CARES Harness in middle seat?

Old Apr 16, 2023, 12:40 pm
  #1  
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CARES Harness in middle seat?

On board a B6 flight today, the FA came over mid-flight to tell us that we couldn't use our CARES harness in a middle seat. I was surprised since we've used it a few dozen times on different airlines and I've never heard of this rule. I looked on the B6 website and the only statement that is possibly relevant is

https://www.jetblue.com/help/traveling-with-children

Safety seats or CRS should be placed in a window seat.


The FAA defines a CRS as:

A CRS is a forward- or aft-facing hard-backed child safety seat.

Which seems to suggest that a CARES harness is distinct from a CRS and can be used anywhere. However, the FA showed me her manual which seems to specifically include a CARES harnes as a CRS. Anyone know what the correct interpretation of the rule is? And which form on Jetblue's website is the right one to get this clarified? Ideally, if this is Jetblue's policy to restrict CARES to window seats, I'd like to get them to say so on their website, not just on internal docs. This is a safety issue that we could have avoided (we had a window seat that we switched out of at the beginning of the flight and had we known we would have kept our toddler in the window seat but by the time they informed us at cruise it was too late to ask for our old seat back).
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Old Apr 16, 2023, 4:20 pm
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Your post is alarming but quite interesting. First of all, you use the pronoun "we." Who was flying? If both parents were with the child, did you have 2 aisle seats and 1 middle seat? Please clarify.

What was your reason for switching out of the window seat? (Just wondering). Then, are you saying that the Flight Attendant obligated your child to fly without a CRS (child-restraint-system) instead of allowing you to use the CRS in the middle seat, even though it seems that was your only option? Did the FA make any attempt to move you and your child to a window seat since, according to her and JetBlue's website, the CRS can only be used in a window seat? If you answered yes then no to the previous two questions, it seems you have a serious complaint on your hands.

As to your questions about JetBlue and FAA policies: First of all, a CARES harness is a CRS (child-restraint-system). Second of all, JetBlue's website does say that CARES seats are restricted to window seats because it says, "Safety seats or CRS should be placed in a window seat. It may be placed in a middle seat or aisle seat as long as the other seat(s) remain empty. Safety seats may not obstruct a customer’s pathway to the aisle. Safety seats may not be placed between two individuals." Finally, the FAA website confirms that you should, "Reserve adjoining seats. A CRS must not block the escape path in an emergency. Many airlines have policies that require a CRS to be placed in a window seat. Do not place a CRS in an exit row."

Personally, I found your post very interesting because my family and I are taking a 5-hour international flight in less than 2 weeks, and we will be trying out the CARES harness for the first time. Our return flight is on JetBlue. Thanks for this valuable information and I look forward to hearing your response!
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Old Apr 16, 2023, 8:09 pm
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You understand why child restraint systems need to go in the window seat right? Because if you do I would have never thought to put the kid anywhere other than the window seat.
And yes I have traveled with a toddler in a car seat.
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Old Apr 16, 2023, 9:17 pm
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To answer first question: We were both parents with two children, one in CARES and one older. We booked Window-aisle-aisle-window, with the knowledge that people are always happy to switch to a better seat if it ends up being a full flight. My wife, who was sitting with the toddler, offered the window to the person ticketed for the middle and put toddler in middle and herself in aisle.

As to the second piece, I was about to write a response about why I think CARES is excluded from CRS and decided to dig a little deeper. Seems that the source of the confusion has been known to the FAA for some time now
https://www.amsafe.com/wp-content/up...n-Aircraft.pdf
Avoiding Consumer Confusion. The FAA recognizes that the term “child restraint system” was originally used to refer to child restraints meeting the requirements of FMVSS No. 213 and designed to perform effectively in motor vehicles. However, in recent rulemakings, the FAA uses the term “child restraint system” to describe any approved seat or device used to restrain children on aircraft regardless of whether or not it complies with the requirements of FMVSS No. 213. To reduce consumer confusion between a CRS meeting the requirements of FMVSS No. 213 (safe for use in motor vehicles) and a CRS designed only for use in aircraft (not safe for use in motor vehicles), the FAA has introduced a new term referring to a CRS only approved for aviation use. The FAA will call these aviation-only restraints an ACSD. Regulations regarding the use of a CRS in aircraft also apply to an ACSD. Figure 1 is an example of an ACSD (also shown in paragraph 13).
So at one point CRS excluded the CARES harness, but now includes the CARES harness...sometimes...in order to avoid confusion. Oh well.
Anyway, I think that things could be a lot clearer since some airlines have different rules for CARES harnesses than car seats. It shouldn't take reading an FAA advisory to airlines for pax to understand the rules.
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Old Apr 16, 2023, 9:20 pm
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Originally Posted by SWCPHX
You understand why child restraint systems need to go in the window seat right? Because if you do I would have never thought to put the kid anywhere other than the window seat.
And yes I have traveled with a toddler in a car seat.
I understand why car seats need to go in a window seat. Because they are bulky and could create an obstruction when trying to escape in an emergency, so you don't want anyone sitting "inside" of a car seat. That has always made perfect sense to me.
By the same logic, a CARES harness should not have such a rule, since it effectively takes up no more extra space than the seat itself. Someone trying to escape from the window would have no more trouble getting out if there is a CARES harness in the middle seat. Is there another reason I'm missing?
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Old Apr 16, 2023, 9:38 pm
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Originally Posted by dblumenhoff
I understand why car seats need to go in a window seat. Because they are bulky and could create an obstruction when trying to escape in an emergency, so you don't want anyone sitting "inside" of a car seat. That has always made perfect sense to me.
By the same logic, a CARES harness should not have such a rule, since it effectively takes up no more extra space than the seat itself. Someone trying to escape from the window would have no more trouble getting out if there is a CARES harness in the middle seat. Is there another reason I'm missing?
The extra time it may take to unbuckle a CARES harness may be just as bad as a carseat physically blocking egress in an emergency.
The truth is that somebody probably argued a CARES harness wasn't a carseat but like any rule or policy it got solved with all the bluntness of a hammer and got declared a carseat or CRS so that nobody had to think about what it is and could just say it should go in the window seat.
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Old Apr 17, 2023, 12:00 pm
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Any harnesses or seat devices need to go in a window seat. In the event of an emergency, if in a middle or aisle seat it could impede the evacuation of whoever is in the exterior-most seat(s). This is an FAA requirement and while I don't know the specific citation it is enforced in air crew training programs.

