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NTSB · Safety Recommendation

Safety Recommendation A-21-045

Recommendation

TO AIRLINES FOR AMERICA, THE NATIONAL AIR CARRIER ASSOCIATION, AND THE REGIONAL AIRLINE ASSOCIATION: 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.

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

September 22, 2025 · Recipient Response · Airlines for America (formerly Air Transport Association of America, Inc.)

-From Justin W. Madden, Vice President, Safety and Technical Operations, Airlines for America: I am writing in response to your correspondence to Airlines for America, dated July 10, 2025,regarding child restraint systems (CRS).

The safety of our passengers and crew members is always the top priority for A4A and our member carriers-which also applies to our youngest passengers. While the FAA, which is responsible for setting: the acceptable level .of safety for; the traveling public, has not required children under the age of two to be seated separately in a CRS, we recognize that the choice for purchasing a seat for children under the age of two is up to the parent or guardian.

We believe that together with the FAA we can provide parents and guardians with important information to assist them in making an informed decision. To that end, we have published on our public facing website the following:

Safety of our passengers and crew members is the top priority for A4A and our member carriers-and that applies to our youngest passengers, especially those under the age of two. A4A and our passenger carriers support the recommendation of the Federal Aviation Administration (FAA), that strongly urges travelers to secure children under two in an approved child restraint system (CRS) for the entirety of a flight. For additional information, travelers are encouraged to read their individual carrier's policies and recommendations in addition to the FAAs guidance on child safety (Flying with Children Federal Aviation Administration).

Moreover, we continue working with our member carriers to collect data regarding the number of children under the age of two who have flown since 2022 in our effort to determine whether such additional messaging by the association and member passenger carriers has a meaningful effect on a parent's or guardian’s decision to increase CRS usage for children under the age of two.

In addition, while the FAA itself has chosen not to require children under the age of two to be seated separately in a CRS based on its past analysis of the associated risks of traveling ·on the nation's highways, the agency nonetheless has provided additional information to the traveling public to include the following:

Read Recommendation

Recommendation Facts

Status
Open - Acceptable Response
Issued
September 7, 2021
Priority
CLASS II
Recipient
National Air Carrier Association, Inc., Regional Airline Association, Airlines for America (formerly Air Transport Association of America, Inc.)
Adopted
August 10, 2021
Related Investigation
DCA18SS003
Related Report
SS-21-01

Recipient Responses

National Air Carrier Association, Inc.: Open - Acceptable Response

Regional Airline Association: Open - Acceptable Response

Airlines for America (formerly Air Transport Association of America, Inc.): Open - Acceptable Response

• The safest place for your child under the age of two on a U.S. airplane is in approved child restraint system (CRS) or device, not in your lap. Your arms aren't capable of holding your in-lap child securely, especially during unexpected turbulence. 'Unrestrained lap children are prone to in-flight injuries, particularly during meal service or turbulence,' according to a 2019 study by the National Institutes of Health.

• The FM strongly urges you to secure your child in an approved CRS or other approved device for the entirety of your flight. Buying a ticket for your child is the only way to guarantee that you will be able to use a CRS. It's the smart and right thing to do so that everyone in your family arrives safely at your destination. Buckle up your child for the car ride to the airport, on the plane and when you arrive at your destination.

By leveraging the combined efforts of the FAA, A4A, and its passenger carrier members, we can provide parents and guardians with the appropriate information they need to make a well-informed decision.

July 10, 2025 · NTSB Correspondence · National Air Carrier Association, Inc.

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.

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.

July 10, 2025 · NTSB Correspondence · Regional Airline Association

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.

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.

July 10, 2025 · NTSB Correspondence · Airlines for America (formerly Air Transport Association of America, Inc.)

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.

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.

March 24, 2022 · NTSB Correspondence · National Air Carrier Association, Inc.

We believe your plan to work with industry and your members to educate the traveling public about the benefits of CRSs in airplanes, and to collect data to determine if your efforts have increased CRS use, are responsive to this recommendation. Pending updates on your progress and completion of the recommended actions, Safety Recommendation A-21-45 is classified OPEN-- ACCEPTABLE RESPONSE.

