AC 120-87A

Historical

Advisory circular · Use of Child Restraint Systems on Aircraft

A newer version is currentThis is a historical version. AC 120-87C is the version in force, approved September 24, 2015.
Approved
December 1, 2006
Last reviewed
August 22, 2024
Cancels
AC120-87
Cancelled by
AC120-87B
Family
AC 120-87 · 4 versions
Revision
A
14 CFR parts
21, 91, 121, 125, 135

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 22, 2025.

Show pages 1–12

is installed underneath the tray table, then this seat back design will not allow the tray table to be properly secured during ground movement, takeoff and landing. In this case, the strap must be placed completely over both the seat back and stowed tray table during these phases of aircraft operation.

19. TRAVELING WITH MORE THAN ONE CHILD. In the event a parent/guardian is traveling with more than one child in CRSs or is traveling with several small children, only one of whom is occupying a CRS, good judgment should be used regarding placement of the CRSs.

As long as these conditions below are met, the CRS could be placed in a seat other than a window seat. At a minimum:

• The CRS should be placed so it does not block any passenger’s (including the parent/guardian’s) egress to the aisle used to evacuate the aircraft

• The CRS should be placed so the parent/guardian can reach the child in the CRS to release and evacuate with the child, should an emergency evacuation be necessary

20. RESPONSIBILITY FOR ENSURING THE PROPER USE OF CRS. If the approved CRS is supplied by the parent or guardian, typically he or she will check to ensure the CRS is approved, the child is the right size and weight for the CRS, and the CRS is properly installed in a forward-facing passenger seat. However, aircraft operators still have overall responsibility to ensure the CRS is properly secured to a forward-facing seat, the child is properly secured in the CRS and does not exceed the weight limit for the CRS, and that the CRS bears appropriate labels or markings (§ 121.311(b)(2)(iii); http://www.gpoaccess.gov/ecfr).

21. EFFECTIVE PRACTICES THAT AN AIRCRAFT OPERATOR MAY CONSIDER IN ITS PROGRAM. Effective practices can include:

• The aircraft operator’s training program and crewmember operating manuals should contain information, policy, and procedures regarding CRS use

• The CRS should be secured to a regular passenger seat at all times or, if not in use, stowed as carry-on baggage

• The child should always be properly secured in the CRS whenever other passengers are required to fasten their seatbelts

22. FAA INTENT REGARDING THE AGE OF AN “ADULT” AS FOUND IN SECTION 121.311. The word “adult,” as it appears in § 121.311, is used in the ordinary sense of the word to denote a person 18 years of age or older (http://www.faa.gov/safety/programs_initiatives/aircraft_aviation/cabin_safety/regs/legal/).

23. CONSIDERATIONS REGARDING THE USE OF AN APPROVED CRS FOR A CHILD WITH DISABILITIES. The majority of individuals using CRSs on aircraft are young children typically weighing 40 pounds or less. However, there are some people who, because of physical challenges, need the support and security a restraint system provides in order to travel Par 18 Page 13

safely on aircraft. Aircraft operators should ensure flight attendants are aware that older children (who have not reached their eighteenth birthday) may use a properly approved CRS appropriate for that child’s size and weight. In this case, the aircraft operator may not prohibit the use of the CRS. There are several companies manufacturing CRSs approved for use on aircraft specifically designed for larger children who are physically challenged.

24. CONSIDERATIONS REGARDING THE USE OF A NON-APPROVED CRS FOR A

CHILD, OR A NON-APPROVED RESTRAINT SYSTEM FOR AN ADULT WITH DISABILITIES. In the case of a person who, because of physical challenges, needs the support and security a non-approved CRS or restraint system provides in order to travel safely on aircraft, the individual, his or her guardian, or the aircraft operator (on the individual’s behalf) may request an exemption to certain operating rules addressing the use of CRS on aircraft. Upon application, the FAA will determine whether the exemption request will be granted in order to allow the use of any non-approved restraint systems during all phases of flight. While not required, it has been found to be an effective practice for the individual or the parent/guardian to have a copy of the grant of exemption available for aircraft operator review when using a nonapproved CRS or restraint system on aircraft. See paragraph 25 for information on requesting an exemption.

25. HOW A PETITION FOR EXEMPTION IS SUBMITTED. To find out how to submit a petition for exemption, visit http://www.faa.gov/regulations_policies/rulemaking/petition/.

Exemption information is also available for review on the DOT Docket Management System Web site. To review previously granted exemptions regarding the use of restraint systems, visit http://dms.dot.gov/. To view previously granted exemptions regarding the use of specialized restraint for adults, type “12485,” or “9364” in the blank “Docket Search” field. To view previously granted exemptions regarding the use of non-approved restraint for children, type “17184,” “29824,” or “28630” in the blank “Docket Search” field.

26. IMPROVING EMERGENCY EVACUATION CAPABILITIES WHEN A CHILD IS USING A CRS. To improve emergency evacuation capabilities, the CRS should remain attached to the passenger seat during an emergency evacuation, and only the child should be removed from the aircraft. Researchers from CAMI, AAM-600, have completed two studies designed to determine the most favorable methods for the emergency evacuation of infants from aircraft. All CAMI Aerospace Medicine Technical Reports can be found at:

http://www.faa.gov/library/reports/medical/oamtechreports/.

a. The purpose of the first study, DOT/FAA/AM-01/18, was to determine the most favorable methods for the evacuation of infants via an inflatable emergency evacuation slide. The results of this study strongly suggest that jumping onto the slide should be the favored boarding maneuver, as opposed to sitting down and sliding which slows the progress of the evacuation.

The carrying position that provides the most protection for the child would include cradling the child’s head and neck with the hand (for a vertical position) or in the arm (for horizontal positions), keeping the child’s arms, legs and feet enfolded as much as possible by the adult’s arms.

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b. The purpose of the second study, DOT/FAA/AM-05/02, was to determine the most favorable methods for evacuation of infants through a Type III overwing exit. The results of this study suggest that carrying the infant vertically should be the favored egress maneuver through the Type III exit, as opposed to carrying the child horizontally or passing the child to another passenger on the outside of the Type III exit.

ORIGINAL SIGNED BY John M. Allen for James J. Ballough Director, Flight Standards Service Par 26 Page 15