Commercial and Business Aviation Advisory Circulars

Compliance with Regulatory Requirements Respecting Infant Life Preservers

INTRODUCTION

This Commercial and Business Aviation Advisory Circular (CBAAC) is intended to inform operators that the Director General, Civil Aviation has reissued a global exemption from subsection 602.62(4) of the Canadian Aviation Regulations (CARs). The exemption allows operators operating with flight attendants under subparts 604 and 705 of the CARs to stow infant life preservers in a bulk stowage location that is easily accessible to the flight attendant(s). The flight attendant(s) will provide an infant life preserver to each person responsible for an infant when preparing for a ditching.

This CBAAC replaces CBAAC 0204 dated 2002.05.01.

Subsection 602.62(4) of the CARs states "For aircraft other than balloons, every life preserver, individual flotation device and personal flotation device referred to in this section shall be stowed in a position that is easily accessible to the person for whose use it is provided, when that person is seated".

An infant is considered a person and therefore, life preservers for infants must also be easily accessible.

To comply with this subsection, some air operators are distributing infant life preservers to the adult responsible for the infant prior to every take off. This can result in theft and damage to life preservers. As well, this practice does not ensure proper stowage of the life preserver within easy reach of the infant unless the operator modifies its aircraft cabin to accommodate these additional life preservers. This modification can be costly.

Prior to CARs implementation, an aircraft operating with flight attendants required infant life preservers to be easily accessible to the flight attendant.

Air operators operating with flight attendants under subpart 705 of the CARs have proposed that the stowage of life preservers for infants be located in a bulk location on the aircraft where flight attendants can easily access and distribute these life preservers to the adult(s) responsible for the infant(s) during the preparation steps for a ditching.

As per subsections 602.62(1), (2) and (3) of the CARs, life preservers are required on board aircraft to address those emergencies where a ditching is likely to occur. This type of emergency would normally provide time for the flight attendant(s) to prepare the cabin and distribute life preservers to the infant(s). These emergency procedures are approved by Transport Canada.

Subsection 602.62(4) of the CARs was introduced to ensure compliance of floatplane operators that were previously stowing life preservers in cargo compartments or other areas that were not easily accessible. It was not intended to include life preservers for infants on flights operating with flight attendants.

The Director General, Civil Aviation has reissued an exemption (copy attached) exempting operators operating under subparts 604 and 705 from the regulatory requirement to stow infant life preservers in a position that is easily accessible to the person for whose use it is provided, and allowing the stowage of the infant life preservers in a bulk location that is easily accessible to the flight attendant(s). The flight attendant(s) will provide an infant life preserver to each person responsible for an infant when preparing for a ditching. The exemption is granted where conditions identified in the exemption are complied with.

FUTURE DISPOSITION

A Notice of Proposed Amendment to permit the stowage of the infant life preservers in a bulk location that is easily accessible to the flight attendant(s) was presented to the Canadian Aviation Regulation Advisory Council (CARAC) in 2003. The amendment will be published in a future revision to the CARs.

This CBAAC informs operators of the exemption from subsection 602.62(4) of the CARs that has been reissued by the Director General, Civil Aviation.

Michel Gaudreau
Director
Commercial & Business Aviation