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115 This chapter draws on the findings from the analyses in the previous chapters to offer a summary assessment, albeit preliminary, of the techni- cal feasibility of an in-cabin wheelchair securement system concept. After reviewing the available information, the preceding chapters did not identify any technical issues that seem likely to present design and engineering chal- lenges so formidable that they call into question the technical feasibility of an in-cabin wheelchair securement system and the value of exploring the concept further. While the chapter analyses and findings suggest that equip- ping enough airplanes with securement systems to provide meaningful levels of airline service would require substantial effort, the types of cabin modifi- cations required to provide the needed space and structural support would likely be of moderate technical complexity for many individual airplanes. Further evaluation and assessments, including efforts to fill the information gaps identified in this report, would appear to be warranted, particularly to understand how personal wheelchairs secured in an airplane cabin are likely to perform relative to the Federal Aviation Administrationâs (FAAâs) safety criteria in restraining and protecting occupants during a survivable crash or emergency landing. Such follow-on assessments are warranted because the many techni- cal issues that could be assessed using the information at hand appear to be manageable from an engineering perspective. Concerted efforts to un- derstand and address the remaining technical uncertainties through more focused analysis and testing would enable more informed public policy considerations about the systems and their potential to expand air travel opportunities for people with significant disabilities. Indeed, the Statement 5 Assessment of Findings and Recommended Next Steps
116 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL of Task for this study calls on the committee to make recommendations on the additional research, information gathering, and technical analyses needed to inform public policy choices about in-cabin wheelchair secure- ment systems. Before summarizing the studyâs key findings and presenting the commit- teeâs conclusions and recommendations, the next section provides a recap of the objectives, reasoning, and analyses undertaken in each of the previous four chapters in accordance with the task items in the study committeeâs charge. In this regard, it is important to restate that the committee was not asked to define the optimal securement implementation for any given airplane and operational condition or to demonstrate how an in-cabin wheelchair securement system implementation could be designed and engi- neered to satisfy all constraints. The study was intended to be a preliminary feasibility assessment, as in-cabin wheelchair securement systems at this time are conceptual only. A central aim of this report, therefore, is to frame the technical challenge and its magnitude and check for technical issues and uncertainties that could impede the conceptâs realization, thus highlighting areas for follow-on information gathering and assessment. Consideration is also given to some of the airline operational and pas- senger accommodation issues that could arise in implementing wheelchair securement systems. Central to these considerations is the presumption that the systems should allow people to remain seated in their personal wheel- chairs for access to ample flight offerings to and from places they want to go, as opposed to being available sporadically or on only a handful of scheduled flights. Numerous operational issues arise from this presumption, such as ensuring that (1) a sufficient number of airplanes (although not nec- essarily all or even most) is equipped with securement systems, (2) requisite service assistance is available to passengers who choose to use the systems, and (3) efficient and standardized means are instituted to verify that a personal wheelchair meets all applicable eligibility requirements before ticketing and boarding. While these and several other operational and ac- commodation issues are noted, a more thorough treatment of them would be premature at this early stage when an in-cabin wheelchair securement system remains a concept and there is limited information available for assessing important factors such as system demand and use characteristics. The chapter concludes with recommendations for next steps. They are focused on developing the information needed to fill identified gaps in un- derstanding of certain technical issues and the potential for user demand. RECAP OF CHAPTER TOPICS AND OBJECTIVES The committee has framed the question of âtechnical feasibilityâ in keep- ing with the key interest that motivated the request for this study. The
ASSESSMENT OF FINDINGS AND RECOMMENDED NEXT STEPS 117 committee presumes that the interest, as noted above and for reasons explained more fully in Chapter 1, is for people who are nonambulatory and have significant disabilities to have access to ample flight offerings that will enable them to fly to and from places they want to go while seated in their personal wheelchairs. An emphasis on being seated in a personal wheelchair during flight is fundamental to the studyâs charge because it stems from a concern that people who have significant disabilities and use wheelchairs are not always able to board an airplane, transfer to and from a conventional passenger seat, and remain in that seat for the duration of a flight without significant discomfort, pain, and risk of injury. The idea is that by having the ability to fly while seated in a personal wheelchair that is customized to their medical and physical needs, travelers can avoid these hardships and also use their personal wheelchair (as opposed to a wheelchair optimized for air travel) at the destination. A securement system concept that has the potential to be used on many airplanes, and thus in many travel markets, is also fundamental to the study charge, becauseâas noted aboveâniche implementation would provide limited utility even if technically feasible. Indeed, an emphasis on meeting these two conditionsâ providing transportation service to people when seated in their personal wheelchairs and ensuring that travelers are afforded ample service options (i.e., flight offerings)âis the norm for the accommodation of people who use wheelchairs on most other modes of transportation. With these two conditions in mind, Chapter 2 provides background on the population of personal wheelchairs in common use, the means by which wheelchairs are secured when used as seats in transportation, the structure of airline service, and the airplanes used for this service, including their seat- ing and other relevant features