TECHNICAL PAPER ON MOBILITY AIDS STOWAGE



Volume 1:  Research Findings and Recommended Practices



September 1988



Prepared for:



ARCHITECTURAL AND TRANSPORTATION BARRIERS COMPLIANCE BOARD



1111 18th Street, N.W. Suite 501



Washington, D.C.  20036-3894



(202) 657-7848 (Voice or TDD)



Prepared by:



Michael E. Wiklund



American Institutes for Research



45 North Road



Bedford, MA  01730



NOTICE  



This document is disseminated under the sponsorship of the Architectural

and Transportation Barriers Compliance Board in the interest of

information exchange.  The United States Government assumes no

liability for its contents or use thereof.  The United States

Government does not endorse products, manufacturers, or private

corporations.  Trade or manufacturer's names appear herein solely

because they are considered essential to the object of this report. 





FOREWORD  



This technical paper, titled Mobility Aids Stowage, was prepared by

American Institutes for Research under contract to the Architectural

and Transportation Barriers Compliance Board, Washington, D.C.  The

paper follows several interim project reports that have documented the

extent and effectiveness of mobility aids stowage services in the U.S.

and international airline industry.  The goal of the project is to

promote improved mobility aids stowage methods in the airline industry,

thereby improving the accessibility and quality of air transportation

services provided to passengers with disabilities.  The technical paper

is divided into two volumes:  





Volume 1:  Research Findings and Recommended Practices  



Volume 2: Recommended Approaches to Solving Remaining Problems and 

Barriers  



As described in the paper, several opportunities have been identified to

improve mobility aids stowage services.  Some involve leading airlines

to implement specific policies, procedures, practices and technology

that are already in-place and have been proven effective by one or more

airlines.  Other opportunities involve developing new technology,

stowage requirements data, and operational approaches, and then

promoting their implementation.                   





Volume 1



TABLE OF CONTENTS  



Section No.  Title  



1.0 INTRODUCTION  



2.0 DESCRIPTION OF ATBCB'S RESEARCH EFFORT  



3.0 THE REGULATORY ENVIRONMENT 



3.1 Current Regulations 



3.2 Revised Regulations  



4.0  THE EXISTING PROBLEMS 



4.1  Non-Powered Wheelchair Stowage Problems 



4.2  Powered Wheelchair Stowage Problems 



4.3 Cane and Crutch Stowage Problems 



4.4  Service Dog Transportation Problems 



4.5  Miscellaneous Equipment Stowage Problems 



4.6  Problems Related to Airline Policy-Making and Implementation  



5.0  MOBILITY AIDS STOWAGE PRACTICES 



5.1 Wheelchair Stowage 



5.2  Service Dogs 



5.3  Crutches and Canes 



5.4  Miscellaneous Equipment 



Attachment 1 - Proposed Wheelchair Battery Stowage Procedure 



Attachment 2- Federal Regulations on Stowing On-Board Articles   



Volume 1 



LIST OF FIGURES AND TABLES  



Table   Title  



1 Airline Personnel Who Innovated Handicapped Services or Hold Current

Responsibility  



Figure  Title  



1  Everest & Jennings Premier 8 Powered Wheelchair;  Dismantled and Folded  



2 Wheelchair Stowed in a Unit Load Device (ULD)  



3  Wheelchair Being Loaded in an Upright Position (Boeing 727-200)  



4  Wheelchair Stowed in Forward Cargo Compartment (Boeing 727-200)  



5  Wheelchair Tipped Sideways to Fit Through Foreword Cargo Compartment

Access Door (Boeing (737-200) 



6  Wheelchair Being Loaded into Aft Cargo Compartment  (Beechcraft 1900)  



7  Wheelchair Stowed in Belly Compartment (Jetstream 31)   



8  Control Mechanism Disconnected From Wheelchair  



9 & 10  Wheelchair Being Loaded by Belt Loader into Aft Cargo

Compartment (Boeing 737-300)  



11  United Airline's Combined Pilot Notification Form and  Wheelchair

Stowage Checklist  



12  Alternative Pilot Notification Form     



1.0  INTRODUCTION  



The need to improve the mobility aids stowage services provided by

airlines is felt by both the airlines and disabled persons.  The

airlines seek ways to serve the disabled passenger more effectively

while also assuring efficient and safe operations.  An increasing number

of disabled passengers are utilizing air transportation services and

increasingly advanced mobility aids. These passengers want their trips

to be convenient and to know that their mobility aids will be accepted

for carriage and remain undamaged.  



With these goals in mind, the reality of mobility aids stowage practices

among major and regional airlines is that mobility aids stowage

requirements can disrupt airline operations, especially if workable and

efficient procedures are not developed and implemented in advance.



On the other side of the issue, many passengers have encountered

repeated problems including damage to their mobility aids, delays in

service (such as long waits for their personal wheelchair to be

delivered to them), and even denial of service.  





A review of airline policies and procedures has shown many opportunities

for improving the level of mobility aids stowage service in several

principal areas:  



the scope and clarity of federal regulations   



the airlines' policy-making and policy implementation  processes



industry standardization stowage procedures  



These changes are consistent with ongoing efforts to revise federal

regulations, a process which is designed to improve the level of

mobility aids stowage services and accessibility to handicapped

travelers in general.  



2.0 DESCRIPTION OF ATBCB'S RESEARCH EFFORT  



In October 1986, the Architectural and Transportation Barriers

Compliance Board (ATBCB) initiated a study of the mobility aids stowage

services provided by airlines.  The goal of this research was to

identify the best, in-place stowage services and promote their

industry-wide adoption.  The study followed several logical steps

leading to the preparation of this technical paper which contains a

discussion of mobility aids stowage issues and recommended procedures

and practices.  



The first step involved collecting information on (1) disabled passenger

experience utilizing stowage services, (2) major and regional airline's

mobility aids stowage policies, procedures and practices and (3) the

regulatory environment.  The second step involved identifying the best

stowage services already in-place that meet the intent of federal

regulations, serve passenger's needs, and are also practical for the

airlines.  Where a complete solution could not be found, effective

procedures for portions of the process were combined and synthesized

into a complete procedure.  The third step involved determining where

mobility aids stowage problems persist without in-lace solutions and

developing recommended approaches to solving them.  Each step in the

research process is briefly described below.  





