Arun wrote:
In a four seater, we wanted to do this with two adults and 3 kids. But, while legal
It used to be, and I did that too, but is not so anymore. After one accident with a 6-seater (PA32) where 7 were seated in total (not in the 7-seat arrangement) and where all perished near the German coast German law has changed quite some years ago. It is no longer possible to have more souls on board than seats officially assigned to the plane.
Arun wrote:
Wouldn’t be Baby carriers/Manduca be uncomfortable for a mommy in a small plane?
My wife loved it. She had the baby, climbed into the plane with the baby in the carrier and typically both fell asleep quite quickly 
UdoR wrote:
It used to be, and I did that too, but is not so anymore. After one accident with a 6-seater (PA32) where 7 were seated in total (not in the 7-seat arrangement) and where all perished near the German coast German law has changed quite some years ago. It is no longer possible to have more souls on board than seats officially assigned to the plane.
Are you sure about that? This is taken from LuftBO § 19
(1) Luftfahrzeuge, die für die Beförderung von Personen oder Sachen verwendet werden, müssen ausgerüstet sein mit:
1
Einem Sitz für jede Person und einem Anschnallgurt für jeden Sitz; zwei Kinder mit einem Höchstalter bis zu zwei Jahren oder ein Kind mit einem Höchstalter bis zu zwei Jahren und ein Erwachsener können auf einem Sitz untergebracht werden; in Flugzeugen, die nicht in der Lufttüchtigkeitsgruppe Verkehrsflugzeuge zugelassen sind, und sonstigen Luftfahrzeugen mit einem höchstzulässigen Fluggewicht bis zu 5.700 kg können zwei Kinder mit einem Höchstalter bis zu 10 Jahren auf einem Sitz untergebracht werden, wenn dadurch die Sicherheit und Ordnung nicht gefährdet wird; Freiballone sind von den Vorschriften dieser Nummer ausgenommen;
Means that aircraft which are not used for commercial air transport and have an MTOW of 5700 or less, 2 children of up to 10 years age may share a seat when safety and security is not impacted.
LuftBo? Is that some old national german thing?
Means that aircraft which are not used for commercial air transport and have an MTOW of 5700 or less, 2 children of up to 10 years age may share a seat when safety and security is not impacted.
No.
The relevant text is NCO.IDE.A.140 Seats, seat safety belts, restraint systems and child restraint devices
Regulation (EU) 2019/1384
(1) a seat or berth for each person on board who is aged 24 months or more;
(2) a seat belt on each seat and restraining belts for each berth;
(3) a child restraint device (CRD) for each person on board younger than 24 months; and
(4) a seat belt with upper torso restraint system on each flight crew seat, having a single point release for aeroplanes having a CofA first issued on or after 25 August 2016.
AMC1 NCO.IDE.A.140 Seats, seat safety belts, restraint systems and child restraint devices
ED Decision 2019/019/R
CHILD RESTRAINT DEVICES (CRDs)
(a) A CRD is considered to be acceptable if:
(1) it is a supplementary loop belt manufactured with the same techniques and the same materials as the approved safety belts; or
(2) it complies with (b).
(b) Provided the CRD can be installed properly on the respective aircraft seat, the following CRDs are considered acceptable:
(1) CRDs approved for use in aircraft according to the European Technical Standard Order ETSO-C100c on Aviation Child Safety Device (ACSD);
(2) CRDs approved by EASA through a Type Certificate or Supplemental Type Certificate;
(3) Child seats approved for use in motor vehicles on the basis of the technical standard specified in (i). The child seat must be also approved for use in aircraft on the basis of the technical standard specified in either point (ii) or point (iii):
(i) UN Standard ECE R44-04 (or 03), or ECE R129 bearing the respective ‘ECE R’ label; and
(ii) German ‘Qualification Procedure for Child Restraint Systems for Use in Aircraft’ (TÜV/958-01/2001) bearing the label ‘For Use in Aircraft’; or
(iii) Other technical standard acceptable to the competent authority. The child seat should hold a qualification sign that it can be used in aircraft.