of cabin interiors. The chapter also provides background on the role of the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) in developing standards for wheelchair safety in transportation. Because safe performance is critical for all modes of transportation including air travel, Chapter 3 explores the challenges associated with designing and implementing a wheelchair securement system that can sat- isfy FAAâs aviation safety requirements. FAA closely regulates airlines and airplanes for safety assurance, and a large body of the regulations focuses on the ability of the airplane cabin and seating systems to protect pas- sengers and crew in the event of a survivable crash or emergency landing. Understanding how a secured wheelchair would perform during such an event, when considering the safety of the wheelchair occupant and other airplane passengers and crew, is imperative. FAA crashworthiness criteria for airplane seats and cabin interiors are thus described and compared to criteria developed by RESNA for the crashworthiness of wheelchairs in motor vehicle transportation. Side-by-side comparisons of the two sets of
118 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL crash performance criteria are complicated because each was established for different operating and crash environments. An important point, however, is that the RESNA standards establish a baseline minimum level of crash and safety performance that many commonly used wheelchairs comply with today and that more wheelchairs could be designed to comply with in the future, potentially facilitating future conformance to FAA safety criteria. While safety considerations will dictate many aspects of the design and implementation of a wheelchair securement system, physical space in the airplane cabin will have a significant effect as well. The airplane must have the requisite space for commonly sized wheelchairs to board, deplane, and maneuver to and from a sufficiently sized and structurally supported secure- ment location. These considerations are examined in Chapter 4 by estimat- ing the clearances and clear spaces required and then comparing them to the dimensions of airplane doors and cabin interiors. The comparisons suggest that a wheelchair securement place that provides sufficient clearance and clear space could be created in the front of the cabin of many airplanes; however, due to variability in cabin sizes, features, and interior layouts, it is not possible to conclude that this would be the preferred or most fea- sible installation location for all airplanes. An illustration of a securement location implemented in one of the most common interior layouts of the most common airplane family in the U.S. airline fleet provides insight into whether space availability could present significant technical challenges to the implementation of securement systems on enough airplanes to provide travelers with ample flight options. In the sections that follow, the key findings from these chapters are highlighted and assessed to identify any technical issues that have the po- tential to present major design and engineering challenges to the feasibility of an in-cabin wheelchair securement system concept. Where more informa- tion is needed to gauge this potential, those gaps are identified. Of course, choices about whether and how to implement an in-cabin wheelchair securement system will depend on factors beyond technical feasibility. The economic implications for airlines from systems that may reduce the number of passenger seats in an airplane in total or by fare class will almost certainly create real challenges to implementation and ac- ceptance. The displacement of seats could be particularly problematic for smaller airplanes that already have limited seating capacity. Such economic issues were not addressed in this study under the premise, as explained in Chapter 1, that the addition of any in-cabin wheelchair securement system would likely lead to a net reduction in passenger seats given the constrained interior space of an airplane and the existing norm of tightly spaced seating configurations. However, it is reasonable to assume that Congress would have recognized this likelihood when it asked for this feasibility study and that adding any constraint to the contrary (i.e., to predicate technical
ASSESSMENT OF FINDINGS AND RECOMMENDED NEXT STEPS 119 feasibility on an airplane without displaced seats) would have set a very high bar for a preliminary assessment of technical feasibility. ASSESSMENT OF FINDINGS ON TECHNICAL FEASIBILITY ISSUES It bears repeating that the purpose of this report is to provide a preliminary assessment of the technical feasibility of in-cabin wheelchair securement systems. The focus, therefore, has been on identifying any technical chal- lenges that could be significant obstacles to the development and implemen- tation of a system able to provide ample flight offerings to people who are nonambulatory. To do so, the committee considered technical challenges with respect to the following three areas: (1) whether airplanes common to airline service have enough physical space to enable a power or manual wheelchair to enter and exit the cabin and maneuver to and from a secure- ment location that is sufficiently sized for the functioning of the securement system and essential wheelchair seat position adjustments; (2) whether an airplane floor structure can accommodate the loadings imparted by an oc- cupied power wheelchair; and (3) whether a secured personal wheelchair could meet the crashworthiness, occupant injury protection, and other safety assurance requirements of FAA. The analyses in this report, and specific findings cited next, indicate that airplane interior space and structure should not present major technical challenges to an in-cabin securement system that could be implemented on a wide enough basis to afford users meaningful levels of flight service. The safety assurance challenge, however, is more difficult to characterize in the absence of specific technical evaluations of how secured wheelchairs would perform in accordance with all of FAAâs crashworthiness requirements. Findings on Airplane Physical Space and Structure Sufficient numbers of airplanes would need to have cabin interiors with the requisite clearances and clear spaces for occupied personal wheelchairs of common types and sizes to (1) enter and exit through the boarding door- way, (2) move within the cabin to and from the securement location, (3) maneuver into and out of the securement location, and (4) be positioned for securement. Airplane floor and structural support in the airplane would need to be able to accommodate the load imparted by the heaviest occupied power wheelchair. With respect to each of these physical space and structural require- ments, the committee finds the following: ⢠The more than 6,000 airplanes active in the U.S. passenger air- line fleet belong to fewer than 10 major airplane families, each
