Exit Row With Underage Child in Reservation
Aug 20, 2018, 1:34 pm
#76
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If I'm not in F/C I'm in 21C, and I know how to decipher what the rule re 15 & under means.
Many very astute and knowledgeable (long time) posters have pointed out the rule on here, and it's literal meaning, but a misinterpretation and parsing of the word "OR" for one's own benefit ain't gonna cut it. I have over the years booked all of my family as adults, and UA's reservation system doesn't know the difference. I have never placed any of my grandkids, who at the time, were under 15 in the awkward position of having to be relocated during the boarding process.
perhaps further research as to what the rule actually states would be territory to venture into.
Last edited by WineCountryUA; Aug 20, 2018 at 1:36 pm Reason: Removed overly personal comment
Aug 20, 2018, 1:43 pm
#77
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Or maybe they simply made their own more explicit rule to avoid these sorts of problems. (I'm guessing it's this one.)
Again, has anyone here ever seen an exit-row passenger asked for ID? I sure haven't. Either airlines are hard-coding a restriction into their systems or this isn't nearly as hard-and-fast of a rule as some are claiming.
Again, has anyone here ever seen an exit-row passenger asked for ID? I sure haven't. Either airlines are hard-coding a restriction into their systems or this isn't nearly as hard-and-fast of a rule as some are claiming.
In the FAA's guidance to flight attendants on enforcement of exit row rules, they word it very slightly differently which makes it a bit more clear:
Is the person less than 15 years of age or does the person lack the capacity to perform one or more of the functions listed in §§ 121.585(d) and 135.129(d) without the assistance of an adult companion, parent, or other relative?
Last edited by Sykes; Aug 20, 2018 at 1:49 pm
Aug 20, 2018, 5:00 pm
#78
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It's a hard and fast rule, you're just interpreting it differently than the FAA does. I pinged a friend who is an Aviation Safety Inspector with the FAA and he confirmed that 15 years of age is a hard-and-fast rule. Further, placards carry the weight of regulation, so if they exist they must be followed.
In the FAA's guidance to flight attendants on enforcement of exit row rules, they word it very slightly differently which makes it a bit more clear:
In that case, it's slightly more clear that it is two separate clauses, and if either of them are true then the person is exit row ineligible.
In the FAA's guidance to flight attendants on enforcement of exit row rules, they word it very slightly differently which makes it a bit more clear:
In that case, it's slightly more clear that it is two separate clauses, and if either of them are true then the person is exit row ineligible.
Last edited by WineCountryUA; Aug 20, 2018 at 6:37 pm Reason: discuss the issue;not the poster(s)
Aug 20, 2018, 5:16 pm
#79
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If this is the case, it sounds like the FAA has outsourced their regulation-writing and/or rules-enforcing to people who don't speak fluent English. As I mentioned earlier, the phrase "if the certificate holder determines" unambiguously grants discretion to the carriers. It's absurd that that phrase can somehow be "interpreted" to mean the exact opposite — i.e., that carriers actually have no discretion whatsoever.
a) For example, if a passenger is being evaluated for assignment to an exit seat, age (with the exception of those younger than 15 years of age) or the size of a person alone should not be the determining factors. The airline employee must evaluate the individual’s physical and mental capabilities and other conditions, as clearly outlined in the selection criteria. If that individual meets all the selection criteria, then age or size alone should not be a disqualifying factor.
b) However, if that individual has difficulty walking and lifting his or her own
carry-on luggage, then the application of the neutral criteria would exclude this individual from being assigned an exit seat because it would appear by observation that the individual would not be able to move expeditiously and perform the tasks involved in the emergency evacuation.
b) However, if that individual has difficulty walking and lifting his or her own
carry-on luggage, then the application of the neutral criteria would exclude this individual from being assigned an exit seat because it would appear by observation that the individual would not be able to move expeditiously and perform the tasks involved in the emergency evacuation.