Step 1 - Collect Information  



A general picture of disabled passenger experience was derived from

personal accounts and opinions, which were described in various

documents or obtained first hand.  This approach was a pragmatic one,

since there is no industry-wide or governmental system to track stowage

problems.  The approach was limited in that it did not provide a basis

for statistical analysis and did not permit stowage problem frequency

estimates.  Nonetheless, the review of passenger accounts and opinions

helped to determine where mobility aids stowage practices are

responsive to passenger needs and preferences and where problems still

exist.  



The airline industry was quite responsive to requests for information on

their mobility aids stowage services.  The Regional Airlines

Association voluntarily distributed a survey on mobility aids stowage

services that was completed and returned to the researchers by 44

regional airlines.  On the basis of written requests, over 20 major

airlines (foreign and domestic) provided sections of their operations

manual describing mobility aids stowage services.  Also by request,

several aircraft manufacturers provided schematic diagrams and drawings

of aircraft configurations (including cargo compartment dimension

data).  



Assessing the regulatory environment focused on a review of federal

regulations (contained in the Code of Federal Regulations) and

background information pertaining to the regulation development and

implementation process.  The U.S. Department of Transportation (DOT)

has reviewed this document to ensure consistency with regulations

implementing the Air Carrier Access Act of 1986.     



The state of mobility aids stowage services was further defined based on

information and insights obtained from the following:  



Discussions held between researchers and representatives from the Air

Transport Association, the Regional Airline Association and two major

airlines;  



A review of disabled passenger's complaints registered with the U.S.

Department of Transportation's Office of Public Affairs during the

period 1982-1987 (Feb);  



A review of issues of NINNESCAH (1984-1987) containing interviews with

disabled air travelers attending the President's  Committee on the

Employment of the Handicapped annual meetings in Washington, D.C.;  



Technical presentations at the 1987 Access to the Skies-  Annual

Meeting;  



Interviews conducted with both major and regional airline operations

personnel (station mangers and cargo handlers) at  Boston's Logan

International Airport;   



Various other documents providing research findings and  guidance on the

stowage of mobility aids and general air travel services for disabled

persons.   



Step 2 - Identify Problems and In-Place Solutions  



Researchers compared the stowage procedures documented in airlines'

operating manuals against accounts of passenger and airline personnel

experience.  By doing this, the "ingredients" of effective stowage

methods became readily apparent.  Effectiveness was measured in terms

of (1) responsiveness to both passenger and airline needs and (2)

feasibility of immediate implementation.  



Once the "ingredients" of good mobility aids stowage procedures were

known, researchers then consolidated them into integrated procedures

covering the various mobility aids stowage needs and requirements.  The

procedures were developed in the context of existing policies and

procedures of some airlines and federal regulations and are intended as

prototypes suitable for immediate airline adaptation and

implementation.  



At the same time effective procedures were being defined, it was noted

that inconsistency in airline policies, procedures and practices

between airlines and even within the same airline had arisen as one of

the disabled passengers' major complaints. Technical investigations

pointed to the airlines' policy-making and implementation process

including dissemination of information within the airline and divergent

interpretations of federal regulations as the principal causes. 

Moreover, airlines do not always share information with one another so

that a particular carrier may not know that an effective procedure

exits.  



Step 3 - Recommend Solutions to Remaining Problems  



Researchers encountered several mobility aids stowage problems for which

no in-place solution was found.  By reviewing the results of related

research and technology development efforts, potential solutions to

several of the unsolved problems were identified.  In some cases, these

solutions were identified by the researchers based on the insights

gained through the research effort, judgement and creativity.  



3.0  THE REGULATORY ENVIRONMENT  



The regulations established by the federal government for handicapped

accessibility are the foundation upon which current mobility aids

stowage practices and specific problems rest. Airlines develop

operational policies, procedures and practices to meet the intent of the

federal regulations and their own operational objectives,  In cases,

problems cited in the area of mobility aids stowage can be traced back

to (1) regulations that may be too broad and lack the detail that would

assure better and more consistent airline practices and/or (2) lack of

regulatory guidance in a key area.  Of course some mobility aids stowage

problems can also be traced to airline practices that are unresponsive

in view of higher levels of service for the disabled passenger,

including better mobility aids stowage services.  



3.1  Current Regulations  



Section 14, Part 382 of the U.S. Code of Federal Regulations (CFR),

titled "Nondiscrimination on the Basis of Handicap" is the regulatory

foundation of accessibility requirements. 14CFR Part 382 serves "to

ensure that handicapped persons receive adequate air transportation

service, without unjust discrimination based on handicap, and to

implement section 504 of the Rehabilitation Act of 1973. . .".  The

original 1984 regulation applies a general non- discrimination policy

to all certificated airlines (those airlines that provide scheduled or

charter services) and specific requirements only to those commuter

(regional) air carriers that receive federal subsidy or compensation

for losses caused by short term, essential services required by the

U.S. DOT.  The Air Carrier Access Act of 1986 required the U.S. DOT to

revise the regulation to cover all certificated carriers.  



Besides establishing broad accessibility requirements, 14 CFR 382

establishes service requirements in the areas of:  



folding and battery powered wheelchairs 



guide (service dogs) 



canes and crutches 



personal oxygen for medical use  



Other regulations affecting mobility aids stowage practices are:  



14 CFR Part 121.589 and 135.87 (canes, crutches) 



49 CFR Part 175 (powered wheelchair batteries) 



14 CFR Parts 121.574 and 135.91 (personal oxygen)  



In several cases, the regulations leave room for interpretation by

airline personnel in determining whether services will be provided. 

This is illustrated in the regulation excerpt provided below.  



"Carriers shall make reasonable efforts to permit handicapped persons to

take folding wheelchairs aboard and to stow those wheelchairs in the

passenger compartment" (14 CFR 382.14(c))   



This sample is indicative of the problem faced by regulators:  writing

regulations that assure the best possible service to handicapped

persons while not unreasonably burdening the airlines.  The level of

regulation specificity is confounded by factors such as the wide

variety in both the type of aircraft used by airlines and the mobility

aids used by handicapped persons.  



