Commercial and Business Aviation Advisory Circulars

Child Restraint Systems

INTRODUCTION

This Commercial and Business Aviation Advisory Circular (CBAAC) is intended to provide air operators with information regarding the use of child restraint systems on aircraft and recommended evacuation procedures for occupants of child restraint systems.

This revision provides clarification on child booster cushions and information regarding manufacturers who market their Child Restraint Systems as "Booster Seats".

This CBAAC replaces CBAAC 0128R dated 1999.03.12.

REFERENCES

Sections 101.01, 537.203, 605.25, 605.26 and 605.28 of the Canadian Aviation Regulations (CARs).

BACKGROUND

Child Restraint Systems were first permitted on board Canadian aircraft in 1990 by means of an Exemption to the former Air Navigation Order (ANO), Series II, No. 2. Information to assist air operators in developing procedures for the safe transportation of occupants using approved child restraint systems was provided by Passenger Safety Technical Directive No. 402.

Since that time, the CARs have been implemented and contain operational regulations pertaining to the safe transportation of occupants using approved child restraint systems.

DETAILS

Infant Restraint System - is an aft-facing restraint system that is generally restricted to an occupant weight of under 20 pounds. Weight restrictions are specified on the system and can vary from one system to another. Infant Restraint Systems are certified to Canadian Motor Vehicle Safety Standard (CMVSS) 213.1.

Child Restraint System - is a forward-facing restraint system that is generally restricted to an occupant weight of 20 to 40 pounds. However, some systems can accommodate occupants of a greater weight. Weight restrictions are specified on the system and can vary from one system to another. Child Restraint Systems are certified to CMVSS 213.

Convertible Restraint System - the term "convertible" is often used by manufacturers to describe restraint systems which can be used as an aft-facing system for infants and as a forward-facing system for children. These restraint systems are certified to both CMVSS 213 and 213.1.

Labelling Requirements - restraint systems which are manufactured or sold in Canada must be affixed with a Statement of Compliance label which states that the system has been certified to CMVSS 213 or 213.1 and indicate the date of manufacture as being after January 1, 1981.

Seats manufactured to US standards between January 1, 1981, and February 25, 1985, must bear the label: "This child restraint system conforms to all applicable Federal Motor Vehicle Safety Standards."

Seats manufactured to US standards on or after February 26, 1985, must bear two labels:

1. "This child restraint system conforms to all applicable Federal Motor Vehicle Safety Standards"; and
   
   
2. "THIS RESTRAINT IS CERTIFIED FOR USE IN MOTOR VEHICLES AND AIRCRAFT" in red lettering.

In the United States, regulations require a separate label certifying the device for use in aircraft, as American manufacturers are only required to conduct an inversion test if the manufacturer wants to certify the device for aircraft use. Canadian manufactured child restraint systems do not require a separate label stating certification for use in aircraft as it is a requirement for all devices to successfully complete an inversion test.

Booster Cushions - these devices are used for older children who have outgrown their child restraint system. These devices are not approved for use in an aircraft as they do not meet the inversion testing provisions of the CMVSS and must be used with an automobile lap and shoulder belt. Booster Cushions are certified to CMVSS 213.2.

"Booster Seat" - this is a term commonly used by manufacturers to describe both Child Restraint Systems and Booster Cushions. In order to be acceptable for use in an aircraft, all of the child restraint system labelling requirements must be met.

Combination Systems - some manufacturers are marketing a system which is a combination Child Restraint System and Booster Cushion. When used as a Child Restraint System, it will include an internal harness system. The internal harness system must be installed and all child restraint system labelling requirements must be met to be acceptable for use in an aircraft.

When used as a booster cushion, the internal harness system is removed and it is not approved for use in an aircraft. Combination Systems are certified to CMVSS 213 and 213.2.

Child Vests or Harnesses - these devices are not approved for use in an aircraft.

"Snugli" ™ - is a trade name for an infant carrier that consists of a pouch which holds the infant close to the wearer’s body. These carriers are not approved for use as a restraint system in an aircraft. Other similar-type carriers are also not approved for use as a restraint system in an aircraft.

Note: The Snugli ™ manufacturer’s packaging box bears a caution which states "This carrier is not meant for holding infants in motor vehicles and should not be used in place of a car seat that meets Federal Motor Vehicle Safety Standards".

"Belly" or "Loop" Belt - is a belt for infant use which is attached to an adult’s safety belt by feeding the adult’s belt segments through a loop on the infant’s belt. The adult’s belt segments are then fastened together, the infant placed on the adult’s lap, and the infant’s belt is then fastened around the infant. This device is not approved for use in an aircraft.

Carry-on Baggage Control Programs and Child Restraint Systems - Transport Canada does not consider a child restraint system to be carry-on baggage when the device is carried on the aircraft as a means of restraining an occupant.

However, if the intended occupant does not occupy the device and the device has to be stowed, then it is considered to be carry-on baggage and must fall within the parameters of the air operator’s approved carry-on baggage control program.

PROCEDURES

Emergency Evacuation Procedures

When establishing emergency evacuation procedures respecting the use of child restraint systems, Transport Canada recommends that the air operator include the following:

• the occupant of the system should not be removed from the restraint system during preparation for an emergency landing;
• the occupant of a child restraint system should be braced in accordance with the instructions of the manufacturer of the restraint system, when such instructions are provided; and
• during an evacuation, the restraint system should remain installed in the passenger seat and only the occupant should be removed from the aircraft.

CONCLUSION

This CBAAC provides clarification and information regarding the use of child restraint systems on aircraft and advises air operators of recommended evacuation procedures to take into consideration.

M.R. Preuss
Director
Commercial & Business Aviation