended that air operators ensure that their procedures for the passenger count include infants as detailed in this ACAC.

A.J. LaFlamme
Director
Commercial and Business Aviation