(4) Child seats approved for use in motor vehicles and aircraft according to Canadian CMVSS 213/213.1 bearing the respective label;
(5) Child seats approved for use in motor vehicles and aircraft according to US FMVSS No 213 and bearing one or two labels displaying the following two sentences:
(i) ‘THIS CHILD RESTRAINT SYSTEM CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS’; and
(ii) in red letters ‘THIS RESTRAINT IS CERTIFIED FOR USE IN MOTOR VEHICLES AND AIRCRAFT’;
(6) Child seats approved for use in motor vehicles and aircraft according to Australia/New Zealand’s technical standard AS/NZS 1754:2013 bearing the green part on the label displaying ‘For Use in Aircraft’; and
(7) CRDs manufactured and tested according to other technical standards equivalent to those listed above. The devices should be marked with an associated qualification sign, which shows the name of the qualification organisation and a specific identification number, related to the associated qualification project. The qualifying organisation should be a competent and independent organisation that is acceptable to the competent authority.
(c) Location
(1) Forward-facing child seats may be installed on both forward-and rearward-facing passenger seats, but only when fitted in the same direction as the passenger seat on which they are positioned. Rearward-facing child seats should only be installed on forward-facing passenger seats. A child seat may not be installed within the radius of action of an airbag unless it is obvious that the airbag is de-activated or it can be demonstrated that there is no negative impact from the airbag.
(2) An infant/child in a CRD should be located in the vicinity of a floor level exit.
(3) An infant/child in a CRD should not hinder evacuation for any passenger.
(d) Installation
(1) CRDs tested and approved for use in aircraft should only be installed on a suitable passenger seat by the method shown in the manufacturer’s instructions provided with each CRD and with the type of connecting device they are approved for the installation in aircraft. CRDs designed to be installed only by means of rigid bar lower anchorages (ISOFIX or equivalent) should only be used on passenger seats equipped with such connecting devices and should not be secured by passenger seat lap belt.
(2) All safety and installation instructions should be followed carefully by the responsible adult accompanying the infant/child. Operators should prohibit the use of a CRD not installed on the passenger seat according to the manufacturer’s instructions or not approved for use in aircraft.
(3) If a forward-facing child seat with a rigid backrest is to be fastened by a seat lap belt, the restraint device should be fastened when the backrest of the passenger seat on which it rests is in a reclined position. Thereafter, the backrest is to be positioned upright. This procedure ensures better tightening of the child seat on the aircraft seat if the aircraft seat is reclinable.
(4) The buckle of the adult safety belt should be easily accessible for both opening and closing, and should be in line with the seat belt halves (not canted) after tightening.
(5) Forward-facing restraint devices with an integral harness must not be installed such that the adult safety belt is secured over the infant.
(e) Operation
(1) Each CRD should remain secured to a passenger seat during all phases of flight unless it is properly stowed when not in use.
(2) Where a child seat is adjustable in recline, it should be in an upright position for all occasions when passenger restraint devices are required.
AMC2 NCO.IDE.A.140 Seats, seat safety belts, restraint systems and child restraint devices
ED Decision 2016/018/R
UPPER TORSO RESTRAINT SYSTEM
(a) The following systems are deemed to be compliant with the requirement for an upper torso restraint system:
(1) A seat belt with a diagonal shoulder strap;
(2) A restraint system having a seat belt and two shoulder straps that may be used independently;
(3) A restraint system having a seat belt, two shoulder straps and additional straps that may be used independently.
(b) The use of the upper torso restraint independently from the use of the seat belt is intended as an option for the comfort of the occupant of the seat in those phases of flight where only the seat belt is required to be fastened. A restraint system including a seat belt and an upper torso restraint that both remain permanently fastened is also acceptable.
SEAT BELT
A seat belt with a diagonal shoulder strap (three anchorage points) is deemed to be compliant with the requirement for a seat belt (two anchorage points).
I’m sorry that I don’t have much time for research, have just taken over a company and don’t sleep much recently
So thank you @Snoopy for pointing it out.
The result is: kids cannot share a seat anymore. I’m not sure whether there was another rule to restrict the total amount of POB to the amount of SOB (seats on board). – so whether a baby of 24 months or less can still sit together with an adult. I, for me, decided for the affirmative
(however, I can tell you, 7 POB in a Comanche is public transport and not fun)
Correct.