3.2  Revised Regulations  



Recognizing the need to clarify the statutory prohibition against

discrimination on the basis of handicap, the U.S. Congress passed the

Air Carrier Access Act (Public Law 99-435) on 2 October 1986.  In

summary, the new law amended Section 404 of the Federal Aviation Act so

that no airline may discriminate against a handicapped individual, or

his or her property, by reason of such handicap, in the provision of

air transportation services.  The U.S. D.O.T.  developed regulations to

implement the law partly through a process termed "Regulatory

Negotiation".  This involved a series of negotiations among government,

airline and public representatives begun in June 1987.  The revised

Part 382 Regulation establishes specific requirements, including

provisions for mobility aids stowage, which apply to all certificated

carriers.  



This increases the urgency for the development of better mobility aids

stowage services and the need to provide information to help airlines

develop effective mobility aid stowage policies, procedures and

practices.  With this background, the mobility aids stowage

recommendations provided in this technical paper have been developed

with the assumption that airlines wish to maximize mobility aids

stowage services and that mobility aids will be accommodated unless

there is a physical impossibility.  



4.0  THE EXISTING PROBLEMS  



This section of the technical paper discusses mobility aids stowage

problems from both the passenger and airline perspective.  The problems

reported are not intended to represent a complete list of problems

since many are never documented, nor should they be interpreted to be

the consensus of disabled passengers or the airlines.  However, except

where noted, the problems have been drawn from personal and documented

accounts and complaints.  The discussion of stowage problems covers

non-powered wheelchair, powered wheelchairs, canes and crutches,

service dogs and miscellaneous equipment.  Also included in this section

of the technical paper is a discussion of the problems related to

airline mobility aids stowage policy-making and implementation

processes.  Problems related to aircraft and cargo handling constraints

are addressed in Section 5.0.  



4.1  Non-Powered Wheelchair Stowage Problems  



The stowage of non-powered wheelchairs presents primarily logistical and

physical accommodation problems.  No specific safety issues need to be

resolved.  Passenger and airline perspectives on the existing problems

are discussed below.  



The Passenger's Perspective  



Disabled passengers have reported the following problems encountered

when traveling with non-powered wheelchairs.  



The airline takes too long to return the wheelchair once at the

destination point.  



One must often relinquish one's personal wheelchair upon arrival at the

terminal and use an airport-provided wheelchair which might not be

comfortable or provide independent

 mobility.  



One's personal wheelchair is not available for passenger use during

extended layovers, so an airport-provided wheelchair must be used, with

the inherent problems described above.  



The wheelchair does not fit into the cargo compartments of some small

aircraft in use.  



The wheelchair is not accepted by certain airlines for  stowage in small

aircraft (even though it fits in the cargo  compartment) on the grounds

that it will use up too much of  the limited cargo space, displacing

other passengers' luggage.  



The wheelchair suffers damage such as: the bending of handles, wheel

spokes and other parts; seat tears and stains; the loss of parts such

as belts.  Some passengers feel they must tape up loose parts on the

wheelchair to protect the parts from damage or loss.  



Passengers have, in some cases, been required to sign a wheelchair

damage waiver.  These forms are reportedly intended to relieve the

carrier of any responsibility for damage caused to the wheelchair

during carriage.  



The wheelchair goes to the wrong destination and is not available to the

passenger upon arrival at his or her destination.  



Airlines have reportedly tried to levy an extra charge for transporting

the wheelchair where the weight of the wheelchair plus normal luggage

exceeds that established limit for carrying luggage at no extra

charge.    



The Airline's Perspective  



All major airlines and a majority of regional airlines surveyed (those

operating relatively large aircraft) indicated that they accept

non-powered wheelchairs.  The physical stowage of non-powered

wheelchairs seems to cause them no major problems since the cargo

compartments of the larger aircraft could accommodate the wheelchair

just like any other piece of luggage.  No special care is generally

taken, although some airlines have tested placing the wheelchair in a

cardboard container or in a protective plastic bag.  Non-powered

wheelchairs are relatively light in comparison to some common pieces of

luggage.  Many non-powered wheelchairs fold-up into compact volumes. 

They are less susceptible to damage since they are less mechanically

complicated than powered wheelchairs.  



Non-powered wheelchairs seem to be problematic only for regional

airlines operating very small aircraft.  The problems are:  



The wheelchair will not fit through the cargo or passenger access door,

even through the cargo compartment itself could  hold the wheelchair.  



The cargo compartment is too small to hold the non-powered wheelchair. 



If the carrier accepts the non-powered wheelchair, not enough room is

left for the other passengers' luggage. Wheelchairs also have created

logistical problems for the airlines: 



Delays incurred at times when there are close flight connections,

especially involving a connection from a major airline to a regional

airline.  Wheelchair transfer and stowage can be time consuming when

stowage space is already partially filled.  



Delays can be caused when a passenger occupies his or her own wheelchair

until boarding (or during boarding if the chair fits down the aircraft

aisle, as is possible in some first class sections), because the

wheelchair has to be stowed at the last moment.   



4.2 Powered Wheelchair Stowage Problems  



Aircraft stowage of powered wheelchairs stands out as the most

challenging mobility aid stowage problem facing both disabled

passengers and the airlines.  Disabled passengers who use powered

wheelchairs experience many of the same types of problems reported by

people who use non-powered wheelchairs, as well as other significant

stowage problems.  



Powered wheelchairs use electrical storage batteries as their power

source.  The batteries are define as a hazardous material and,

therefore, are subject to U.S. DOT Research and Special Programs

Administration (RSPA) hazardous material restrictions.  Powered

wheelchairs, as compared to non-powered ones, are heavier, bulkier, and

more complicated mechanically.  In addition, they are not normally

foldable.  These factors make powered wheelchairs inherently more

difficult to stow on aircraft and more prone to damage.  Passenger and

airline perspectives on the problem are described below.    



The Passenger's Perspective  



Passengers report encountering the following problems related to powered

wheelchair stowage.



There are wide inconsistencies within and between airlines regarding

whether they accept powered wheelchairs and certain types of

batteries.  



Airline personnel can misinterpret federal regulations regarding the

carriage of batteries, citing restrictions that do not exist.  