120 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL consisting of different models. While specific interior layouts can differ widely among these models and even among individual air- planes of a given model, certain dimensions such as doorway and cabin interior widths are uniform for all airplanes in a given fam- ily. Airplanes in just two of the families of narrow-body aircraft, the Boeing 737 and the Airbus A320, are predominant in the fleet and account for most domestic airline enplanements and depar- tures. Therefore, an assessment centered on the ability of these two ubiquitous airplane families to provide the needed interior clear- ances and clear spaces is more manageable and can provide critical insight into whether physical space is likely be a major technical challenge for ensuring that securement systems can be installed on enough airplanes to achieve meaningful levels of air transporta- tion service (e.g., service availability in at least all high-demand markets). ⢠The current population of manual and power wheelchairs in the United States consists of hundreds of models with differing sizes, performance levels, and configurations; however, the vast majority have dimensions and operating capabilities that enable them to maneuver within the clearance and clear space parameters specified in the Americans with Disabilities Act (ADA) access guidelines. The parameters in these widely used and influential guidelines, which have the effect of creating some uniformity in certain wheelchair dimensions, enable the committee to estimate maximum wheelchair dimensions for the purpose of estimating minimum cabin space and clearance requirements. On the basis of these estimates, the com- mittee concludes that the passenger cabins of airplanes that provide much of the countryâs airline service would have sufficient space for the securement of most occupied wheelchairs. ⢠Comprehensive testing data of common power wheelchair models enable a reliable estimate that 850 lb is the maximum occupied weight of a wheelchair that would need to be supported by an airplaneâs structure at the securement location. ⢠Door dimensions of all airplanes in the U.S. passenger fleet are known. They indicate that the boarding door openings of the vast majority of airplanes could accommodate passage into and out of the cabin by a large majority of wheelchairs. The data indicate that the left forward door is the widest on most airplanes and would provide the fewest physical constraints on access, both with respect to clearing the doorway and accessing the door from the airport gate through the usual positioning of passenger boarding bridges. ⢠Maneuvering the wheelchair between the entryway and cabin aisle entails the execution of a 90-degree turn requiring two
ASSESSMENT OF FINDINGS AND RECOMMENDED NEXT STEPS 121 perpendicular 36- à 60-in. clear spaces. Irrespective of the door used by the wheelchair to enter and exit the airplane, many air- planes would have one or more interior features that intrude on these clear spaces to impede the 90-degree turn. These features would need to be resized or relocated to provide the needed space. ⢠A securement area located near the door used for boarding and deplaning is likely to require fewer changes to aisle widths than a location deeper into the cabin because aisle widths in nearly all air- planes are too narrow for the vast majority of personal wheelchairs to pass through unimpeded. ⢠The removal of two successive rows of seats should provide a securement area with sufficient floor and underlying structural support for the load imparted by an occupied power wheelchair, employing pallet systems that are commonly used for distributing loads across seat tracks and structure. ⢠The removal of two successive rows of seats should provide suf- ficient room for a 30- à 60-in. space for a wheelchair securement as specified in the ADA and wheelchair industry guidelines for requisite clear spaces. That space should also be sufficient for the wheelchair to maneuver laterally between the aisle and the secure- ment space without requiring changes to other seating or to aisle widths. Although confident that (1) the main boarding doors on airplanes ac- counting for much of the countryâs airline service have sufficient clearance to accommodate wheelchairs and (2) the removal of two successive rows of seats would provide the needed space and structural support for a se- curement location, the committee notes that the heterogeneity of airplane interiors precludes definitive determinations about the specific interior mod- ifications that would be required to remove, resize, or relocate features that could impede a wheelchair maneuvering the 90-degree turn between the entryway and passenger seating area. In some airplanes, these modifications might present major technical challenges, particularly if the affected feature is an essential galley or lavatory that cannot be relocated. The challenges associated with relocating such a feature could make the implementation of a securement system infeasible for some airplanes. While the precise number of airplanes in the airline fleet that could not accommodate a wheelchair securement system due to unalterable or im- movable interior features cannot be determined from available information, physical constraints of this type are not likely to be a problem for a large share of airplanes because the most common interior layout of airplanes in the ubiquitous Boeing 737 family would only require the removal or resiz- ing of an entryway closet. The common and similarly sized airplanes in the
122 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL Airbus A320 family, where a closet in the same location is the norm, would add further to the share of the fleet that would not appear to have a major physical constraint to the placement of a wheelchair securement location at the very front of the passenger cabin. Findings on FAA Crashworthiness Requirements FAA has not established safety standards that apply to wheelchair secure- ment systems or wheelchairs being used as seats in airplanes. The main body of FAA safety regulations that applies to passenger cabins focuses on ensuring that airplane seats are crashworthy and do not impede the ability of occupants to rapidly evacuate in the event of a survivable crash or emer- gency landing. The committee cannot know how FAA would treat secured wheelchairs in terms of requiring strict compliance with all crashworthiness criteria. Personal wheelchairs are not optimized for airplane transportation and crash environments, and their specific designs with custom features will vary far more than conventional airplane seats that must be certified by FAA. Wheelchairs have