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  3. NTSB A-21-040
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NTSB · Safety Recommendation

Safety Recommendation A-21-040

Recommendation

TO THE FEDERAL AVIATION ADMINISTRATION: Conduct a study to determine the factors that affect caregivers’ decisions about the use of child restraint systems (CRSs) when traveling on a Title 14 Code of Federal Regulations Part 121 air carrier airplane with children under the age of 2 and to understand the challenges associated with using CRSs; publish the study findings.

Safety Issue and Context

Turbulence-related accidents are the most common type of accident involving air carriers operating under Title 14 Code of Federal Regulations (CFR) Part 121. From 2009 through 2018, the National Transportation Safety Board (NTSB) found that turbulence-related accidents accounted for more than a third of all Part 121 accidents; most of these accidents resulted in one or more serious injuries but no aircraft damage.

This NTSB safety research report examines the prevalence and risk factors of turbulence-related accidents in Part 121 air carrier operations; assesses the effectiveness of policies, programs, technologies, and other applicable safety countermeasures; and makes recommendations for improving turbulence avoidance and injury mitigation.

Response History

July 10, 2025 · NTSB Correspondence · FAA

From the Aviation Investigation Report AIR-25-04 “In-Flight Separation of Left Mid Exit Door Plug, Alaska Airlines Flight 1282, Boeing 737 9, N704AL, Portland, Oregon, January 5, 2024” published on July 10, 2025:

2.6.4 Safety Benefits of Child Restraint Systems

The caregivers of the three lap-held children on the accident flight were seated five or more rows away from the fuselage hole (at row 26) and were able to secure their children during the rapid depressurization event. However, passengers seated closer to the hole experienced the most adverse effects of the event, including the loss of clothing and belongings that were forcefully pushed out of the hole as the higher pressure air in the cabin escaped. Had the airplane been at a higher altitude (with a greater pressure differential) when the separation of the left MED plug occurred, the likelihood that a caregiver seated near the hole could have safely restrained a lap-held child is reduced.

Other airplane accidents and incidents have occurred in which caregivers were unable to hold lap-held children securely.

There is widespread consensus among the transportation safety and medical communities that it is safest for children less than 2 years old to be seated in their own seat on an airplane, using an appropriate CRS, such as a car seat that is also approved for airplane use. For example, the American Academy of Pediatrics has stated that “the safest place for a child under 2 on an airplane is in a car seat, not on a parent’s lap,” and that, “if there is turbulence, or worse, you may not be able to protect your baby in your arms” (NTSB 2021, 58-9). The use of a CRS provides an equivalent level of safety for infants and children as that afforded to adult passengers wearing seat belts.

The NTSB has a longstanding history of interest in the safety of lap-held children on board airplanes. For more than three decades, we have recommended that the FAA require the use of a CRS appropriate to the child’s size and weight. However, in response to these recommendations, the FAA has consistently declined to mandate CRS usage for children under the age of 2. Instead, the FAA has emphasized the actions it has taken to increase voluntary CRS usage, including providing information on the FAA website and conducting outreach via social media.

Read Recommendation

Recommendation Facts

Status
Open - Acceptable Response
Issued
September 7, 2021
Priority
CLASS II
Recipient
FAA
Adopted
August 10, 2021
Related Investigation
DCA18SS003
Related Report
SS-21-01

Thus, the NTSB concludes that the FAA’s emphasis on increasing voluntary usage of CRSs, rather than mandating their use as we have long recommended, has continued to allow children under the age of 2 years to travel on board aircraft at a lower level of safety than that of seat belt-wearing adult passengers.

In our 2021 safety research report on preventing turbulence-related injuries, we noted that, because the FAA has not evaluated the effects of its public education campaign, it is difficult to accurately determine trends in the amount of voluntary CRS usage, to identify operational impediments to CRS usage, or to evaluate the effects of public education or industry efforts on CRS usage. We concluded that such analyses require applicable data and that researching the factors that affect caregivers’ decisions about whether to use a CRS would inform and improve government and industry efforts to increase the voluntary use of CRSs (NTSB 2021, 59).