March 24, 2022 · NTSB Correspondence · Regional Airline Association

We believe your plan to work with industry and your members to educate the traveling public about the benefits of CRSs in airplanes, and to collect data to determine if your efforts have increased CRS use, are responsive to this recommendation. Pending updates on your progress and completion of the recommended actions, Safety Recommendation A-21-45 is classified OPEN-- ACCEPTABLE RESPONSE.

March 24, 2022 · NTSB Correspondence · Airlines for America (formerly Air Transport Association of America, Inc.)

We believe your plan to work with industry and your members to educate the traveling public about the benefits of CRSs in airplanes, and to collect data to determine if your efforts have increased CRS use, are responsive to this recommendation. Pending updates on your progress and completion of the recommended actions, Safety Recommendation A-21-45 is classified OPEN-- ACCEPTABLE RESPONSE.

December 3, 2021 · Recipient Response · National Air Carrier Association, Inc.

-From Paul J. McGraw, Vice President, Operations and Safety, Airlines for America and George Paul, Vice President, Technical Services, National Air Carrier Association: This is in response to your recent correspondence to Nicholas E. Calio, President and CEO, Airlines for America, and similar correspondence to George Novak, President and CEO, National Air Carrier Association (NACA).

On August 10, 2021, the NTSB issued its’ findings from its’ study entitled Injuries in Air Carrier Operations Conducted Under Title 14 Code of Federal Regulations Part 121, NTSB/SS-21/01. As a result of its research, the NTSB identified several safety issues and recommendations to the commercial aviation industry to help reduce injuries associated with turbulence events in Part 121 operations. More specifically, the NTSB made the following recommendation to the associations:

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)

The purpose of issuing the recommendation to the associations is in recognition of the unique relationship that each organization has with its member airlines. The NTSB believes that this relationship may influence change within its members airlines.

First and foremost, the safety of our member’s passengers and crew is paramount. While rare, injuries related to turbulence primarily occur to passengers who are either out of their seats or seated with their seat belts unfastened. FAA regulation, 14 CFR 121.311, require separate seats and seatbelts for each person traveling on board an aircraft in Part 121 air carrier operations. As the NTSB study shows, passengers seated with seat belts fastened is an effective measure during a turbulence encounter. This regulation does, however, provide an exception for children under the age of 2 (lap child) that allows children to be held on an adult’s lap (e.g., parent or guardian).

Notwithstanding prior NTSB recommendations to the FAA to amend its regulations to require children under the age of 2 to be seated separately in a CRS, the FAA which is primarily responsible for setting the acceptable level of safety for the traveling public has elected not to do so based on analysis of the associated risks.

In the absence of a federal requirement, the choice of purchasing a separate seat for children under the age of 2 is up to the parent or guardian. However, we believe that the decision-maker should have all the information to make an informed decision. As such our member carriers provide information on their websites to parents and guardians stating for example that the safest place for a child is in a government approved CRS.

As a result of the NTSB study and in response to the specific recommendation to the associations, we offer the following actions to be taken:

• Work collaboratively with the NTSB and FAA to provide a clear and consistent message across passenger carriers to parents/caregivers to communicate that the safest place for an infant is in a CRS. This would include working with our member carriers to inform the traveling public, and appropriately display this message, as well as exploring opportunities to collaboratively work with the NTSB and FAA on an education and communication plan for informing families regarding safety when traveling with children.

• Work with our member carriers to determine the feasibility and most appropriate means to gather available data over a specified period of time (i.e., years) to determine whether the education and communication plan has meaningful effect on a parent/caregiver’s decision to purchase a ticket for infants.

The associations believe that working with the NTSB and FAA we can best educate and communicate to parents and caregivers’ safety information so that they may make a well-informed decision that is in their best interest.