In practice, it doesn't really matter how bad the regulation is written since everyone that matters (the FAA and the airlines) are interpreting it the same way, and the airlines are required to design and implement a more prescriptive exit seating program into their FAA-approved policies and procedures, and those policies and procedures also carry the weight of regulation once they are approved.
Last edited by Sykes; Aug 20, 2018 at 5:22 pm
Aug 20, 2018, 5:21 pm
#80
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In practice, it doesn't really matter how bad the regulation is written since everyone that matters (the FAA and the airlines) are interpreting it the same way, and the airlines are required to design and implement an exit seating program into their FAA-approved policies and procedures, and those policies and procedures also carry the weight of regulation once they are approved.
If there truly was a hard-and-fast "no children under 15" policy on United, then what are the odds of a GA and a plane full of FAs all turning their heads and ignoring policy on the same flight for some family none of them knows? That would be a hell of a breakdown. It also remains unexplained why seating systems that allow or disallow seat assignments based on status or fare paid wouldn't be hard-coded to disallow anyone under 15. Doing that would be a lot easier than trusting GAs and FAs to make the right call 100% of the time on thousands of daily flights, wouldn't it?
Aug 20, 2018, 5:29 pm
#81
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Still, you probably should have notified the crew if you and your family were uncomfortable in the exit row.
Aug 20, 2018, 5:58 pm
#82
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You can keep doubting it, but the fact is that the age limit is regulatory, and it is enforced that way.
Given the state of United's IT, I'm guessing it isn't a priority since in the end the GAs and FAs have to do the final verification anyway. Age is only one of many factors that affect exit row eligibility, and even if the system prevents that seat assignment, people often end up swapping seats once on-board anyway.
Aug 20, 2018, 6:06 pm
#83
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On a single flight out of thousands in a given day? Pretty high. If you read enough threads on FlyerTalk, you'll see FT members witnessing regulatory violations all the time. I wouldn't expect to see such a breakdown often, but it definitely happens from time-to-time. The FAA's philosophy on risk management assumes that there will be gaps at points along the way because no individual measure is perfect.
You can keep doubting it, but the fact is that the age limit is regulatory, and it is enforced that way.
You can keep doubting it, but the fact is that the age limit is regulatory, and it is enforced that way.
Given the state of United's IT, I'm guessing it isn't a priority since in the end the GAs and FAs have to do the final verification anyway. Age is only one of many factors that affect exit row eligibility, and even if the system prevents that seat assignment, people often end up swapping seats once on-board anyway.
Aug 20, 2018, 6:23 pm
#84
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It also remains unexplained why seating systems that allow or disallow seat assignments based on status or fare paid wouldn't be hard-coded to disallow anyone under 15. Doing that would be a lot easier than trusting GAs and FAs to make the right call 100% of the time on thousands of daily flights, wouldn't it?
Ever since I began traveling with my daughter starting at 3 months (she is 3 and a half now), exit rows are blocked off for me every time I’m traveling with her. Happens every time, even when the seat map of a new reservation without a child allows it. So it does do that. The question is why or how an agent can do it in this case Seating systems that disallow certain seats for certain individuals have exceptions to them, and GAs need to do this all the time. By definition, those sitting in BE should never be in anyE+ seat, but go to that thread and see the instances being reported just there - imagine if it’s being reporters on here so much, how much it must happen in general. Difference is BE being disallowed from E+ is a choice UA makes for their own benefit. This is a safety issue.
IMO, there might be some 13 year olds who could open an exit door - even some who might be able to do so in the stress of an emergency. But I’d guess these are the exception, and be majority wouldn’t/couldn’t. For that matter, I bet there are a number of adults that might not be able to handle that responsibility in the heat of the moment, but far fewer.
Biggest problem of exit row seating these days, IME, is that carriers charge for it like it is any other extra legroom seat, promoting it as such, instead of that those in those seats need to be prepared to help in a worst case scenario. So now you have people that don’t really want to help in an emergency, just looking to score a more comfortable seat, and paying for the privilege. No, most sitting there aren’t going to be needed, but the wrong person in that seat on the wrong flight could mean the difference between survivors in the event of a crash or not. I don’t think carriers should be taking that risk (but this last paragraph is probably fodder for a different thread).