As a result, we recommended that the FAA do the following:

Conduct a study to determine the factors that affect caregivers’ decisions about the use of child restraint systems (CRSs) when traveling on a Title 14 Code of Federal Regulations Part 121 air carrier airplane with children under the age of 2 and to understand the challenges associated with using CRSs; publish the study findings. (A-21-40)

After the action in Safety Recommendation A-21-40 is completed, use the study findings to direct the Federal Aviation Administration’s efforts to increase child restraint system usage. (A-21-41)

We also recommended that Airlines for America, the National Air Carrier Association, and the Regional Airline Association each do the following:

Coordinate with your member airlines to develop and implement a program to increase child restraint system (CRS) usage in airplanes; this effort should include collecting data to determine the program’s effectiveness at increasing CRS usage. (A-21-45)

At the time of this report, the FAA and the industry groups had initiated responsive action to these recommendations, but some planned actions are not yet completed. As a result, Safety Recommendations A-21-40, -41, and -45 are classified Open—Acceptable Response. We continue to believe that the safest place for a child under the age of 2 on board an aircraft is in a CRS. For accidents involving such events as severe turbulence, loss of control during landing, and rapid depressurization, the use of CRS could be the difference between no injury and a tragic loss of life.

Thus, the NTSB concludes that, although none of the three lap-held children on board the airplane sustained injury, the circumstances of this accident and others show that the potential for severe injury or death exists for children less than 2 years old who are not secured in a CRS appropriate to their size and weight. Therefore, the NTSB reiterates Safety Recommendations A-21-40, -41, and -45.

January 3, 2024 · NTSB Correspondence · FAA

We note that, in 2018, the Center for Child Injury Prevention Studies conducted an FAA-sponsored study, titled, “Understanding Child Restraint System Use on Airplanes,” which indicated the need for additional information about child safety prior to booking and boarding a flight and, once on board, the safety protocols and roles of flight attendants as safety professionals.

We also note that, in 2021, the Injury Biomechanics Research Center at Ohio State University conducted an FAA-sponsored study, titled, “Compatibility of Child Restraint Systems with Commercial Aircraft Seats,” which concluded that FAA-approved CRSs that are also suitable for vehicular use fit differently in aircraft due to variations in seat cushion length, width between armrests, and seat cushion angle. You used this research to develop a communications outreach plan that focuses on creating conversations with caregivers about child safety on airplanes through social media, blogs, and podcasts.

We are encouraged to learn about the research that you have sponsored on CRS use; however, to determine if the research is an acceptable solution to Safety Recommendation A-21-40, we request copies of the studies because they are not available online. Pending our receipt and review of this information, Safety Recommendation A-21-40 is classified OPEN-- ACCEPTABLE RESPONSE.

Regarding Safety Recommendation A-21-41, we believe your outreach efforts to engage with caregivers about child safety on airplanes are positive; however, we point out that this recommendation asks you to use the study findings to direct your efforts to increase CRS use. Therefore, we have the following questions:

1. What has the FAA done to educate caregivers about child safety needs on airplanes prior to booking? Prior to boarding the aircraft (at the gate)? 2. What has the FAA done to make traveling with a CRS easier for caregivers? 3. What has the FAA done to alleviate compatibility concerns that have been identified between CRSs and aircraft seats and belts? 4. What has the FAA done to educate flight attendants about CRSs and how they fit into their role as safety professionals?

Pending our receipt and review of the requested information, Safety Recommendation A-21-41 is classified Open—Acceptable Response.

August 22, 2023 · Recipient Response · FAA

-From Kathryn B. Thomson, Deputy Administrator: The Federal Aviation Administration (FAA) sponsored the 2018 study, Understanding Child Restraint System Use on Airplanes, conducted by the Center for Child Injury Prevention Studies. This study looked at the factors that affect caregivers’ decisions when using a CRS with children under the age of two and when traveling on a Part 121 air carrier airplane. This study is available at the following website:

https://cchips.research.chop.edu/understanding-child-restraint-system-use-on-airplanes

On May 18, 2022, the FAA hosted the Understanding Child Restraint Use on Airplanes webinar to publicly discuss the results of this study. The webinar is available at the following website:

https://www.youtube.com/watch?v=dHHSQtU0kXE

The findings indicated that most caregivers did not use a CRS as the cost was a barrier, and parents tend to do what is most economical for their situation. This led the authors of the study to recommend additional education regarding inflight safety needs for infants and children prior to the boarding of a flight and to include information about the safety protocols and the role of flight attendants as safety professionals.