Lead-acid batteries, the most common type used because they provide the

best source of power for wheelchairs, may not be accepted for aircraft

stowage unless the lead-acid battery is removed from the chair and

specially packaged.  Some airlines refuse to transport lead-acid

batteries altogether.  Some airlines will only accept the gel-cell type

batteries (which have a lower power output) because they are

non-spillable.   



When the lead-acid battery is removed from the wheelchair, it is not

always re-installed properly (if it is re-installed at all).  When the

battery is re-installed, it may be done improperly making the

wheelchair inoperable and, in some cases, causing electrical damage

because the cable-terminal connections are reversed.  A common problem

is that the battery terminals are left untightened.  In these cases,

the passenger must find the means to tighten the battery terminals

before the chair will operate reliably.   



Some passengers remove the wheelchair's sensitive electrical control

panel to avoid damage to it during transit.  Passengers take the

control panel on-board as carry on luggage.  



Some airlines require that the powered wheelchair be secured on a pallet

and transported as cargo.  This requires very early check-in and is not

possible during all hours of airline operation.  



When a powered wheelchair is damaged, it may not be possible to fix it

upon arrival at the destination due to lack of skilled service people

and/or the lack of parts.  Some passengers expect damage and carry

extra parts or tool kits for the purpose of anticipated repairs.  



Airlines may require that special, spill-resistant caps be placed on the

battery, a positive safety step.  However, problems can occur when the

special caps either are not compatible with the battery or are not

available.  Removing and replacing the original venting caps requires

extra effort and creates the potential for loss.  



Some passengers have had to buy new batteries at their destination

because an airline would not transport their batteries.  



Airlines may require that the battery be placed in a specialized battery

container such as one developed and used in Canada.  The container

includes all the materials required to isolate electrically the battery

and protect against battery acid spills.  However, the container is not

in widespread use in the U.S.  Some airlines contend that the container

does not represent an acceptable solution since it is not certified by

the U.S. Federal Aviation Administration (FAA). 



Airlines may require that the passenger supply his or her own battery

container; an added expense and inconvenience with no assurance that it

is safe for transport.  



With the current trend towards joint operating or "code sharing"

agreements between major and regional airlines, a passenger may not be

aware that the final leg of a trip will be made on a small commuter

aircraft.  Therefore, the powered wheelchair may be accepted for

transport on the first part of the trip but not for the last part,

because it does not fit on the final aircraft.  



The Airline's Perspective  



Several concerned airlines and airline associations have been searching

aggressively for solutions to powered wheelchair stowage problems. 

Their efforts have included participation in conferences on the topic

and the development by some carriers of procedures to accommodate

powered wheelchair stowage.  Nonetheless, the airlines still contend

with problems such as:  



The acid in a powered wheelchair battery is severely corrosive and,

therefore, would present a safety hazard if it spilled and contacted

critical elements of the aircraft.   For this reported reason, some

airlines are compelled to refuse to transport lead acid batteries,

citing hazardous material regulations and internal policies.  Some also

refuse to transport the safer gel-type batteries.  



If an airline is going to use a battery container, these containers are

an added cost (about $10 each) and must be stored somewhere near the

passenger check-in location.  



Powered wheelchairs can be quite heavy (300 pounds or more).  Some

airlines may elect to use power equipment to load powered wheelchairs

into cargo compartments.  However, at some airports wheelchairs are

still likely to be loaded manually, creating undue physical strain on

cargo handlers and creating the chance for personal injury or physical 

damage to the wheelchair (both incidents could expose an airline to

financial liability risks).  



A weight balance problem can be caused by a heavy wheelchair stowed in

the aft compartment of a small aircraft not carrying a full load of

passengers.  



The powered wheelchair is bulky and may reduce the amount of cargo that

can be loaded into the aircraft, especially when an airline properly

avoids placing anything on top of the wheelchair.  



The powered wheelchair is particularly susceptible to damage, leading to

damage even when special care is taken with it.  



4.3 Cane and Crutch Stowage Problems  



Canes and crutches present similar stowage challenges since they are

typically long, rigid objects which do not bend or compress/telescope

to fit within the small spaces available in passenger cabins.  Canes

include both the type used for standing support and the longer type

used for guidance by blind persons.  Crutches vary slightly in design

and overall length depending on the user.  Both canes and crutches must

be stowed in a manner that prevents them from becoming a dangerous

projectile in the even of a sudden aircraft motion. Passenger and

airline perspectives on the problems of stowing these articles are

presented below.  



The Passenger's Perspective  



Stowage of canes used by blind travelers produced few reported problems,

due in part to recent FAA regulations.  Two reported problems were:  



Some airlines require non-collapsing canes to be stored in the cargo

compartments since they reportedly will not fit safely inside the

passenger compartment.  This is the case where the overhead bins do not

have openings between them.  Blind passengers feel vulnerable without

their canes and feel restricted deplaning without them.  



Some blind passengers believe that the airline should provide a

collapsible cane for temporary use on the aircraft.  



Although no other specific problems have been reported by passengers,

the stowage of crutches and canes that are use for physical support

purposes can be a problem if the item is stowed away yet needed for

walking to the restroom or off the airplane.  The unavailability of

crutches and canes then necessitates the use of a boarding and/or

on-board chair.  



The Airline's Perspective  



Airlines have not reported specific problems regarding the stowage of

canes and crutches. however, it is clear from passenger reports that

there are occasional disputes between airline personnel and passengers

regarding the acceptability of bringing non-collapsing canes into the

passenger compartment.  Passengers may sometimes place canes and

crutches in positions from which they can become projectiles or

obstructions, producing conflicts between flight attendants and the

passenger.  



4.4  Service Dog Transportation Problems  



Blind and deaf passengers routinely travel with guide (seeing eye) or

hearing dogs.  While these animals could travel in the pressurized

cargo compartments reserved for animals, they normally travel with

their owners in the passenger cabin.  The problems associated with

transporting service dogs are described below.  



The Passenger's Perspective  



The normal, if informal, airline procedure regarding the seating of

passengers with guide or hearing dogs is to assign them a bulkhead

seat.  Passengers traveling with a dog sometimes request bulkhead

seating anyway.  Some people feel that the bulkhead seating location

generally provides extra legroom where the service dog can lie down. 

