// HACKER NEWS — CYBERSECURITY
Allow Carriers on Planes
In fact, one specific place where I'd like to see this thinking
applied is adjacent to this rule: babywearing carriers on planes. When our
babies were little, carriers were massively helpful
in flying. The baby likes it, and your arms are free. But for
takeoff and landing, the FAA requires you to take your baby out of the
carrier and hold them in your arms.
The rule is that if an under-two is going to ride on a lap, they must
not "occupy or use any restraining device," (14
CFR 121.311.b.1) and FAA
guidance to parents is clear: "Baby carriers ...are not allowed to
be used during ground movement, take-off, or landing."
This goes back to 1995, and if you look at the notice
of proposed rulemaking it says:
This is based on their 1994
study, where the FAA compared child restraint options. They
looked at "booster seats, forward facing carriers, aft facing
carriers, a harness device, a belly belt, and passenger seat lap
belts." The "carriers" here are car seats; they didn't test
babywearing carriers. I don't think that's a major flaw in the study,
however, since I do expect babywearing carriers would have performed
poorly. [1] The real problem is that they didn't test the most common
alternative, holding the baby in your lap. So "may put children in a
potentially worse situation than the allowable alternatives" seems
clearly wrong to me.
In the 1996 final
rule [2] they discuss why they're making a different decision than
the UK (CAA) and Europe (JAA, predates EASA), and they avoid the
obvious comparison. They say belly belts can be dangerous,
acknowledge that lap-holding has risks, predict parents will buy a
second seat, and then also say they don't want to require a second
seat because people will drive. This isn't completely nuts, since
it's possible that allowing belly belts would have caused some parents
to choose them over a second seat. It's pretty unlikely for the
effects to balance out in just this way, however, and I don't see any
indication that they tried to do this balancing.
I expect that, if fairly evaluated, modern babywearing carriers would
prove much safer than arms during turbulence, crashes, and
evacuations. And I think this is likely enough that if we're not
going to do these tests we should default to not banning
carriers. In 2024 there was a bill proposing to do something like
this (Rep Bill Posey's HR
8972), but it went to the aviation subcommittee and died without a
vote.
I 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.
[1] The closest thing to a carrier they tested was a 'belly belt':
"This belt is designed to be buckled around the child's abdomen and is
secured to an adult's abdomen with the adult's safety belt by routing
the safety belt through a small loop of webbing sewn on the belly
belt." They did not perform well: "In the test, these systems allowed
the anthropomorphic test dummy to make severe contact with the back of
the seat in the row in front of the test dummy. The child also may be
crushed by the forward bending motion of the adult to whom the child
is attached."
[2] Here's the section, if the PDF is hard to load or read:
CAA 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.