-J.
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Old Apr 17, 2023, 1:43 pm
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Originally Posted by GW McLintock
This is an FAA requirement and while I don't know the specific citation it is enforced in air crew training programs.
It is not an FAA requirement. See below what the FAA says:

https://www.faa.gov/travelers/fly_children
A CRS must not block the escape path in an emergency. Many airlines have policies that require a CRS to be placed in a window seat.

It is up to the discretion of the airlines whether having a CRS in a non-window seat would block the escape path in an emergency (and as CARES harnesses don't impede anything, an airline not taking a "bluntness of a hammer" approach per SWCPHX might distinguish between the two in its policymaking).

Case in point, Southwest permits in window or middle (but not aisle): https://www.southwest.com/help/flyin...g-with-infants
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Old Apr 17, 2023, 1:50 pm
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Originally Posted by dblumenhoff
It is not an FAA requirement. See below what the FAA says:


It is up to the discretion of the airlines whether having a CRS in a non-window seat would block the escape path in an emergency (and as CARES harnesses don't impede anything, an airline not taking a "bluntness of a hammer" approach per SWCPHX might distinguish between the two in its policymaking).

Case in point, Southwest permits in window or middle (but not aisle): https://www.southwest.com/help/flyin...g-with-infants
I was led to believe it was an FAA thing, but clearly that is not the case.

Regardless, it's a JetBlue thing. Flight attendants are instructed this during training and it's in their flight attendant manual, which do have to be regularly updated and approved by the FAA. So take that however you want, but for JetBlue to be able to operate under FAA jurisdiction, they (JetBlue in this case, and more specifically the FAA wants JetBlue to) want harnesses in the window seat. At JetBlue this will include any type of device such as a harness, car seat, or even a portable oxygen concentrator. Again this is all in their flight attendant manual (which again is an FAA-approved document), though I'm not about to cite the chapter and section on a public forum.

-J.
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Old Apr 17, 2023, 2:10 pm
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Originally Posted by GW McLintock
I was led to believe it was an FAA thing, but clearly that is not the case.

Regardless, it's a JetBlue thing. Flight attendants are instructed this during training and it's in their flight attendant manual, which do have to be regularly updated and approved by the FAA. So take that however you want, but for JetBlue to be able to operate under FAA jurisdiction, they (JetBlue in this case, and more specifically the FAA wants JetBlue to) want harnesses in the window seat. At JetBlue this will include any type of device such as a harness, car seat, or even a portable oxygen concentrator. Again this is all in their flight attendant manual (which again is an FAA-approved document), though I'm not about to cite the chapter and section on a public forum.

-J.
Yes, I get that now (and the FA even showed me the manual inflight, which I appreciated). And I know that when airlines put it in their manual they are obligated to follow it even if the FAA doesn't specifically mandate it*. I just checked a few other airlines to see how they handle it:
DL and AA - window "preferred' for car seats
F6 - window "suggested" for car seats
WN - window or middle for car seats
UA - window for car seats (CARES harness in separate section with no specification - unclear which rules apply to it).
NK - nothing about location for anything (other than not in exit row)

My main point is that B6 has a stricter requirement than all other airlines wrt the CARES harness being in only a window seat. They should be clearer about it on their website if they have stricter rules. They have the same language from the manual about CRS only being in the window, but don't have the definition of a CRS available publicly (whereas it is clearly defined in their FA manual), and the only publicly available definition of CRS is the FAA's "hard-backed seat".

*As an aside, it drives me nuts when they then claim that "the FAA requires", for instance "the FAA limits you to one carry on and one personal item". The airline chose to put that in their manual, which the FAA approved, and then you're obligated to follow it. Don't pass it off to the FAA when it was an airline decision.
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Old Apr 19, 2023, 2:02 am
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Hi dblumenhoff, I would like to repeat my previous questions to you because they were not answered (no problem!) and I do feel that the answers would not only shine some light on how JetBlue treats its customers, but also inform if you (or other future customers) have the chance to get some sort of refund/compensation for your trouble. My questions are: Did the Flight Attendant obligate your child to fly without a CRS (child-restraint-system) instead of allowing you to use the CRS in the middle seat, even though it seems that was the only option? And, did the FA make any attempt to move your wife and your child to a window seat since, according to the FA and JetBlue's website, the CRS can only be used in a window seat?

As I stated before, if you answered yes then no to the previous two questions, it seems you have a serious complaint on your hands.
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