This seating location may, in cases, be required by the airline.  If a

bulkhead seat is not available or does not exist on the aircraft (as

with some small aircraft), the dog must lie at the passenger's feet in

the space allotted for feet and carry-on articles.  



Yet, many blind passengers submit that airlines have erroneously

concluded that bulkhead seating provides the most room for dogs to lie

at their owner's feet.  The thrust of this assertion is that bulkhead

seating does afford extra knee room which makes it easier to get into

the seat, but actually affords less leg room and less room for the

service dog.  There is not seat in front and, therefore, no additional

space (the space some people use for carry-on luggage) for the

passenger's legs or the service dog.  This is problematic because

service dogs are trained to lie down in the space provided under seats

such as in a bus or movie theatre. Lacking the normal leg room

available in most rows of seats, the passenger must fit his or her legs

and the dog in a smaller floorspace.  The dog ends up lying sideways in

the floorspace in a manner that intrudes into the legroom of the

adjacent passenger.  		 	



The airlines have been challenged repeatedly over the "standard

procedure" that requires persons traveling with service dogs to occupy

bulkhead seating.  Airlines may be misunderstanding some passenger's

requests to not be assigned bulkhead seating as obstructiveness rather

than a simple preference for a seat with the nominal legroom that will

accommodate the service dog better.  Also, a requirement to sit in a

bulkhead location may be considered a limitation of personal freedom,

especially if bulkhead seating is in a non-smoking area and the

passenger is a smoker. 



The Airline's Perspective  



All airlines surveyed stated that they accepted service dogs on their

airplanes.  Some have established practices of seating passengers with

dogs in bulkhead areas.  Sometimes these passengers were upgraded to

first class to provide more room for the dog.  No problems were

reported by airlines on the issue of transporting service dogs. 

However, the following airline concerns can be inferred:  



Dogs can make some passengers who fear dogs uncomfortable, leading to

requests for seating away from the dog.  



A dog in the aisle can restrict passenger and attendant movement within

the cabin, creating inconvenience and a possible safety problem.  



4.5 Miscellaneous Equipment Stowage Problems  



There is an occasional need to transport equipment such as personal

oxygen equipment and infant respiratory monitors.  No problems have

been reported in the stowage of these items. Usually, onboard-use

oxygen is provided by the airline while the passenger's oxygen

equipment is properly stowed in the cargo compartment.  However, some

airlines permit use of personal oxygen in-flight.  The stowage of most

specialized equipment is rare to the point that most airlines simply

innovate services as required.  This seems to be a workable and

sensible approach in this area.  



4.6 Problems Related to Airline Policy-Making and Implementation  



The research leading to this technical paper involved reviewing a wide

range of policies, procedures and practices submitted by a broad

cross-section of air carriers.  Inconsistencies between policies and

the procedures and practices designed to implement them arose as a

major problem area.  The problem was found to be rooted in airline

policy-making and implementation processes.  This problem can be

extrapolated to services for handicapped travelers in general.  The

problem of the policy-making and implementation process is

characterized by the fact that airlines using the same aircraft and

serving the same markets provide markedly different levels of mobility

aids stowage service.  The Influence of the "Expert" on Services to

handicapped Passengers  



In most airlines, one person is typically assigned to be the "expert" on

services to handicapped passengers.  As such, he or she is responsible

for developing mobility aids stowage policy recommendations and

procedures and seeing that they are put into proper practice.  Usually,

this individual is part of the airline's "middle management".  Rarely

has an officer of a major airline become personally involved.  



Table 1 presents a sample of the level and department in which services

for handicapped travelers are coordinated for many selected airlines. 

It should be noted that while many airlines have one person responsible

for the area of such services, other have a number of department heads

involved in finding solutions.  



Variation in the levels of responsibility of the person responsible for

services to handicapped travelers and their areas of expertise indicate

why there are inconsistent policies and levels of service among the

airlines.  Developing responsive policies and levels of services is

dependent on the initiative and interest of the airline's designated

"expert".  However, implementation can depend on organizational

politics and economic competition with other airline priorities.  The

solution may rest in promoting industry standard practices through

governmental and airline association efforts.  



A review of the history of services to handicapped persons among the

airlines indicated that a public statement of commitment to maximize

services by airline management is a key to improved services.  This has

been the case with Air Canada and British Airways.  It was found that

when this commitment was made, the single "expert" began to serve more

as a leader of several people within the airline who themselves become

increasingly expert in services to handicapped travelers.  The process

is self-feeding and moves an entire airline to heightened awareness of

handicapped travelers' needs and the objective of serving the needs

effectively. The airline benefits in the process through an increased

level of pride among airline personnel and an improved image among

handicapped travelers and patronage by them.  



Internal commitment of a single division within an airline also can

motivate improvements in services to handicapped persons.  United

Airlines, through the effort of its Engineering Division to assure an

accessible Boeing 767 cabin, achieved a reputation as an industry leader

in services to handicapped travelers.  The Engineering Division has

continued to provide the thrust to maximize other areas of services to

handicapped travelers throughout the airline's operation. 



Table 1.  