It used to be, and I did that too, but is not so anymore. After one accident with a 6-seater (PA32) where 7 were seated in total (not in the 7-seat arrangement) and where all perished near the German coast German law has changed quite some years ago. It is no longer possible to have more souls on board than seats officially assigned to the plane.
Not correct as cleared up in the meantime by Udo above. Until 24 months, an infant does not need a dedicated seat.
Example: 6 Seater PA32, 1 Pilot + 4 Adults in the back can each have one <24months infant on the lap with a CRD loop belt = 9 POB
Do ask:
Is it safe?
Is it legal?
Does it make sense?
Snoopy wrote:
(a) Aeroplanes shall be equipped with:
- a seat or berth for each person on board who is aged 24 months or more;
- a seat belt on each seat and restraining belts for each berth;
- a child restraint device (CRD) for each person on board younger than 24 months; and
- a seat belt with upper torso restraint system on each flight crew seat, having a single point release for aeroplanes having a CofA first issued on or after 25 August 2016.
AMC1 NCO.IDE.A.140 Seats, seat safety belts, restraint systems and child restraint devices (ED Decision 2019/019/R)
CHILD RESTRAINT DEVICES (CRDs)(a) A CRD is considered to be acceptable if:
- (1) it is a supplementary loop belt manufactured with the same techniques and the same materials as the approved safety belts; or
- (2) it complies with (b).
(b) Provided the CRD can be installed properly on the respective aircraft seat, the following CRDs are considered acceptable:
- (1) CRDs approved for use in aircraft according to the European Technical Standard Order ETSO-C100c on Aviation Child Safety Device (ACSD);
- (2) CRDs approved by EASA through a Type Certificate or Supplemental Type Certificate;
- (3) Child seats approved for use in motor vehicles on the basis of the technical standard specified in (i). The child seat must be also approved for use in aircraft on the basis of the technical standard specified in either point (ii) or point (iii):
(i) UN Standard ECE R44-04 (or 03), or ECE R129 bearing the respective ‘ECE R’ label; and
(ii) German ‘Qualification Procedure for Child Restraint Systems for Use in Aircraft’ (TÜV/958-01/2001) bearing the label ‘For Use in Aircraft’; or
(iii) Other technical standard acceptable to the competent authority. The child seat should hold a qualification sign that it can be used in aircraft.(4) Child seats approved for use in motor vehicles and aircraft according to Canadian CMVSS 213/213.1 bearing the respective label
(5) Child seats approved for use in motor vehicles and aircraft according to US FMVSS No 213 and bearing one or two labels displaying the following two sentences:
(i) ‘THIS CHILD RESTRAINT SYSTEM CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS’; and
(ii) in red letters ‘THIS RESTRAINT IS CERTIFIED FOR USE IN MOTOR VEHICLES AND AIRCRAFT’;(6) Child seats approved for use in motor vehicles and aircraft according to Australia/New Zealand’s technical standard AS/NZS 1754:2013 bearing the green part on the label displaying ‘For Use in Aircraft’; and
(7) CRDs manufactured and tested according to other technical standards equivalent to those listed above. The devices should be marked with an associated qualification sign, which shows the name of the qualification organisation and a specific identification number, related to the associated qualification project. The qualifying organisation should be a competent and independent organisation that is acceptable to the competent authority.
(c) Location
- (1) Forward-facing child seats may be installed on both forward-and rearward-facing passenger seats, but only when fitted in the same direction as the passenger seat on which they are positioned. Rearward-facing child seats should only be installed on forward-facing passenger seats. A child seat may not be installed within the radius of action of an airbag unless it is obvious that the airbag is de-activated or it can be demonstrated that there is no negative impact from the airbag.
- (2) An infant/child in a CRD should be located in the vicinity of a floor level exit.
- (3) An infant/child in a CRD should not hinder evacuation for any passenger.