not been tested comprehensively for compliance with FAA crashworthiness criteria applicable to airplanes, and securement systems intended specifically for airplane cabin applications have not been developed for such wheelchair crashworthiness testing and evaluation. With respect to the crash performance of wheelchairs, the committee finds, on the basis of motor vehicle crash performance standards, that per- sonal wheelchairs can be, and often are, designed and constructed to do the following: ⢠Retain their form, stay upright with the restrained occupant re- maining in a seated posture, and retain their battery when subject to 20-g impact forces characteristic of a 30-mph frontal motor vehicle crash when the wheelchair is secured to the vehicle by a system demonstrating satisfactory performance under this dynamic loading; ⢠Accommodate a wheelchair-anchored pelvic safety belt that will stay in place and restrain the occupant during a frontal crash; and ⢠Provide four standardized points with slot-type geometries (e.g., brackets) for attaching tiedown straps for in-vehicle securement. The committee finds that the ability of wheelchair securement systems to meet these motor vehicle crash performance standards, which require testing that has some commonalities with the testing required for demon- strating airplane seat crashworthiness, is suggestive that wheelchair secure- ment and occupant restraint systems could also be designed for airplane
ASSESSMENT OF FINDINGS AND RECOMMENDED NEXT STEPS 123 installation. Specifically, the findings suggest that systems could be designed to do the following: ⢠Accommodate wheelchairs equipped with standardized four-point brackets for connecting tiedown straps and that otherwise comply with motor vehicle crashworthiness criteria (including many wheel- chairs in use today and wheelchairs that can be designed to this standard in the future); ⢠Keep a crashworthy wheelchair secured to withstand the dynamic forces of a survivable frontal airplane impact with the occupant remaining seated, upright, and restrained; and ⢠Protect the occupant of a crashworthy wheelchair and other pas- sengers from serious head and leg injuries as long as the wheel- chair is secured in a 30- à 60-in. zone that is clear of objects and structure. However, in the absence of comprehensive testing and evaluation data for the crash performance of wheelchairs and their securement systems in accordance with FAA crashworthiness criteria, it is not possible to confirm the technical feasibility of designing and implementing an airplane-specific wheelchair securement and occupant restraint system that would demon- strate the requisite airplane crashworthiness capabilities. It merits noting, however, that during a committee meeting, the nonprofit organization All Wheels Up,1 which advocates for wheelchair accommodation on airplanes, described the exploratory testing that it has sponsored on the performance of a wheelchair securement and occupant restraint system. The test results, as described to the committee, demonstrated how a power wheelchair (oc- cupied with a mid-size male test dummy) that is secured by tiedown straps normally used for motor vehicle transportation could keep the wheelchair secured and upright with no damage to the straps when tested according to FAA dynamic criteria. While the tested wheelchair is reported to have retained all items of mass, including the battery, the tests were designed to assess the airplane crash performance of a standard tiedown system. The exploratory tests were not designed to demonstrate airplane crash perfor- mance (in accordance with FAA criteria) of a range of common wheelchairs, including their ability to protect the occupant from serious injury when re- strained only by a wheelchair-anchored pelvic belt and to retain the battery and other items of mass. The All Wheels Up test data are proprietary; thus, they were neither included in a published external technical review nor shared with the committee. The committee concludes, however, that more comprehensive and externally reviewable testing of this type is essential for 1 See https://www.allwheelsup.org.
124 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL assessing the feasibility and informing the design of wheelchair securement systems for in-cabin applications. The committee finds that the most uncertain technical issue pertaining to cabin crashworthiness criteria, and one that warrants further informa- tion gathering and evaluation, is whether the population of personal wheel- chairs themselves, including those designed to meet motor vehicle crash performance standards, would satisfy the FAA requirements for airplane crashworthiness. The review indicates the following: ⢠RESNAâs crash performance test for WC19 wheelchairs has some similarities with one of FAAâs two dynamic crash tests for airplane seats in which the predominant impact vector is horizontal. FAAâs horizontal test requires an airplane seat to demonstrate the ability to avoid severe deformation, retain items of mass, and protect the occupant from severe head and leg injuries from a 16-g peak dy- namic loading along the airplaneâs longitudinal axis, such as from a survivable crash or emergency landing impact when the airplane is primarily moving forward. To meet the WC19 standard, secured wheelchairs must demonstrate crashworthiness, occupant restraint, and battery and component retention in a frontal motor vehicle crash occurring at 30 mph. The horizontal test condition in this case creates a dynamic loading that averages 20 g, which is higher than the peak 16-g loading of the FAA test, and also assumes a nearly instantaneous deceleration from 30 to 0 mph. ⢠RESNAâs WC19 standard does not include a test condition compa- rable to FAAâs second dynamic crash test in which the predominant impact vector is vertical. This second test is also intended to dem- onstrate the seat structureâs ability to avoid severe deformation, retain items of mass, and protect the occupant from spinal injury but under vertical loadings characteristic of a survivable airplane crash during an attempted takeoff or emergency landing with a high descent rate. In the absence of a WC19 vertical test, technical evaluations are needed to determine the crash and injury protection performance of wheelchairs when subject to such vertical forces, which seldom occur in motor vehicle crashes. Likewise, RESNAâs flammability testing standards for wheelchairs differ from FAAâs standards for airline seats. While wheelchairs that meet crashwor- thiness standards for motor vehicle transportation must also meet industry standards for resistance to ignition by a cigarette and match, FAA standards are different and thus technical evaluations are needed to gauge the ability of wheelchairs to satisfy FAA crite- ria for resistance to post-crash fires.
