Restraint mechanism for people with special needs

According to ANAC Resolution 280 of July 11, 2013, people with special needs may use additional restraint mechanisms of their own during the flight. Some possibilities for using a restraint mechanism require authorization from ANAC.

It is worth noting that this authorization is only valid for the cases described in Article 2 of Resolution 280:

“Art. 2 This Resolution applies to passengers, airport operators, air operators and their agents, in domestic or international public passenger air transportation services, scheduled or non-scheduled, except air taxi services.

§ Paragraph 1 The provisions of this Resolution do not apply to embarkation and disembarkation procedures carried out outside national territory and to procedures prior to travel and during the flight of a stage departing from outside national territory...”

There are three possibilities for using an additional containment mechanism, owned by the person with special needs or those responsible for it:

1. People with special needs up to 12 years old, when you want to use restraint systems approved for use by children (https://www.gov.br/anac/pt-br/assuntos/regulados/aeronaves/informacoes-gerais/-cadeirinhas).
   
   In this case, no specific authorization from ANAC is required.
   
   Important! The device must be approved for use in aircraft and the limitations imposed by the manufacturer must be respected (e.g. age, weight, height, form of installation in the aircraft for the flight);
   
   
2. People with special needs aged 12 or over, when you want to use restraint systems approved for use with children (https://www.gov.br/anac/pt-br/assuntos/regulados/aeronaves/informacoes-gerais/-cadeirinhas) and whose anthropometry (height, weight, etc.) allows the use of such devices when compared to the manufacturer’s limitations.
   
   In this case, specific authorization from ANAC is required
   
   For this authorization, the person with special needs or person responsible must provide information so that the device can be evaluated. This information includes photos of the device manufacturer’s manual, photos of the approval label for aeronautical use, the weight and height of the device user, their medical condition, etc.
   
   Important! The device must be approved for use in aircraft and the limitations imposed by the manufacturer must be respected (e.g. weight, height, manner of installation in the aircraft for flight).
   
   
3. People with special needs of any age, when you want to use restraint systems not approved for use with children, manufactured by the person in charge, by the people with special needs themselves or third parties, or even industrially.
   
   In this case, specific authorization from ANAC is required.
   
   For this authorization, the person with special needs or guardian must provide information so that the device can be evaluated. This information includes the weight and height of the user of the device, their medical condition, drawings and/or photos of the device, a description of the materials and manufacturing methods, its weight, how it is attached to the aircraft seat, etc.
   
   

Important! The limitations imposed by ANAC at the time of authorization must be respected.

In cases where prior authorization from ANAC is required, the concerned party must follow the specific instructions on the Gov.br Portal regarding the service “Obtain authorization to use a containment device for people with special needs”.

ANAC will then carry out a technical analysis of the process and issue authorization or request further information about the mechanism. In the case of systems in accordance with item 3 above, ANAC may require modifications to the mechanism before issuing the authorization.

The evaluation service, if necessary, is free of charge. 

Foreseen limitations

Even if ANAC issues authorization for use in cases where it is necessary, the person with special needs or those responsible for them must be aware that limitations on the use of the device may be imposed. The list below contains examples of these limitations, depending on the evaluation of the device and the condition of the user, but may contain other restrictions.s

1. The seat behind the seat on which the device is installed must not be occupied;
2. The seat in front of the seat on which the device is installed must not be occupied;
3. Once the device has been installed in the aircraft and the occupant has been seated, their seat belt (aircraft standard) must be able to restrain them by their pelvis;
4. The angle between the lap belt (aircraft standard) and the plane of the seat must not exceed 60 degrees when the occupant is seated (see picture below);
   
   
   
   
5. It must be ensured that the device is in good condition for use, e.g. free from corrosion and severe dents. 

Making or adapting your own device

If the person with special needs or person responsible decides to build their own restraint device, or adapt it from an existing device, the recommendations below, if followed, can contribute to it being authorized by ANAC for use in flight. Please note that this is not a complete list:

1. The proposed device must have desirable characteristics with regard to the possibility of injury to the user and other occupants of the aircraft, such as not being too fragile and not having sharp or perforating edges;
2. Magnesium alloys should not be used in the construction;
3. Parts of the device should not extend beyond the back of the seat;
4. There should be no parts that can easily detach when moving forwards. 

Legislation

ANAC Resolution No. 280, of July 11, 2013, amended by ANAC Resolution No. 608, of February 11, 2021.

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