The FAA sponsored a second study in 2021, Compatibility of Child Restraint Systems with Commercial Aircraft Seats, conducted by the Injury Biomechanics Research Center at The Ohio State University. Findings from this study discussed the compatibility of CRSs in aviation seats, which were presented at the FAA’s Fire and Cabin Safety Research Conference in October 2022. The data presented in this study concluded that FAA-approved CRSs, also suitable for vehicular use, fit differently in aircraft due to variations in seat cushion length, width between armrests, and seat cushion angle.

At the April 2023 Lifesavers National Conference on Highway Safety Priorities, the FAA presented this data to discuss the FAA’s outreach and inform the flying public of the airlines’ responsibility to accommodate an approved CRS in another seat on the aircraft if the CRS does not fit the specific seat purchased. This study is available at the following website: https://www.fire.tc.faa.gov/2022Conference/files/Crash_Dynamics_I/MansfieldCRSFit/Mansfiel d_CRSFit_Pres.pdf

Utilizing the findings from our research on CRS usage, the FAA developed a communications outreach plan for parents and caregivers to increase the use of CRSs on airplanes. The outreach goal is to create conversations about child safety on airplanes by connecting with parents and caregivers using simple, engaging visual assets through digital and news media, with a focus on travel and child safety influencers and organizations, as well as our established partners. The FAA’s outreach efforts include:

• Updated Flying with Children web content on https://www.faa.gov/travelers/fly_children • Engagement with the National Highway Traffic Safety Administration and Transportation Security Administration, airports throughout the nation, and other stakeholders • Engagement with parenting and travel social media influencers • Development of partnerships and stories to reach parents where they get safety and travel information • Engagement with parents across social media platforms, with more than 1.5 million followers, to answer their questions about traveling with children in CRS • Development and promotion of the FAA blog and podcast content

• Incorporation of Spanish-language social media posts

I believe the FAA has effectively addressed Safety Recommendations A-21-40 and -41 with its robust, study-derived communications outreach plan and consider our actions complete.

May 4, 2022 · NTSB Correspondence · FAA

We did not find any information in your letter related to these recommendations. Pending our receipt and review of this additional information, Safety Recommendations A-21-39 through -41 remain classified OPEN-- AWAIT RESPONSE.

November 19, 2021 · Recipient Response · FAA

-From Steve Dickson, Administrator: The FAA is reviewing part 121 requirements and associated guidance material that pertains to aircraft turbulence and injury prevention. Our review will determine if updates to part 121 and/or current guidance material are necessary to address turbulence-related injuries.

I will keep the Board informed of the FAA’s progress on these recommendations and anticipate providing an update by December 31, 2022.

September 7, 2021 · NTSB Correspondence · FAA

The attached letter from the NTSB Chairman provides information about the NTSB’s August 10, 2021, report Preventing Turbulence-Related Injuries in Air Carrier Operations Conducted Under Title 14 Code of Federal Regulations Part 121, NTSB/SS-21/01. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.

The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, A-21-25 through -42; Reiterated Recommendations A-17-21 and -22, A-17-26; Classified and Reiterated Recommendation A-17-25). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov.

If your reply exceeds 20 megabytes, including attachments, please e mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.

This letter provides information about the National Transportation Safety Board’s (NTSB) August 10, 2021, report Preventing Turbulence-Related Injuries in Air Carrier Operations Conducted Under Title 14 Code of Federal Regulations Part 121, NTSB/SS-21/01. The details of this safety research and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.

As a result of this research, we identified the following safety issues:

• Insufficient submission and dissemination of turbulence observations. • A lack of shared awareness of turbulence risks. • The need for mitigation of common turbulence-related injury circumstances. • The need for updated turbulence guidance.

Accordingly, the NTSB makes the following safety recommendations to the Federal Aviation Administration. Additional information regarding these recommendations can be found in the noted sections of the report.

• Work with stakeholders to standardize the distribution of pilot weather reports (PIREPs) across and within air traffic control facilities to ensure they are disseminated to only those facilities and air traffic controller positions for which each PIREP applies. (A-21-25) (See section 4.1.1.)

• As a condition of enhanced weather information system approval, require Title 14 Code of Federal Regulations Part 121 air carriers to disseminate all turbulence observations to the National Airspace System as pilot weather reports, as well as reports of smooth ride conditions. (A-21-26) (See section 4.1.1.)