(d) Installation
- (1) CRDs tested and approved for use in aircraft should only be installed on a suitable passenger seat by the method shown in the manufacturer’s instructions provided with each CRD and with the type of connecting device they are approved for the installation in aircraft. CRDs designed to be installed only by means of rigid bar lower anchorages (ISOFIX or equivalent) should only be used on passenger seats equipped with such connecting devices and should not be secured by passenger seat lap belt.
- (2) All safety and installation instructions should be followed carefully by the responsible adult accompanying the infant/child. Operators should prohibit the use of a CRD not installed on the passenger seat according to the manufacturer’s instructions or not approved for use in aircraft.
- (3) If a forward-facing child seat with a rigid backrest is to be fastened by a seat lap belt, the restraint device should be fastened when the backrest of the passenger seat on which it rests is in a reclined position. Thereafter, the backrest is to be positioned upright. This procedure ensures better tightening of the child seat on the aircraft seat if the aircraft seat is reclinable.
- (4) The buckle of the adult safety belt should be easily accessible for both opening and closing, and should be in line with the seat belt halves (not canted) after tightening.
- (5) Forward-facing restraint devices with an integral harness must not be installed such that the adult safety belt is secured over the infant.
(e) Operation
- (1) Each CRD should remain secured to a passenger seat during all phases of flight unless it is properly stowed when not in use.
- (2) Where a child seat is adjustable in recline, it should be in an upright position for all occasions when passenger restraint devices are required.
AMC2 NCO.IDE.A.140 Seats, seat safety belts, restraint systems and child restraint devices (ED Decision 2016/018/R)
UPPER TORSO RESTRAINT SYSTEM(a) The following systems are deemed to be compliant with the requirement for an upper torso restraint system:
- (1) A seat belt with a diagonal shoulder strap;
- (2) A restraint system having a seat belt and two shoulder straps that may be used independently;
- (3) A restraint system having a seat belt, two shoulder straps and additional straps that may be used independently.
(b) The use of the upper torso restraint independently from the use of the seat belt is intended as an option for the comfort of the occupant of the seat in those phases of flight where only the seat belt is required to be fastened. A restraint system including a seat belt and an upper torso restraint that both remain permanently fastened is also acceptable.
SEAT BELTA seat belt with a diagonal shoulder strap (three anchorage points) is deemed to be compliant with the requirement for a seat belt (two anchorage points).
Tried to edit for clarity.
So it’s either the little orange belt or a ‘certified’ seat according to its manual, like a airplane.
I think it’s worth checking with insurance, my certificate state max 4pob…I rented one SR22 in Toususs where insurance states max 4pob (the aircraft had 5 seats)
Snoopy wrote:
LuftBo? Is that some old national german thing?
It’s the Betriebsordnung für Luftfahrtgerät (LuftBO) – Operating regulations for aviation equipment.
This legislation, if no longer valid, should be removed from the statute books but it’s still there….other legislation which has been superseded is routinely removed with a note explaining when and through which new legislation it was replaced but it’s still appearing if you search for it…..
Snoopy wrote:
No.The relevant text is NCO.IDE.A.140 Seats, seat safety belts, restraint systems and child restraint devices
Regulation (EU) 2019/1384
I’m still doubting whether that is relevant. The EU regulation states that 2019/1384 is amending Regulations (EU) No 965/2012 and (EU) No 1321/2014 as regards the use of aircraft listed on an air operator certificate for non-commercial operations and specialised operations, the establishment of operational requirements for the conduct of maintenance check flights, the establishment of rules on non-commercial operations with reduced cabin crew on board and introducing editorial updates concerning air operations requirements.
Private aircraft do not fall under the rules of an Air Operator Certificate. Noting also that the German AIP Gen 1.6 refers specifically to LuftBO as the relevant national laws governing aircraft operation and if there is an exception there as noted above, which of these laws has priority if indeed 2019/1384 is to be complied with?
Oh how do I remember the time when I was discussing all this with others who involved themselves into our matters, because I wanted to fly with 5 POB (me plus a friend of mine and 3 kids in the back) to a nearby airfield in our clubs PA28. Seven people had 9 opinions.
We ended up not doing it anymore, because the “two kids on one seat” – option seems in fact to be not valid anymore.