ASSESSMENT OF FINDINGS AND RECOMMENDED NEXT STEPS 125 Given these identified information gaps and knowing the variability in wheelchair designs, the committee has no current basis for gauging whether wheelchairs could satisfy FAA criteria with respect to these crashworthiness criteria. The committee is optimistic, however, that future efforts to fill the gaps in technical information will benefit from RESNAâs crashworthiness standards for wheelchairs. The standards provide a performance minimum, or widely applicable baseline, for wheelchair evaluations on the basis of FAA test criteria, as many commonly used wheelchairs comply with the RESNA standards today and more wheelchairs could be designed to comply with them in the future. If the WC19 and other RESNA standards did not exist to provide such a common baseline, the job of evaluating a heteroge- neous population of personal wheelchairs for compliance with FAA criteria could be technically daunting and potentially impractical. Finally, it merits noting that in briefing the committee, FAA representa- tives cited instances where some cabin installations or design features were granted exemptions from specific crashworthiness criteria when demon- strating compliance would be extremely difficult to do and when the ap- plicability of the criteria may be limited. A cited example was an in-cabin medical stretcher installation, which was exempted from demonstrating compliance with the dynamic loading criteria for passenger seats.2 In pro- viding the reasoning for the exemptions, FAA acknowledged that the ap- plicantsâ ability to demonstrate compliance would be difficult, if possible at all. Nevertheless, the agency pointed out that the dynamic testing criteria for passenger seats were originally established based on a regulatory calcu- lation that the added safety benefit to passengers would significantly exceed the cost of designing and engineering the compliant seats. This net benefit calculation, however, was based on design and engineering costs amortized across potentially hundreds of seats in an airplane, which would not be the case for a single stretcher installation. Expecting medical stretchers to be limited to one or two installations per applicable airplane and not used on every flight, FAA granted the exemptions under the premise that it would not be âprecedent-settingâ and on the condition that the stretcher would be installed in such a way that it would not reduce the level of protection afforded to other occupants of the airplane. A presumption of this feasibility study is that FAA would apply its crashworthiness regulatory criteria established specifically for airplane seats and cabin interiors to wheelchair securement systems. As these exemption examples indicate, however, the technical challenge will be to design a sys- tem that will satisfy FAA determinations about how safe the system must be in accordance with the statutory goals and obligations that underpin those 2 Exemption No. 10197, Regulatory Docket No. FAA-2010-0989, issued January 21, 2011; Exemption No. 10457, Regulatory Docket No. FAA-2011-1389, issued February 23, 2012.
126 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL criteria. The purpose of further testing and evaluation of wheelchairs and wheelchair securement systems would inform such safety determinations. AIRLINE OPERATIONAL AND PASSENGER ACCOMMODATION ISSUES The implementation of an in-cabin wheelchair securement system, if tech- nically feasible, would invariably require airlines to address a range of practical issues associated with passenger use of the securement system on individual flights as well as other challenges associated with ensuring adequate and reliable service through modifications to reservation systems and the coordination of flight offerings and flight schedules. Indeed, the studyâs Statement of Task, under the rubric of âaccommodation,â asks the study committee to address the following questions: ⢠How will airlines be able to use the systems to provide an equal level of service to air travelers with significant disabilities? ⢠What will be the implications of removing standard aircraft seats to create the space needed for a restrained, occupied wheelchair in the cabin? ⢠What will be the implications on cabin interior designs and furnish- ings (e.g., aircraft doors, aisles, galleys, lavatories)? ⢠What will be the implications on boarding and deplaning proce- dures and staff training? ⢠What will be the implications on reservation procedures? ⢠How will the batteries of power wheelchairs be treated and han- dled prior to and during flight? All but a few of these issues have already been addressed as part of the studyâs review of the technical issues associated with developing and imple- menting an in-cabin wheelchair securement system. Starting with the ques- tion about âequal level of service,â the committee interpreted this interest to mean that people who have significant disabilities and cannot currently fly safely in a passenger airplane will be able to do so much like people who can fly in an airplane seat. In particular, the emphasis of this report has been on examining the technical feasibility of securement systems that can be installed on enough airplanes to allow people with significant disabili- ties to fly seated in their personal wheelchairs (as opposed to wheelchairs specialized for use in airplanes) and be âequalâ with other travelers in the sense that they will have equitable service, be able to fly comfortably, and have access to a reasonable number of flights to and from places they want to go. Accordingly, the committeeâs assessments of the technical issues as- sociated with safety, airplane structure, and cabin space have been based on
ASSESSMENT OF FINDINGS AND RECOMMENDED NEXT STEPS 127 the premise that personal wheelchairs will be used and that common types of airplanes would be equipped. The reportâs assessments of the interior modifications required to implement the systems assume that the secured passengers will have access to the same in-cabin amenities and safety fea- tures as other passengers, including access to entertainment systems, call buttons, and oxygen masks. While the reportâs technical assessments suggest that the removal of two rows of seats should be needed and sufficient to free up enough room and structural capacity for a wheelchair securement system, the specific cabin location most suitable for installation of the system would depend on operational as well as technical considerations. From a technical per- spective that considers cabin space requirements only, the ideal location would depend on the door used for entering and exiting the cabin with the wheelchair, because any location far from the boarding door would require the removal of additional seats to create sufficient aisle width for access. The choice of a boarding door, in turn, would depend on the doorway hav- ing sufficiently wide clearance for the wheelchair. It would also depend on considerations about whether and which interior features might need to be modified or relocated to enable a wheelchair to navigate the turn between the doorway and passenger seating area. Additionally, from an operational standpoint, the choice of a boarding door for travelers using a wheelchair could also depend on an airlineâs desire to board and deplane all passengers through the same door in accordance with its standard boarding practices. When taking into account all of these considerations, the designation of a wheelchair securement area at the very front of the passenger cabin, as assumed for most of the scenarios developed in this report, appears to be the strongest candidate for a common placement. From both technical and operational standpoints this location has many advantages, including the prospect of fewer airplanes requiring major interior modifications than if the securement system was located elsewhere in the cabin. This forward location would allow passengers, including wheelchair users, to board and deplane through the same left forward door that is in common use today, resulting in little, if any, disruption to existing airline boarding and deplan- ing procedures. The use of a single door for all boarding would not only minimize airline operational impacts but also result in more equal service treatment for ambulatory and nonambulatory passengers. Likewise, there is good reason to believe that this forward securement location would require no more than an ordinary level of interior design and engineering effort for an airline to ensure that passengers in and near the securement zone would be afforded the same amenities as other passengers in the cabin. The in- novative seating configurations and amenity offerings in first class cabins today are indicative of how cabin interior designers and engineers can be flexible and adaptive to such circumstances.