Aug 20, 2018, 6:26 pm
#85
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I don't really expect me to trust me on the issue though. I'm pretty sure the acting FAA administrator himself could show up to the thread and you still wouldn't believe him.
Aug 20, 2018, 6:32 pm
#86
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Ever since I began traveling with my daughter starting at 3 months (she is 3 and a half now), exit rows are blocked off for me every time I’m traveling with her. Happens every time, even when the seat map of a new reservation without a child allows it. So it does do that. The question is why or how an agent can do it in this case.
IMO, there might be some 13 year olds who could open an exit door - even some who might be able to do so in the stress of an emergency. But I’d guess these are the exception, and be majority wouldn’t/couldn’t. For that matter, I bet there are a number of adults that might not be able to handle that responsibility in the heat of the moment, but far fewer.
Last edited by joe_miami; Aug 20, 2018 at 6:37 pm
Aug 20, 2018, 6:35 pm
#87
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Yup, the guy I texted whose job is overseeing airline operations. You won't find any enforcement actions because the vast majority of the time issues are resolved privately and without enforcement action. It's only with extremely serious systemic issues that these kinds of things become public (and even in the linked story the specific details of the violations were not made public).
I don't really expect me to trust me on the issue though. I'm pretty sure the acting FAA administrator himself could show up to the thread and you still wouldn't believe him.
I don't really expect me to trust me on the issue though. I'm pretty sure the acting FAA administrator himself could show up to the thread and you still wouldn't believe him.
Aug 20, 2018, 6:44 pm
#88
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It's bizarre that anyone would have to "trust" anyone here. We're not debating proprietary information. If there was an explicit FAA rule affecting the public, it should be easy to cite. But 24 hours into the discussion, all we have are a citation to FAA regs that unambiguously grant discretion to the carriers, plus someone claiming he texted someone.
Aug 20, 2018, 6:51 pm
#89
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It's bizarre that anyone would have to "trust" anyone here. We're not debating proprietary information. If there was an explicit FAA rule affecting the public, it should be easy to cite. But 24 hours into the discussion, all we have are a citation to FAA regs that unambiguously grant discretion to the carriers, plus someone claiming he texted someone.
In any event, from what I can tell, you seem to be the only one that thinks the under-15 rule is optional, and for everyone else, it’s clear as day.
If you need further proof, here is what the USDOT says on the matter ( https://www.transportation.gov/indiv...family-seating )
- FAA regulations prohibit children under 15 and passengers caring for small children from sitting in exit row seats. Please contact your specific airline for more information on its exit row policy.
Aug 20, 2018, 6:58 pm
#90
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From the FAA perspective, there's no difference. Not only would there be a concern that the adult's first priority would be the child, but everyone in the emergency exit row is responsible for the exit door, not just the window passenger. The window seat could be empty, the window passenger could be in the lavatory -- heck, the window passenger could already have been incapacitated.
The rule has been cited several times, and the intent is unambiguous, and it's not what you've repeatedly claimed that it is. Several different sources have been presented to show you that the intent of the rule is that no one may be seated in the exit row under 15 years of age. You continue to parse an "or" which appears to be sloppy writing, is ambiguous at best, and which would never be interpreted the way that you claim, because your interpretation makes the age restriction superfluous. Regulations (and laws) are intended to be read with the understanding that unnecessary words are not added, so that if you have two conflicting interpretations, one of which would make part of the phrase superfluous, the other one is correct. Put another way: the FAA would not bother coming up with an age clause if the intent was that certificate holders could disregard it.
The phrase "if the certificate holder determines" unambiguously grants discretion to the carriers in this area. It's much more likely that the GA chose to exercise discretion than it is that the GA and a plane full of FAs all recklessly ignored a United and/or FAA policy for a family they don't even know.