December 3, 2021 · Recipient Response · Regional Airline Association

-From Faye Malarkey Black, President and CEO: Thank you for your correspondence dated September 7, 2021, regarding a recommendation issued by the National Transportation Safety Board (NTSB) on its study entitled Injuries in Air Carrier Operations Conducted Under Title 14 Code of Federal Regulations Part 121, NTSB/SS-21/01. In the study, the NTSB made the following recommendation to the Regional Airline Association, as well as to Airlines for America (A4A) and the National Air Carrier Association (NACA):

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)

We were pleased to facilitate a meeting between you and our Board of Directors on September 28 to further discuss these and other NTSB objectives. This first step will be one of many cooperative discussions between NTSB, RAA and our members to facilitate sharing information and ideas to advance aviation safety. RAA believes that working collaboratively with our industry partners as well as the NTSB and FAA will best assist parents and caregivers make a well-informed decision regarding use of child restraint system (CRS). We support the roadmap to further this effort offered by A4A and NACA and will continue to be a part of ongoing collaborative discussions with those two groups.

In addition to supporting those efforts, I would like to offer additional mechanisms for RAA to support your objectives while recognizing the distinction between our members’ business model and that of ticketing carriers. Though all of RAA’s members hold individual operating certificates, the vast majority (including 100% of our part 121 carriers) do not market flights or sell tickets. Instead, they operate under Capacity Purchase Agreements (CPAs) with larger airlines including Alaska, American, Delta, JetBlue and United.

Under such arrangements, our member carriers do not have means or opportunities to directly interact with our passengers before the boarding area or in some cases, until they board our aircraft. Our mainline partners, as marketing carriers, handle all passenger policies and communications and are solely responsible for any attestations that may be required by various government agencies.

We support the following industry efforts described in the letter sent by A4A and NACA and will continue to actively participate and contribute to ongoing dialogue and industry-wide cooperative efforts surrounding these objectives:

• To work collaboratively with the NTSB and FAA to provide a clear and consistent message across passenger carriers to parents/caregivers to communicate that the safest place for an infant is in a CRS. This would include working with our member carriers to inform the traveling public and prominently display this message as well as exploring opportunities to collaboratively work with the NTSB and FAA on an education and communication plan for informing families regarding safety when traveling with children.

• To work with our member carriers to determine the feasibility and most appropriate means to gather available data over a specified period of time (i.e., years) to determine whether the education and communication plan has meaningful effect on a parent/caregiver’s decision to purchase a ticket for infants.

Because the efforts described above reflect the specific role that ticketing carriers may be able to take, RAA suggests that we would like to play a further, distinct, but important role, in advancing our members’ discussions about the topic of CRS use. Through our Safety Council and its associated committees, RAA will offer a platform to share information and ideas to encourage the correct use of the CRS once passengers are onboard the aircraft. To that end, RAA intends to place this topic on the agenda for our next in-person meeting, asking members to share steps that may be taken to encourage and support CRS use on the aircraft.

As a parent who consistently used CRS when I flew with my own two children, I believe that a positive experience using a CRS may promote that parent’s repeat use of the CRS for their next flight.

In conclusion, we want to reiterate our full support of the industry-wide initiative to increase CRS usage while explaining the unique nature of the relationship between our member airlines and their partners, who are the primary interface with passengers at all stages between ticketing and ultimately boarding the flight. We look forward to working with our industry partners in conjunction with the NTSB and FAA as we believe this will help assist parents and caregivers in making well-informed decisions.

Should you have any questions or want to discuss further, please feel free to contact me or Nobuyo Reinsch, our VP Aviation Safety and Security and Bill Whyte, VP Aviation Operations and Technical Services, who will take the lead on this project through our committee structures.

Thank you for including RAA in your communications and for talking with us in person about these and other important objectives. We look forward to continuing our work together.

December 3, 2021 · Recipient Response · Airlines for America (formerly Air Transport Association of America, Inc.)

-From Paul J. McGraw, Vice President, Operations and Safety, Airlines for America and George Paul, Vice President, Technical Services, National Air Carrier Association: This is in response to your recent correspondence to Nicholas E. Calio, President and CEO, Airlines for America, and similar correspondence to George Novak, President and CEO, National Air Carrier Association (NACA).

On August 10, 2021, the NTSB issued its’ findings from its’ study entitled Injuries in Air Carrier Operations Conducted Under Title 14 Code of Federal Regulations Part 121, NTSB/SS-21/01. As a result of its research, the NTSB identified several safety issues and recommendations to the commercial aviation industry to help reduce injuries associated with turbulence events in Part 121 operations. More specifically, the NTSB made the following recommendation to the associations:

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)

The purpose of issuing the recommendation to the associations is in recognition of the unique relationship that each organization has with its member airlines. The NTSB believes that this relationship may influence change within its members airlines.