128 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL A passenger flying in a wheelchair may or may not require assistance from a flight attendant or customer service agent during boarding and de- planing, but is likely to require assistance with securing and releasing the wheelchair. It is already the case that the International Air Transport Asso- ciationâs (IATAâs) special service request (SSR) codes identify passengers re- quiring boarding and deplaning assistance. For instance, the SSR codes for wheelchair assistance include WCHSâpassenger can walk a short distance but not up or down stairs; WCHCâpassenger cannot walk any distance and will require an aisle chair to board in cabin; and WCLBâpassenger traveling with a lithium ion batteryâpowered wheelchair. The creation of in-cabin wheelchair seating capability is likely to require a new SSR code that alerts airline personnel and wheelchair assistance providers about the presence of a passenger traveling in a personal wheelchair. Currently, most nonambulatory people who fly are transferred between their personal wheelchair and a boarding or aisle wheelchair and then as- sisted into and out of the conventional passenger seat by a customer service agent. Presumably, the same agent could be trained to provide assistance to the passenger as needed when maneuvering the wheelchair into and out of the cabin and securement area and when securing the wheelchair and occupant restraint system. Indeed, this assistance may be provided more quickly than the current process of assisting the passenger when transfer- ring between the personal wheelchair and boarding chair, in maneuvering the boarding chair in the cabin, and in transferring between the chair and airplane seat. The agentâs new duty could include verifying that a small ramp on either side of the airplane sill is available and in place if needed for the wheelchair to clear the boarding doorway. While procedures would need to be established for properly securing and releasing the wheelchair, the level of training needed for this procedure could be comparable to the highest quality training provided to operators of surface transportation vehicles such as transit buses. Flight attendants would need to be able to visually inspect the securement and a checklist would need to be in place for the handoff from the customer service agent to the flight crew. Flight attendants may need training on visual standards for indications of proper wheelchair securement and occupant restraint, as well as any other neces- sary adaptions to procedures before, during, and after the flight. For most matters, such as emergency evacuation protocols, the occupant of the wheelchair would presumably be treated like other nonambulatory pas- sengers seated in a conventional seatâand thus, of course, not be expected to evacuate in the wheelchair. In this reportâs assessment of technical feasibility, it was pointed out that FAA will need to determine whether personal wheelchairs that meet WC19 standards will satisfy airplane cabin crashworthiness requirements or whether the wheelchair will need to meet additional criteria and conditions
ASSESSMENT OF FINDINGS AND RECOMMENDED NEXT STEPS 129 to be eligible for in-cabin securement. If WC19 compliance is considered to be at least one eligibility condition, one might expect airlines to design their securement mechanisms to take advantage of the four-point securement brackets and anchors for a lap belt specified by the standard. While some people with significant disabilities are mostly homebound and may have wheelchairs designed for indoor use only that are not WC19 compliant, it is reasonable to assume that people who are interested in flying while seated in their own wheelchairs will seek out equipment that is WC19 compliant (and labeled accordingly) and mandatory for air travel. Inasmuch as in- cabin securement systems are likely to be used disproportionately by people in power wheelchairs, WC19 compliance is desirable for transportation generally because these wheelchairs are frequently used as seats in motor vehicles.3 Ideally, methods would be developed to confirm that the wheel- chair satisfies applicable eligibility criteria during ticketing for verification at check-in. Thus, presumably in advance of boarding, the customer service or gate agent would need to inspect the wheelchair to verify that it is equipped with the requisite securement brackets and lap belt, which can be done visually and verified by checking for a WC19 label. Where the verification process could become more complex, however, is if the agent is expected to examine the wheelchair for deviations from the standard or other eligibility conditions; to ensure that the battery is adequately secured and sufficiently charged; and to ensure that removable items on the wheelchair, from packs to control devices and essential accessories (such as a ventilator and oxygen dispenser), are in compliance with all relevant FAA and airline requirements. While not knowing the specific eligibility requirements that would be in place for wheelchairs to be used as seats in airplanes, a reasonable ex- pectation is that eligibility would be ascertained by determining if a given wheelchair is of a type or model that has been preapproved as conforming to the requirements. A specifically trained agent may be required to verify at airports that an individual wheelchair is an eligible model and in a condi- tion to be secured. The imposition of any additional requirements on wheel- chair owners to periodically demonstrate that their wheelchair continues to comply with all of the eligibility requirements met by the model would need to be carefully considered for practicality and avoidance of excessive cost and burden. Adaptions to airline reservation systems will be critical for accom- modating travelers who want to use the wheelchair securement systems. 3 Indeed, wheelchair manufacturersâ voluntary provision of information on WC19 compli- ance of their wheelchair models to aid consumers shows that 153 wheelchair models from 18 major manufacturers meet WC19 standards. See University of Michigan Transportation Re- search Institute. 2020. âWheelchair Product ListâWC19 Full Compliance.â http://wc-transpor tation-safety.umtri.umich.edu/crash-tested-product-lists/wheelchairs and https://docs.google. com/spreadsheets/d/1qf6Mlm5FB-QLOpeFGLf-dNcFksZdbqF-buuY5M-sQ4M/edit#gid=2.
