Why FAA’s Child Seat Campaign Is Deadly

Federal law allows airline passengers with children under the age of two to travel with their children on their laps. This option, which has existed since the 1950s, has been under attack for quite some time by various agencies and consumer protection advocacy groups. These opponents claim that a lap-seated child is not afforded the same safety as other passengers, and may risk injuring or killing himself or other passengers in the event of strong turbulence or a crash. There are a very small number of plane crashes in which a lap-seated child died and in which the evidence suggests that he might have survived in a Child Restraint Seat (CRS). Nonetheless, requiring all children to be strapped in on an airplane is not a particularly good idea. As it turns out, CRS in airplanes would raise the cost of air travel for families with toddlers, making some of them travel in ways that pose a much larger threat.

Back in the 1990s, when FAA proposed mandating the use of CRS in airplanes, several researchers showed that this could result in another 13 to 42 added fatalities over 10 years in highway accidents. Since the CRS requirement would force families traveling with a child to purchase a ticket for an extra seat, the increased cost would make some travelers drive their cars instead. This, however, would make them subject to the risks of accidents on America’s highways. Because air travel is generally much safer than car travel, FAA withdrew its proposed regulation in 2005.

These findings where confirmed by FAA in 2011, when it concluded that requiring the use of CRS would increase total transportation deaths by 72 deaths over 10 years and by 115over 15 years.

Allowing toddlers to fly on their parent’s lap is therefore quite a good idea.

The National Transportation Safety Board (NTSB) opposes giving parents this option, and it criticized FAA in a not-very-persuasive 2004 study. The option is also opposed by the Association of Flight Attendants. Lap babies, however, are probably not the flight attendant’s favorite passengers. My guess is that they’d like to see babies on planes not only in a seat of their own, but bound and gagged.

Lately, FAA has tried to reduce the number of lap babies by nudging parents in the agency’s preferred direction — not through regulation but through an educational campaign.

But considering FAA’s steadfast conviction that a CRS mandate would indeed result in more deaths, just how wise is this campaign? Consider these statements on its website:

Did you know that the safest place for your child on an airplane is in a government-approved child safety restraint system (CRS) or device, not on your lap?

While stating that its attempts only are educational and do not force anyone to buy an extra seat, the intended effects are, obviously, to make parents believe that a lap-seated child is an unsafe child:

[FAA] strongly urges you to secure your child in a CRS or device for the duration of your flight. It’s the smart and right thing to do so that everyone in your family arrives safely at your destination.

Such statements could persuade some parents that, if they can’t afford to pay for their babies’ air fare, then perhaps they shouldn’t fly at all. And if some of those parents choose to drive instead, the results could be deadly.

Regardless of this, FAA decided last year to intensify its push on child safety “via child safety advocacy organizations and media,” and announced that “[o]utreach via social media and traditional pitching will be accomplished monthly”.

Even worse, NTSB is still promoting a CRS mandate in what one newspaper calls “a battle” between the agencies. Here’s NTSB chairman Deborah A.P. Hersman asking rhetorical questions:

The laws of physics don’t change, whether you’re on an airplane or in an automobile. And we know that no parent would intentionally place their child in a less-safe position than they place themselves. If we are so careful to strap our children into car seats when we drive to the airport, then why are we not as diligent in securing them in a seat of their own on the aircraft?

Consider this: If there are strong arguments against mandating the use of child seats, do these arguments simply disappear because the agency uses “education” rather than legal force? Sure, you could argue that those families that actually follow the recommendations are increasing the safety, but considering how safe air travel actually is, that increase should be insignificant. As a consequence, aren’t the safety campaigns by FAA just as likely to result in more deaths as their withdrawn regulations?

Considering that aviation travel steadily is becoming safer, we are puzzled by the fact that FAA wants parents to believe that letting their child travel on their lap is a real safety hazard. If the FAA campaign really is supposed to be a “nudge” aimed at increasing the safety of toddlers, wouldn’t a more reasonable policy be to inform parents about the dangers of driving a car as compared to flying? You could argue that the educational campaign induces much higher risks than those risks that are trying to be avoided.