Representative Sample of Airline Personnel Who Innovated Services to

Handicapped Persons or Hold Current Responsibility  



Aer Lingus  Manager/Customer Standards 



Aero Trasporti Italiani  Director/Traffic Management 



Air Canada  Operations Support Manager 



Air New Zealand  Principal Medical Officer 



Alaska Airlines  Assistant V.P./Customer Service 



Ansett Airlines of Australia   National Manager/Traffic 



Australia Airlines  Airport Manager Service Controller 



Braathens S.A.F.E.  Manager of Flight Operations 



British Airways Principal Overseas Medical Officer 



British Caledonian Airways   Manager/Operations Projects 



Dan-Air  Passenger Services Officer 



Delta Airlines Systems Manager-Stations Administration 



East-West Airlines  Traffic Systems Supervisor 



Eastern Airlines  Manager/Line Training and Inflight Services 



Finnair  Inspector/Passenger Handling and Services 



Garuda Indonesia Inflight Service Supervisor 



Henson Airlines  Chief Flight Attendant 



Kuwait Airways  Manager/Airport Services Procedures 



MALEV Hungarian Airlines  Manager/Airport Facilities 



Mesaba Aviation VP Ground & Flight Services 



Pacific Southwest Airlines Director of Consumer Affairs 



Pakistan International  Manager/Customer Services, Research and

Development  



Pan American World Airways   Director/Passenger Terminal Support

Services 



Piedmont Airlines  Director of Passenger Procedures 



Scandinavian Airlines  System Senior Cargo Systems Officer 



Swissair  Manager/Cabin Concepts and Comforts 



TAP-Air Portugal  Conditions of Service Manager 



Trans World Airlines  Manager/Inflight Services, Planning and Equipment



US Air  Director/Customer Service Systems 



Wardair Canada   Manger/Procedures and Training 



Yemen Airlines  Customer Services Manager  





Problems Related to Turning airline Policy Into Practice  



A comparison was made between stated airline policies and field

practices.  It was determined that documented airline policies often do

not include procedures and, even where a detailed procedure is set

forth,, this does not necessarily define actual airline practice.  Wide

gaps between procedures and practice were found.  Interviews with

airline station personnel and cargo handlers showed that mobility aids

stowage often depends on field innovation as opposed to following

detailed procedures.  Many of those interviewed could not cite the

details of their airline's wheelchair handling procedures and yet

described how they would preform the task if the need arose.  The need

to reference procedures was not mentioned.  



Most people interviewed said that the need to stow a mobility aid was a

rare event.  This means that many airline personnel are not well

practiced at mobility aids stowage techniques and have not had

extensive opportunities for on-the-job training.  This should produce a

greater dependence on procedures but this was not found to be the case. 

There is a high degree of innovation prevalent in mobility aids stowage

services, even where procedures exist. this explains why there are

inconsistencies in services within given airlines.  



Nevertheless, some airlines have developed effective procedures to deal

with many of the problems identified.  The purpose of this technical

paper is to provide this information to other carriers and promote

uniformity.  The solution to the problem centers not only on developing

effective policies, but also translating those policies into effective

procedures and then providing the proper training to assure that these

procedures are turned into effective practices.  This requires a

commitment to a process that includes:  



documenting policies 



developing usable, readable procedures 



conducting training in the field practices required by the procedures  



5.1  Wheelchair Stowage  



This section of the technical paper discusses the various facets of

stowing powered and on-powered wheelchairs, including:  



when to stow and return the wheelchair 



cargo compartment accessibility 



handling and loading 



use of specialized containers 



securing the wheelchair in the cargo compartment 



stowing the battery  When to Stow and Return the Wheelchair  



A review of (1) a representative sample of airline operating procedures

and (2) accounts of personal experience indicated that procedures for

stowing and returning wheelchairs to their owners are highly variable. 

Procedures can vary between airlines and even within the same airline

at different locations and times.  Procedural inconsistencies have a

disruptive effect on the disabled air traveler's sense of freedom and

equal access and create bad public relations for the air carrier.  



Wheelchair users are often requested or required to leave their personal

wheelchairs upon check-in and get into an airport terminal wheelchair. 

The transfer to an airport terminal wheelchair often occurs earlier

than is necessary for the personal wheelchair to be stowed on the

departing aircraft.  Often, the airport wheelchair may not be physically

suitable to the traveler.  This can exacerbate physical problems such

as pressure sores.  Also, disabled air travelers must often wait long

periods of time to have their own wheelchairs returned to them at the

flight's destination point.  



In summary, the disabled air traveler can never rest assured that

effective, timely services provided by one airline at a given location

and time will be available later at the next location or when flying

with a different airline.  The restriction of freedom, not being able to

use one's personal wheelchair and waiting extended periods at the end

of the flight, intrudes into travel plans and naturally causes

passenger frustration and anger.  To achieve a degree of

predictability, disabled travelers often find one airline that provides

good service and stick with it as much as possible.  Establishing a

consistent procedure for wheelchair stowage would have a positive

effect on the disabled traveler's real and perceived sense of freedom

and equal access.  



Airline personnel who handle wheelchairs should be aware that

wheelchairs often have special options such as removable armrests,

swing-out/removable footrests, and quick-disconnect wheels.  These

features may not be readily apparent to airline personnel.  Also, many

wheelchairs that appear to be standard wheelchairs have actually been

customized or modified by their owners.  Airline personnel should not

assume that a passenger's wheelchair is identical to the one they have

been trained to handle, even if it looks similar.  The wheelchair user

is the best authority on how to handle the wheelchair.  Taking

advantage of the wheelchair user's expertise was identified as a key

component in the successful airline policies reviewed. Therefore, this

component is included in the recommended preparations for wheelchair

stowage.  



An appropriate airline staff person should discuss with the wheelchair

user stowage methods to determine how mechanical parts like the

footrests are to be removed (if possible), how the (non-powered)

wheelchair folds-up and if any special protection measures can be taken.

To the extent possible, any dismantling should be performed in the

presence of the wheelchair user so that the task is performed

correctly.  



Figure 1 shows an Everest & Jennings Premier 8 powered wheelchair with

several parts removed for the purpose of aircraft stowage.  Care should

be taken to identify removable or delicate parts by which the chair

should not be lifted.  Also determine whether there are any articles

such as seat cushions or packs which should remain with the passenger.

Where appropriate, airline personnel should consider tagging components

to ensure correct assembly at the destination.  



The wheelchair user should stay in his or her own personal wheelchair as

close as possible to boarding.  If the wheelchair will fit down the

aircraft aisle (as in some first class compartments), the chair should

be used for boarding.  If a skybridge is used, the transfer to a

boarding chair should take place just outside the aircraft cabin door. 



If possible, the manual wheelchairs should be stowed in the cabin,

consistent with Air Carrier Access regulations (14 CFR 382) and FAA

regulations on stowing on-board articles (14 FAR 121.589 and 135.87).

Note:  Regulations provided in Attachment 2.   



After the passenger gets out of his or her personal wheelchair, the

wheelchair is immediately brought to the cargo dispatching area.  



The individual who spoke with the wheelchair user on the subject should

communicate any special handling requirements to a cargo handler who

has been specifically trained in the handling and protection of

wheelchairs.  



The wheelchair should be prevented from unfolding (with a strap, elastic

bungy cord or tape) and placed in a plastic bag for nominal protection

purposes (see later section on the use of containers).  Any special

protections that are feasible should be carried out.