130 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL At the pre-travel phase, when searching for fare and service offerings, the traveler would need information about the availability of a system on each flight and to be assured that boarding bridges and trained customer support agents are available at all airports on the itinerary. Likewise, the airline would want this assurance before a booking takes place to minimize the potential for problems during check-in. Reservation systems would there- fore need to be adapted to allow travelers to find flights that meet these requirements. The reservation system might also need to ask, for instance, for the customer to confirm that the wheelchair is WC19 compliant. The search for flight offerings would be facilitated if a large portion of airplanes was equipped with securement systems. If securement system implementation is limited to a few airplanes or city-pair markets, its utility would be greatly limited. As discussed in Chapter 2, many cities have non- stop service to only a handful of destinations, and thus connecting service is the norm. The search for securement service could therefore be particularly complicated for itineraries that require airplane transfers. Passengers would need to be assured that a wheelchair securement system would be available for all flight segments. However, as the number of flight segments increases, so too does the risk that one or more of the flights would not be able to accommodate a wheelchair for a variety of reasons after the booking has been made, including the airline needing to make a last-minute substitution of equipment due to mechanical problems, weather delays, and air traffic control holds. The reservation system will need to be able to provide the traveler with advance notification and a means of rescheduling in the event that a suitable airplane is not available. Advance notice, however, may not be possible once travel is under way, and therefore any of the above cir- cumstances, or simply a missed connection to the only suitably equipped airplane, could leave the traveler stranded en route. The extent to which such service availability issues will create chal- lenges for travelers will depend in large part on passenger demand for in- cabin wheelchair service, because the level of demand will affect both the likelihood of a traveler finding a wheelchair space that has not already been booked and an airlineâs motivation to equip more airplanes with secure- ment systems. That demand is difficult to know at this point, because it would presumably depend in part on whether people who do not fly now because of troubles with transferring to and from an airplane seat would be willing to fly if they could travel seated in their personal wheelchair. Still another component of this demand would be passengers who are able to transfer to an airplane seat and check their wheelchair in the cargo hold but who do not fly as often as they would like because of the discomfort or risks associated with the transfer and/or the potential for the stowed wheelchair to be damaged or lost in transit. Gauging demand for in-cabin
ASSESSMENT OF FINDINGS AND RECOMMENDED NEXT STEPS 131 wheelchair service is therefore a complicated but potentially critical step for making decisions about equipping airplanes with wheelchair securements. With regard to the handling of wheelchair batteries, FAA regulations state that batteries may remain on a wheelchair stowed in the cargo hold but must be disconnected or otherwise disengaged to avoid unintentional activation.4 The exception is lithium ion batteries, which may need to be removed from the wheelchair and stored in the cabin. Neither FAA regu- lations nor industry standards developed by IATA5 (in partnership with airlines and the battery industry) address the issues of battery engagement, power activation, and seating function availability when wheelchairs are in the cabin. It would be important for the battery to remain engaged for most portions of the flight to allow the occupant of the wheelchair to make certain medically necessary seating adjustments, such as tilt and recline. Assuming battery retention can be demonstrated for a wide range of wheelchairs in accordance with FAA crash performance requirements, the batteryâs engagement and disengagement during flight would need to be addressed by standards along with the temporary disabling of certain seat functions during some periods of flight. Seat functions are activated by the occupant and will stop when the electronic control mechanism is released and when the power is disengaged. However, if inadvertent activation is a concern, it is reasonable to assume that wheelchair manufacturers could develop a pre-programmed âairplane modeâ controller function that could be enabled at the flight attendantâs direction to temporarily disable certain seat functions during critical flight phases, such as takeoff and landing and during turbulence. It is also reasonable to assume that flight attendants would be trained to provide such instructions to passengers occupying wheelchairs during critical flight phases similar to those required for pas- sengers in regular airline seats (e.g., to fasten seat belts and adjust seats to the required position for turbulence, takeoff, and landing). Finally, it is not possible to identify and examine all of the implications of more people with significant disabilities flying, but a thorough assess- ment of these implications would be needed if airplanes were equipped with wheelchair securement systems. For instance, a review of emergency evacuation standards and procedures might be in order to ensure that they remain effective and appropriate if more passengers with significant dis- abilities occupy the cabin. 4 49 CFR, § 175.10; see https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=bba5ad065 18b529c94e1d67a3270196b&ty=HTML&h=L&r=SECTION&n=49y2.1.1.3.12.1.25.5e- DFR. 5 See IATA. 2021. Battery Powered Wheelchair and Mobility Aid Guidance Document. https://www.iata.org/contentassets/6fea26dd84d24b26a7a1fd5788561d6e/mobility-aid- guidance-document.pdf.