• Determine how to harmonize current and future eddy dissipation rate algorithm performance in operational environments and publish the results of this determination. (A 21-27) (See section 4.1.2.)

• Incorporate the automatic dependent surveillance-broadcast weather capability in the next version of the automatic dependent surveillance broadcast technical standard order. (A 21 28) (See section 4.1.2.)

• After the automatic dependent surveillance-broadcast (ADS-B) technical standard order is revised as recommended in Safety Recommendation A 21 28, require that aircraft flown in Title 14 Code of Federal Regulations Part 121 air carrier operations be retrofitted with automatic dependent surveillance broadcast weather capable ADS-B equipment. (A 21 29) (See section 4.1.2.)

• Require automatic dependent surveillance-broadcast weather (ADS-B Wx)-equipped aircraft to broadcast ADS-B Wx information when operating in airspace requiring automatic dependent surveillance-broadcast capability as defined by Title 14 Code of Federal Regulations 91.225. (A-21-30) (See section 4.1.2.)

• In collaboration with the National Weather Service, modify airmen’s meteorological information (AIRMET) advisory issuing practices to include graphical AIRMET advisories with higher granularity, taking into account the effect it would have on all National Airspace System users. (A-21-31) (See section 4.2.1.)

• Distribute graphical airmen’s meteorological information advisories, significant meteorological information advisories, and center weather advisories to air traffic controllers as controller-selectable layers on current and future controller radar displays in air route traffic control centers and terminal radar approach control facilities. (A 21 32) (See section 4.2.1.)

• Work with local safety councils to develop training on the use of the advisories developed for Safety Recommendation A-21-32. (A-21-33) (See section 4.2.1.)

• In collaboration with the National Weather Service, operationalize a turbulence nowcast, such as the graphical turbulence guidance nowcast. (A-21-34) (See section 4.2.2.)

• Develop air traffic control guidelines for use of the turbulence nowcast operationalized in accordance with Safety Recommendations A-21-34 and A-21-44. (A-21-35) (See section 4.2.2.)

• Incorporate total lightning and hail information as selectable layers on air traffic controller radar displays in air route traffic control centers and terminal radar approach control facilities. (A-21-36) (See section 4.2.3.)

• After the action in Safety Recommendation A-21-36 is completed, provide training to air traffic controllers on the use of the controller-selectable total lightning and hail information. (A-21-37) (See section 4.2.3.)

• Based on National Transportation Safety Board data on turbulence-related Title 14 Code of Federal Regulations Part 121 accidents, include in the revisions to Advisory Circular 120-88A, “Preventing Injuries Caused by Turbulence,” in Safety Recommendation A-21-42 the phases of flight and associated altitudes at which flight attendants should be secured in their seats during Part 121 air carrier operations, including in particular the descent phase of flight. (A 21 38) (See section 4.3.1.)

• Conduct a study of how aircraft accelerations vary along the length of the aircraft during turbulence encounters, including differences among aircraft types operated by Title 14 Code of Federal Regulations Part 121 air carriers, and publish the study findings. (A 21 39) (See section 4.3.2.)

• Conduct a study to determine the factors that affect caregivers’ decisions about the use of child restraint systems (CRSs) when traveling on a Title 14 Code of Federal Regulations Part 121 air carrier airplane with children under the age of 2 and to understand the challenges associated with using CRSs; publish the study findings. (A-21-40) (See section 4.3.3.)

• After the action in Safety Recommendation A-21-40 is completed, use the study findings to direct the Federal Aviation Administration’s efforts to increase child restraint system usage. (A-21-41) (See section 4.3.3.)

• Revise Advisory Circular 120-88A, “Preventing Injuries Caused by Turbulence,” to reflect current best practices and the findings of this research report, such as new turbulence forecasting and warning technologies; training methods; in-flight communications between pilots and flight attendants, procedures, and available information for predicting turbulence; and altitudes at which flight attendants should be secured in their seats. (A 21 42) (See section 4.4.)

In addition, the NTSB reiterates the following recommendations to the Federal Aviation Administration:

• Provide air traffic controllers with automated pilot weather report (PIREP) data-collection tools that incorporate design elements to prevent input errors, increase quantity, and improve the timeliness of PIREPs disseminated to the National Airspace System. (A 17 21) (See section 4.1.1.)

• Incorporate automation technology that captures data elements from air traffic controllers’ displays,