The wheelchair should be placed and secured in the cargo compartment in

a position which will allow it to be removed immediately from the

aircraft upon arrival at the destination point. this will facilitate

rapid delivery of the wheelchair to the passenger.  Optimally, there

should be a predefined wheelchair location in the aircraft which

affords maximum protection and accessibility.  



The wheelchair should be immediately available to the passenger upon

deplaning.  Deplaning will usually first require use of a boarding

chair to get out of the aircraft. If a skybridge is used, the

wheelchair should be available at the base of the skybridge where it

attaches to the aircraft cabin door.  Passengers should be transferred

to their own wheelchairs and assisted into the terminal and thereafter

as appropriate.  



If there is a long layover (over one hour), the airline should deliver

the passenger's personal wheelchair for intra-terminal use while the

passenger waits to take the next leg of the trip. When a layover is

short (less than one hour), this step may not be feasible or worthwhile.



The wheelchair should be returned to the passenger in the same condition

it was received from the passenger.  If any part of the  wheelchair was

dismantled, it should be reassembled.  Here the problem is that the

person who dismantled the wheelchair will not be the person who

reassembles the wheelchair.  An effective solution to reassembly

problems is for the airline employee to discuss proper assembly with

the wheelchair's owner.  



The airline should confirm with the wheelchair user that the wheelchair

has been returned in proper working order and that no additional

assistance is needed.  



Cargo Compartment Accessibility  



Powered wheelchairs can be difficult to fit into cargo compartments of

aircraft because of their overall size and weight and the fact that

powered wheelchairs are not generally foldable.  The degree of the

problem depends largely on the type of aircraft involved and to a lesser

degree on the type of wheelchair involved.  



Ideally, powered wheelchairs should be stowed standing upright so that

they can be best protected from damage and so that their batteries can

stay in their normal orientation (protecting from electrolyte

spillage).  If necessary, a powered wheelchair can be stowed on its

side, although this position increases the chance of damage and requires

removal of the battery.  The necessary wheelchair orientation will

depend on the height of the cargo compartment and cargo access door.  



Wide body aircraft (such as the DC-10, L1011, B-747, B-757, B-767, and

A-300) generally permit upright wheelchair stowage in special

containers called unit load devices (ULDs) which are then inserted into

the cargo compartment.  Figure 2 shows a powered wheelchair stowed

upright in a ULD.  As shown in figures 3 and 4, some narrow body

aircraft such as the 165 passenger B-727- 200 have cargo compartments

and access doors which are also high enough to fit a powered wheelchair

standing upright.  Other narrow body aircraft such as the B-737-300

have cargo compartments which are also tall enough.  However, as shown

in Figure 5, they have access door which are not as tall and require

sideways tipping of the wheelchair to get through the door.  



Fitting wheelchairs upright is not possible in several of the

narrow-body aircraft (such as the DC-9, F-28, BAe-146 and BAC- 1-11)

because cargo is stowed in a belly compartment with a low ceiling.  In

these narrow-body aircraft, the powered wheelchair can usually be fit by

laying the wheelchair on its side.  However, some aircraft such as the

72 passenger F-28-4000 have cargo doors which are too small to allow a

powered wheelchair to pass through in any orientation, even if folded. 



In many small regional aircraft (such as the F-27, Short 330, Beechcraft

1900, Fairchild Metro 3) that feature aft stowage compartments, the

wheelchair can be stowed upright because of the greater ceiling

height.  Figure 6 shows a powered wheelchair being loaded upright into

the aft cargo compartment of a 19 passenger Beechcraft 1900.  Figure 7

shows a powered wheelchair which could be dismantled and folded to fit

in the belly cargo compartment of a 19 passenger Jetstream 31.  This

illustrates that the mid-sized, (50-150 passenger), narrow-body

aircraft often create the greatest difficulties or barriers to

wheelchair stowage.  



To avoid accessibility problems, some airlines instruct ticketing agents

and station managers to verify that wheelchairs accepted for transport

will fit in the cargo compartments of all aircraft that will be flown

on the passenger's route (round trip).  This procedure is especially

important where the flight plans involve connections with regional

airlines that operate smaller aircraft. The procedure avoids the

possibility that a wheelchair which can be stowed in the aircraft used

on the first leg of a trip does not fit in the aircraft used on a later

leg of the trip.  Clearly, a comprehensive guide to cargo compartment

and access door sizes of all commercial passenger aircraft would be

valuable for travel planning by wheelchair users, travel agents and the

airlines.  



To improve cargo compartment access, the overall space requirements of

the powered wheelchair can be reduced by removing certain parts such as

the footrests, armrests, and headrest.  For example, removing the

headrest may make the wheelchair just short enough to fit through the

compartment door and allow upright stowage inside the cargo compartment.

the height and width of the cargo compartment door is typically less

than the internal dimensions of the cargo compartment and, therefore,

is the limiting factor on fitting a powered wheelchair in the cargo

compartment.  If wheelchair parts are removed, they should be attached

to the wheelchair so that they are not lost.  Removal of the wheelchair

parts should be performed with prior discussion and permission of the

wheelchair owner.  Airlines should ensure that personnel with the

proper skills and tools will be able to reassemble the wheelchair at

the flight destination point.  



As a side note, removal of an item such as the electrical controller

(control stick), shown in figure 8, is not likely to reduce wheelchair

stowage space requirements.  However, removing the control protects it

from damage due to other items that may get stacked around the

wheelchair.  When total luggage capacity is limited, such as in small

commuter aircraft, removal of the control eliminates the possibility

that shifting baggage will damage the delicate control mechanism.  It

is recommended that, if possible, the wheelchair owner retain (as a

carry-on item) the control in his or her personal possession to avoid

damage or loss.  



