Flying with a Child Who Lacks Trunk Support – Equipment, Exemptions and Resources
Flying with any child requires a certain amount of planning; however flying with a child who uses a wheelchair and lacks trunk support requires a good deal of forethought, preparation and even special equipment. And although the task is manageable when children are small, as they grow it becomes even more challenging. That said, it’s difficult but not impossible. With that in mind here’s what you need to know to have a safe and comfortable trip.
Infants
Infants are pretty easy, as far as air travel is concerned. Basically you just need to bring along a Federal Aviation Association (FAA) approved Child Restraint System (CRS) – more commonly known as a car seat. It can be a forward or rear facing model, but it must have two FAA approved labels on it. One label must include the text, “This child restraint system conforms to all applicable federal motor vehicle safety standards”. The other label must include (in red) the text “This restraint is certified for use in motor vehicles and aircraft.” Alternatively, it’s acceptable to have the two labels merged into one if all the appropriate text is included.
Toddlers
As a child that lacks trunk support grows, parents have to explore other options. The FAA limits what type of seating devices may be brought aboard the aircraft, but many parents use neck pillows, towels and blankets to help support their children. Seating the child next to the window sometimes helps too, as they can lean on it for support. That said, you have to be careful with what you bring aboard, because unless it’s FAA-approved, any homemade device that straps to the seat or is too big and bulky will usually get the boot.
Another option is buy a first-class seat and physically help help the child maintain his balance during takeoff and landing. After that he can recline, and because of the extra room in first-class, the seat goes back further.
Additionally, the CARES Harness (www.kidsflysafe.com) may be an option for some children. This FAA-approved harness straps to the seat and can be used on children over one year old who weight between 22 and 44 pounds and are up to 40-inches tall.
A number of companies also offer FAA-approved CRS for toddlers. They all have height and weight limits, so it’s best to check the company’s website carefully for these restrictions. It’s also important to remember that in order to take any CRS on an airplane, it must be labeled that it is FAA approved for use on an aircraft. If a CRS does not have this label, it will not be accepted, even if the manufacturer says it’s approved. Labeling is extremely important.
It’s also a good idea to check for contradictions in the labeling. For example, one Convaid CRS that was labeled as FAA-approved, also included a label that stated it must always be used with a three-point restraint system. And since commercial aircraft do not have shoulder harnesses, that CRS was not allowed on board.
It’s also important to remember, that under FAA regulations, no carrier may prohibit a child (any passenger under 18) from using an approved CRS as long as they have purchased a seat, fall within the manufacturer’s height and weight limits for the CRS, and are accompanied by a parent or guardian. If the CRS does not fit in the assigned seat, it’s the carrier’s responsibility to reseat the child.
Older Children
As your child grows you may have to look for creative solutions. For example, when Avery Ottenbreit grew too large for her CARES Harness, her father filed for an FAA exemption. And he was granted one. (http://barrierfreetravels.com/2009/05/persistent-parent-wins-access-for-wheeler-child/).
Additionally you may want to consider if a non-approved device will work for your child. The Meru Travel Chair (meru.org.uk/what-we-do/travelchair/), which is manufactured in the UK, may work for some folks. Although not approved by the FAA, it has been approved by the European Aviation Safety Agency. Additionally, Virgin Atlantic uses this device. And the Meru Travel Chair has already received one FAA exemption.
If you want to use a Meru Travel Chair (or any other non-approved CRS), or if your child exceeds the height and weight limits for an approved CRS, you will need to file for an FAA exemption in order to use that device on an aircraft. For more information about how to file an exemption, visit https://www.faa.gov/regulations_policies/rulemaking/petition/.
If your exemption is granted, it’s good for five years and it’s valid on all US airlines. It typically takes about eight weeks to get an exemption, so start early. Additionally you don’t have to have any specific travel plans in place in order to file for an exemption, so there’s really no risk or out of pocket expense to go this route.
Sometimes it also helps to see granted exemptions, to know how to ask for something. To see Avery’s exemption for the CARES Harness, go to aes.faa.gov/ and type in 9834. You can also see an exemption for the Meru Travel Chair by entering 7831, and the E-Z-ON Vest by entering 8264. In the end, you just need to clearly and concisely describe your child’s disability, and include information on why a specific CRS or other device will meet their needs.
Once your child turns 18, they are considered an adult by the airlines. If they have an exemption in place, it should state when it will end. Most exemptions will carry over into adulthood if the child turns 18 before the exemption expires. After that, your child will need to apply for an exemption as an adult.
A Few Travel Tips
Again, these are FAA policies, so they only apply to US airlines. It’s also advisable to check with the airline in advance if you are traveling with a toddler or an older child who uses a CRS, as some small aircraft may not be able to accommodate a larger CRS. Additionally, some seating restrictions — such as no exit row seating — may apply to passengers who travel with a CRS. And it’s always a good idea to give the airline advance notice if you are traveling with an exemption, so there are no surprises or delays at the airport.
Regulations about flying with a CRS vary around the world. Some are more restrictive, while others are more liberal. As noted earlier, Virgin Atlantic is already using the Meru Travel Chair, which still lacks FAA approval. Copious research is needed for international travel. Never assume that policies will be the same overseas, as they are in the US.
Finally, if you experience unresolved issues about your CRS on a US airline or on flights to and from the US, contact the Complaints Resolution Official. This airline employee is specifically trained to resolved access-related issues, and all covered airlines must have a CRO available by phone or in person. The CRO can be your best ally. Read more about how to work with a CRO at emerginghorizons.com/access-in-the-skies-always-remember-the-cro/.
