| Allow Carriers on Planes | September 8th, 2026 | \n| | airplanes ,kids ,policy |
\nIn fact, one specific place where I'd like to see this thinking\napplied is adjacent to this rule: babywearing carriers on planes. When our\nbabies were little, carriers were massively helpful\nin flying. The baby likes it, and your arms are free. But for\ntakeoff and landing, the FAA requires you to take your baby out of the\ncarrier and hold them in your arms.
\nThe rule is that if an under-two is going to ride on a lap, they must\nnot "occupy or use any restraining device," (14\nCFR 121.311.b.1) and FAA\nguidance to parents is clear: "Baby carriers ...are not allowed to\nbe used during ground movement, take-off, or landing."
\nThis goes back to 1995, and if you look at the notice\nof proposed rulemaking it says:
\nThis notice proposes to withdraw FAA approval for the use\nof booster seats and vest- and harness-type child restraint systems in\naircraft during takeoff, landing, and movement on the surface. ... The\nFAA believes that, during an aircraft crash, the banned devices may\nput children in a potentially worse situation than the allowable\nalternatives.
\nThis is based on their 1994\nstudy, where the FAA compared child restraint options. They\nlooked at "booster seats, forward facing carriers, aft facing\ncarriers, a harness device, a belly belt, and passenger seat lap\nbelts." The "carriers" here are car seats; they didn't test\nbabywearing carriers. I don't think that's a major flaw in the study,\nhowever, since I do expect babywearing carriers would have performed\npoorly. [1] The real problem is that they didn't test the most common\nalternative, holding the baby in your lap. So "may put children in a\npotentially worse situation than the allowable alternatives" seems\nclearly wrong to me.
\nIn the 1996 final\nrule [2] they discuss why they're making a different decision than\nthe UK (CAA) and Europe (JAA, predates EASA), and they avoid the\nobvious comparison. They say belly belts can be dangerous,\nacknowledge that lap-holding has risks, predict parents will buy a\nsecond seat, and then also say they don't want to require a second\nseat because people will drive. This isn't completely nuts, since\nit's possible that allowing belly belts would have caused some parents\nto choose them over a second seat. It's pretty unlikely for the\neffects to balance out in just this way, however, and I don't see any\nindication that they tried to do this balancing.
\nI expect that, if fairly evaluated, modern babywearing carriers would\nprove much safer than arms during turbulence, crashes, and\nevacuations. And I think this is likely enough that if we're not\ngoing to do these tests we should default to not banning\ncarriers. In 2024 there was a bill proposing to do something like\nthis (Rep Bill Posey's HR\n8972), but it went to the aviation subcommittee and died without a\nvote.
\nI don't think the harm of the current rule is very large in the scheme of things: flying is very safe, even for unrestrained lap infants. Most of the harm is probably the inconvenience of waking happily sleeping babies. Still, it bugs me as a clear example of incoherent rulemaking. The FAA sensibly considered substitution behavior in deciding not to ban lap infants, but failed to balance it here.
\n[1] The closest thing to a carrier they tested was a 'belly belt':\n"This belt is designed to be buckled around the child's abdomen and is\nsecured to an adult's abdomen with the adult's safety belt by routing\nthe safety belt through a small loop of webbing sewn on the belly\nbelt." They did not perform well: "In the test, these systems allowed\nthe anthropomorphic test dummy to make severe contact with the back of\nthe seat in the row in front of the test dummy. The child also may be\ncrushed by the forward bending motion of the adult to whom the child\nis attached."
\n[2] Here's the section, if the PDF is hard to load or read:
\nCAA and JAA state that they permit the belly belt on the grounds that it provides a measure of protection to children and/or other passengers versus lap holding a child.
\nFAA Response: The FAA would like to emphasize that belly belts are not permitted under current regulations. Even if belly belts do provide some measure or protection, the CAMI study found that belly belts allowed the test dummy to make severe contact with the back of the seat in the row in front of the test dummy and that a child may be crushed by the forward bending motion of the adult to whom the child is attached. Consideration of revising this current prohibition is beyond the scope of the notice.
\nThe JAA also stated that in a crash or severe air turbulence, parents are often unable to keep a lap-held child in their arms.
\nFAA Response: As discussed earlier, the FAA has determined that mandating child restraint devices could cause more deaths and injuries than it would prevent. However, the FAA does not encourage lap-holding children. The FAA expects, with its education campaign providing clear guidance on child restraint devices, parents will choose an approved device, rather than lap holding their children, in order to provide the safest traveling environment for their children. The two members of the APCS Working Group submitted identical letters that discussed the need to mandate restraints for children. In addition, they stated that the FAA's argument that the extra cost to families caused by mandating child restraint devices would force them to less safe road travel is invalid since the same cost situation arises when the child is 3 or 4 or 10 years old.
\nFAA Response: The APCS Working Group's argument is that the extra cost to families of mandating child restraint devices is no more of a deterrent to air travel than the price of a ticket for a child of any age. However, the FAA notes that this argument does not take into account that ordinarily there is no charge for a lap-held child, whereas certificate holders very often do charge if a seat is requested for this infant. Thus, many people would switch to less safe automobile travel as a result of mandating child restraint usage because unlike most rulemakings where the compliance costs are passed along to all travelers, mandatory use of child restraint would impose compliance costs only on families with infants.
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