132 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL CONCLUSIONS AND RECOMMENDATIONS After reviewing the available information, as summarized in the findings above, the committee did not identify any issues in this preliminary assess- ment of technical feasibility that seem likely to present design and engi- neering challenges so formidable that they call into question the technical feasibility of an in-cabin wheelchair securement system and the value of exploring the concept further. While the reportâs analyses and findings sug- gest that equipping enough airplanes with securement systems to provide meaningful levels of airline service would require substantial effort, the types of cabin modifications required to provide the needed space and structural support would likely be of moderate technical complexity for many individual airplanes. Further assessments, including efforts to fill the information gaps identified in this report, would appear to be warranted, particularly to understand how secured personal wheelchairs are likely to perform relative to FAAâs safety criteria in restraining and protecting oc- cupants during a survivable airplane crash or emergency landing. The com- mittee believes that such follow-on assessments are warranted because the many feasibility issues that could indeed be assessed using the information at hand appear to be manageable from a technical perspective. Concerted efforts to understand the remaining technical uncertainties through more focused analysis and testing, as described in the recommendations offered next by the committee, would enable more informed public policy decisions about the feasibility and desirability of in-cabin wheelchair securement systems. ⢠The U.S. Department of Transportation and the Federal Aviation Administration (FAA) should establish a program of research, in collaboration with the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) and the assistive technology industry, to test and evaluate an appropriate selection of WC19-compliant wheelchairs in accordance with applicable FAA crashworthiness and safety performance criteria. The research program should address, but not be limited to, assessing the perfor- mance of WC19 wheelchairs secured in an airplane cabin during a survivable crash, an emergency landing, and severe turbulence by maintaining their form, restraining their occupants and protecting them from injury, retaining batteries and other items of mass, and providing adequate fire resistance. Consideration should be given to different conditions experienced in flight, such as the occurrence of unexpected severe turbulence while a wheelchairâs seat position functions are activated (e.g., leg elevation, recline, and tilt). The research should be conducted to inform decisions that may need
ASSESSMENT OF FINDINGS AND RECOMMENDED NEXT STEPS 133 to be made by the U.S. Department of Transportation (U.S. DOT) and FAA in response to petitions and other requests for in-cabin wheelchair securement systems to be allowed or even required on passenger airplanes; by RESNA and the assistive technology in- dustry to identify opportunities to align existing wheelchair trans- portation safety standards with performance criteria required for airplane transportation; and by the airline and aircraft industries to more fully understand the implications of and opportunities for providing travelers who are nonambulatory and have significant disabilities the ability to remain seated in their personal wheel- chairs during flight. ⢠The U.S. Access Board should sponsor studies that assess the likely demand for air travel by people who are nonambulatory if they could remain seated in their personal wheelchairs in flight. The studies should estimate the total demand for this service as well as the nature of this demand, including the demand by people with varying degrees of impairment. The studies should assess both the extent to which and how people with different disabilities are likely to use the securement systems, which could better define the space needed in the airplane cabin for wheelchair maneuvering and securement, provide insight into passenger support and service as- sistance requirements, and inform airline decisions about needed levels of fleet coverage and flight availability. Ideally, these recommended next steps of research, testing, and evalu- ation would be planned and programmed in a systematic mannerâor in accordance with a high-level âroadmapââthat takes into account the series of follow-on decisions and work that would be needed depending on the research, testing, and evaluation results. Numerous issues would need to be addressed in concert and stepwise. For instance, it would be important to find ways to ensure that wheelchairs brought on board an airplane cabin do not create security issues and are kept crashworthy as they age and are potentially modified. A fuller understanding of the training requirements for airline personnel will be needed along with testing and simulations to con- firm the actual amount of cabin space required for wheelchair maneuvering and securement, and the in-flight use of essential wheelchair seat position functions. A more in-depth understanding of the likely travel experience of passengers using the systems will be needed, along with the implications of their installation and use on airline operations and economics. A strategic roadmap that identifies and connects these issues and fol- low-on requirements could be important for sustained progress toward the realization of in-cabin wheelchair securement systems should evaluations indicate continued promise. The roadmap could contain key decision points
134 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL where information from the results of testing and analyses can be assessed for confidence and on the basis of risk analysis to define and prioritize next steps for information gathering and for furthering engineering and design activities, standards and regulation development, and practical re- quirements for implementation (e.g., personnel training requirements). U.S. DOT would be the logical lead for the development of such a roadmap in collaboration with the agencies and entities identified in the recommenda- tions above and with consultation and input from a wide range of interests and experts, including the airlines and their passenger service personnel, airframe manufacturers and interior component suppliers, people with dis- abilities and their advocates, and the assistive technology industry. Inasmuch as Congress called for this study, the committee trusts that Congress will consider these recommendations and the need for agency resources to execute them.
