FAA clarifies GA seat belt guidance

July 6, 2011

The FAA, responding to a request from the National Transportation Safety Board, has published notice of a proposed clarification of how it interprets seat-belt and seating requirements of the federal aviation regulations for general aviation. The document also emphasized that the proper method of restraint for children during flight relies on the operational knowledge and good judgment of the pilot.

The FAA’s prior guidance has stated that shared use of a single restraint may be permissible. Now it has proposed to clarify that interpretation with language stating “that the use of a seat belt and/or seat by more than one occupant is appropriate only if: The seat belt is approved and rated for such use; the structural strength requirements for the seat are not exceeded; and the seat usage conforms with the limitations contained in the approved portion of the Airplane Flight Manual. The proposed clarification also emphasizes that the proper restraint method for children during operations conducted under Part 91 relies on the good judgment of the pilot, who should be intimately aware of the capabilities and structural requirements of the aircraft that he or she is operating.”

The FAA noted in its filing that it continues to strongly advocate for the use of child restraints such as child safety seats for children who are within the weight restriction of the restraint. Whether a child “should be held, placed under a restraint or allowed to share a single restraint or seat with another occupant during Part 91 operations is a matter of prudent operating practice.” Members may comment on the proposed clarification of FAR 91.107(a)(3) until Aug. 22.

The trigger for the FAA’s effort to clarify previous interpretations of seat-belt and seating requirements for GA flights was the NTSB’s discussion of a March 22, 2009, crash of a PC-12/45 in Butte, Mont. The pilot and all 13 passengers—including seven children—were killed.

“The NTSB was unable to determine the original seating position for most of the occupants, but the bodies of four children, ages 3 to 9 years, were found farthest from the impact site, indicating that these children were likely thrown from the airplane because they were unrestrained or improperly restrained. The NTSB noted that if the accident had been less severe and the impact had been survivable, any unrestrained occupant or occupants sharing a single restraint system would have been at a much greater risk of injury or death,” the FAA said.

Members may submit comments under docket number FAA-2011-0628 by Aug. 22 online or by mail to Docket Operations, M-30; U.S. Department of Transportation, 1200 New Jersey Avenue, SE., West Building Ground Floor, Room W12-140, Washington, DC 20590-0001.

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