First and foremost, the safety of our member’s passengers and crew is paramount. While rare, injuries related to turbulence primarily occur to passengers who are either out of their seats or seated with their seat belts unfastened. FAA regulation, 14 CFR 121.311, require separate seats and seatbelts for each person traveling on board an aircraft in Part 121 air carrier operations. As the NTSB study shows, passengers seated with seat belts fastened is an effective measure during a turbulence encounter. This regulation does, however, provide an exception for children under the age of 2 (lap child) that allows children to be held on an adult’s lap (e.g., parent or guardian).

Notwithstanding prior NTSB recommendations to the FAA to amend its regulations to require children under the age of 2 to be seated separately in a CRS, the FAA which is primarily responsible for setting the acceptable level of safety for the traveling public has elected not to do so based on analysis of the associated risks.

In the absence of a federal requirement, the choice of purchasing a separate seat for children under the age of 2 is up to the parent or guardian. However, we believe that the decision-maker should have all the information to make an informed decision. As such our member carriers provide information on their websites to parents and guardians stating for example that the safest place for a child is in a government approved CRS.

As a result of the NTSB study and in response to the specific recommendation to the associations, we offer the following actions to be taken:

• Work collaboratively with the NTSB and FAA to provide a clear and consistent message across passenger carriers to parents/caregivers to communicate that the safest place for an infant is in a CRS. This would include working with our member carriers to inform the traveling public, and appropriately display this message, as well as exploring opportunities to collaboratively work with the NTSB and FAA on an education and communication plan for informing families regarding safety when traveling with children.

• Work with our member carriers to determine the feasibility and most appropriate means to gather available data over a specified period of time (i.e., years) to determine whether the education and communication plan has meaningful effect on a parent/caregiver’s decision to purchase a ticket for infants.

The associations believe that working with the NTSB and FAA we can best educate and communicate to parents and caregivers’ safety information so that they may make a well-informed decision that is in their best interest.

September 7, 2021 · NTSB Correspondence · National Air Carrier Association, Inc.

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.

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 recommendation may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.

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 recommendation by number (for example, A-21-45). 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.

All communications regarding safety recommendations will be stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.

We are providing the following information to urge the National Air Carrier Association to act on the safety recommendation in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.

This letter also includes information about our 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 recommendation to the National Air Carrier Association. Additional information regarding this recommendation can be found in the noted section of the report.

• 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) (See section 4.3.3.)

The NTSB is vitally interested in this recommendation because it is 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 this recommendation. When replying, please refer to the safety recommendation by number (Safety Recommendation A 21 45). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, 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.

All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your company uses auto generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.

September 7, 2021 · NTSB Correspondence · Regional Airline Association

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.

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 recommendation may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.

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 recommendation by number (for example, A-21-45). 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.

All communications regarding safety recommendations will be stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.

We are providing the following information to urge the Regional Airline Association to act on the safety recommendation in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.

This letter also includes information about our 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 recommendation to the Regional Airline Association. Additional information regarding this recommendation can be found in the noted section of the report.

• 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) (See section 4.3.3.)

The NTSB is vitally interested in this recommendation because it is 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 this recommendation. When replying, please refer to the safety recommendation by number (Safety Recommendation A 21 45). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, 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.

All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your company uses auto generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.

September 7, 2021 · NTSB Correspondence · Airlines for America (formerly Air Transport Association of America, Inc.)

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.

The attached letter from the NTSB Chairman provides information about the NTSB’s our 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 recommendation may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.

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 recommendation by number (for example, A-21-45). 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.

All communications regarding safety recommendations will be stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.

We are providing the following information to urge Airlines for America to act on the safety recommendation in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.

This letter also includes information about our 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 recommendation to Airlines for America. Additional information regarding this recommendation can be found in the noted section of the report.

• 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) (See section 4.3.3.)

The NTSB is vitally interested in this recommendation because it is 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 this recommendation. When replying, please refer to the safety recommendation by number (Safety Recommendation A 21 45). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, 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.

All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your company uses auto generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.