Legal Interpretations
Heidorn 2012
Summary
The Question
Does 14 CFR 91.205(b)(13) require each occupant 2 years of age or older to have an individual seat belt?
Background
A requester asked how the day VFR equipment requirement for an approved safety belt for each occupant 2 years or older fits with 14 CFR 91.107, which the FAA has interpreted to allow shared seat belts in certain situations.
The FAA’s Interpretation
No. Read consistently with 14 CFR 91.107, 14 CFR 91.205(b)(13) requires only that each occupant at least two years old have access to an approved safety belt, so occupants may share one if each is securely restrained. Sharing is permitted only if seat use conforms to the approved Airplane Flight Manual limitations, and the PIC must check, if the information is available, that the belt is approved and rated and seat strength is not exceeded.
- Requester
- Heidorn
- Issued
- February 18, 2012
- Subject
- General Operating & Flight Rules
Regulations Cited
- 14 CFR 91.20
- 14 CFR 91.107
- 14 CFR 91.205
Page 1
U.S. Deportment
of Transportation
Federal Aviation
Administration
Dear Mr. Heidorn,
JUN 18 !012
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington. D.C. 20591
This is in response to your February 18, 2012 letter requesting clarification concerning the seat belt requirements of 14 CFR § 91.205(b)(13). Specifically, you ask whether§ 91.205(b)(l3) requires that each occupant over 2 years of age have their own individual seat belt in light of the fact that § 91.107 allows the shared use of seat belts in certain situations. Section 91.107 sets the minimum standards for seat belt use in part 91 flights. The FAA has previously interpreted this section as permitting aircraft occupants to share seat belts in certain situations. See 77 FR 30885. Subsection 91.20S(b)(l3) sets out equipage requirements for operations conducted during the day under visual flight rules (VFR). Under this section a powered civil aircraft with a standard category U.S. airworthiness certificate may not be operated under VFR during the day unless it has "[a]n approved safety belt with an approved metal-to-metal latching device for each occupant 2 years of age or older." Reading § 91.205(b)(13) consistently with the FAA 's interpretation of§ 91.107, which permits aircraft occupants on part 91 flights to share seat belts in certain situations, we conclude that § 91.205(b)(13) does not mandate that each aircraft occupant have their own individual seat belt. Rather, § 91.205(b)(13) simply requires that each aircraft occupant who is at least two years of age have access to a safety belt. Because § 91.205(b)(13) does not require individual seat belts for each occupant, this section permits aircraft occupants to share an approved safety belt with an approved metal-to-metal latching device as long as each occupant who is sharing the safety belt is securely restrained by the approved safety belt.
However, the FAA emphasizes that § 91.107 has been interpreted to state that the use of a seat belt and/or seat by more than one occupant is permitted only ifthe seat usage conforms to the limitations contained in the approved portion of the Airplane Flight Manual (AFM). See 77 FR 30885. Additionally, before multiple occupants use the same seat and/or seat belt, if the pertinent information is available, the pilot in command (PIC) must also check whether: (1) the seat belt is approved and rated for such use; and (2) the structural strength requirements for the seat are not exceeded. Id.
We appreciate your patience and trust that the above responds to your concerns. If you need further assistance, please contact my staff at (202) 267-3073. This response was prepared by Alex Zektser, Attorney, Regulations Division of the Office of the Chief Counsel, and coordinated with the General Aviation and Commercial Division of Flight Standards Service.
Page 2
Sincerely,
μ-~-~
Rebecca B. MacPherson Assistant Chief Counsel for Regulations, AGC-200
Regulations Referenced
Snapshot retrieved August 6, 2026.