Handling and Loading  



Cargo/baggage handlers need to be aware that a wheelchair can sustain

costly damage if not handled with special care.  A wheelchair can not

be treated with the same "roughness" to which luggage is routinely

exposed.  Wheelchair users report frequent damage of the following

kinds:  



bent parts (wheel spokes, push handles, armrests) 



torn or stained seat coverings 



missing pieces such as footrests, armrests, and belts  This type of

damage suggests:  



luggage is piled on top of wheelchairs 



luggage is crushed laterally against wheelchairs 



shifting objects impact and abrade the wheelchair 



wheelchairs are banged-up during loading and unloading 



wheelchair components that are removed from the wheelchair for compact

stowage get separated from the chair because they are not in some way

affixed or packaged with the wheelchair.  The solution is to increase

cargo handler's understanding of the importance of protecting

wheelchairs from damage and to provide to cargo handlers guidelines on

stowing the wheelchair.  Such guidelines should be short, simple and

concise and could include the following:  



Do not stack luggage on top of a wheelchair  



Do not laterally compress a wheelchair that is not protected by a

special container.  



Belts and ropes used to hold down a wheelchair should be attached to the

wheelchair frame, as opposed to more delicate components (such as the

spokes).  



Where feasible, the wheelchair should be stowed standing upright.  



The wheelchair should be protected with a plastic covering which can

also hold detached components to avoid their loss.  



The wheelchair should be stowed at a location where it can be stowed

last upon aircraft departure and removed first from the aircraft upon

arrival at the destination.  



The wheelchair should be tagged with a warning label which specifies

that the wheelchair is delicate and should be stowed standing upright. 



The wheelchair should be tagged or otherwise marked with the passenger's

identification and ticket information.  



Handling a Heavy Wheelchair  



The weight of a powered wheelchair can exceed 300 lbs.  This heavy

weight results from a large steel frame, one or more batteries, a heavy

duty electric motor, a large seat, and accessories.  The heavy weight,

by itself, poses a cargo handling challenge rather than an

accessibility problem.  Ideally, a lifting mechanism should be used to

transport the wheelchair to the proper location and elevation so it can

be moved laterally into and out of the aircraft cargo compartment. 

Often, the wheelchair must be handled manually due to the lack of

lifting equipment.  In either case, several strong individuals are

required to manipulate a heavy powered wheelchair.  



Some airports may not have enough cargo handlers available to safely

lift the wheelchair into the aircraft cargo compartment.  If an

individual cargo handler is overburdened by the weight of the powered

wheelchair, there is an increased chance of personal injury and damage

to the wheelchair.  To avoid such incidents, airlines need to implement

procedures incorporating: guidance on the number of cargo handlers who

participate in the movement of heavy wheelchairs. 



cautions regarding the importance of avoiding damage to the 

wheelchair.  



instructions to utilize lifting equipment.  



where practical, advance notification to cargo handlers that a heavy

wheelchair is anticipated, especially at small airports where an

appropriate number of trained handlers may not be readily available.  



guidance on the proper areas to grip the wheelchair (i.e. by the frame

and not by the spokes or removable parts) so as to avoid damage.  



Use of Specialized Containers  



Several initiatives have been undertaken to develop specialized

containers for wheelchairs, which will protect them from damage during

cargo handling and transit inside aircraft.  To date, development

efforts led by Transport Canada have not produced positive results

except to demonstrate that protection of wheelchairs may ultimately

depend on (1) instituting effective and consistent airline cargo

handling procedures and (2) providing a minimal level of wheelchair

protection against environmental factors.  



In an attempt to reduce the damage caused to wheelchairs while in

transit, the Transportation Development Centre (TDC) in Montreal,

Quebec sponsored the design and field testing of a cardboard wheelchair

container and a re-usable foldable container.  The projects resulted in

technical reports describing the development effort (Transport Canada

Report No. TP 3609 and TP 341E, respectively).  Fifty cardboard

containers were manufactured and placed in field testing with Air

Canada at Dorval.  The design requirements for the cardboard containers

were matched closely by containers used by Everest & Jenning (a

wheelchair manufacturer) to protect and ship over 2000 various model

wheelchairs from their plant in Canada to sites in Canada and the

United States.  Everest & Jenning had reported little incidence of

damage during shipping.  Therefore, one of the Everest & Jenning

containers was selected as the pattern for a TDC prototype.  



TDC field testing of the prototype cardboard container yielded quite

unsatisfactory results such as torn handles, punctures in the side, and

torn seams and closure flaps.  Moveover, TDC's report recommended

against the implementation of a container, even if it were sturdier,

because of cost, insufficient protection against dropping, time and

training requirements, and supply problems.  In addition, an opaque,

rigid container could encourage handlers to treat it rougher than they

would ordinarily treat a wheelchair.  



In addition to investigating a cardboard container, TDC sponsored the

development of a re-usable container (TDC Project No. 4504) designed to

protect the wheelchair against a 90 kg lateral load, protect against

intrusion, provide a means to contain detached wheelchair parts,

protect the wheelchair against rain, snow, and dirt, be re-usable and

cost effective, be foldable for compact storage, be quick and easy to

use, and accommodate a standard-sized wheelchair.  The TDC initiative

produced a container design that met the project's developmental

requirements but TDC called the container a compromise from the ideal -

a dedicated, protective storage location (pigeon-hole) inside the

aircraft which might alleviate the need for a special container. 



Despite extensive investigation of other container systems by Transport

Canada, use of a simple plastic bag has emerged as the only  wheelchair

protection system that is feasible to implement, economically

acceptable to the airlines, and worth the trouble.  



Air Canada has had considerable success using a plastic, transparent bag

to protect wheelchairs against minor damage.  Similar in concept to

bags used to protect skis and other athletic equipment, the bags are

reportedly a more effective means of protection, as compared to rigid,

view-obscuring containers.  The plastic bag does not mask the fact that

the container holds a wheelchair which is vulnerable to damage.  The

belief is that cargo handlers are less likely to stack other luggage on

top of a wheelchair that is in full view.  



The plastic bag does not afford protection from static loads or impacts.

However, it affords good protection from environmental factors (rain,

snow,, dirt, etc.).  The bags do not require significant storage space

at the cargo handling location, nor are they expensive.  The bags

assure that detached items are contained with the wheelchair and that

parts that are broken off during handling and transit will not get

lost.  Since the wheelchair is in view during stowage and handling,

there is an increased chance that the wheelchair will be recognized as

requiring priority handling (last on, first off).  



Using a Belt Loader  



As shown in Figures 9 and 10, a "belt loader" is used by airlines to

load wheelchairs aboard many of the narrow body and larger jet

aircraft.  United Airlines has developed specific instructions/cautions

for belt loading of wheelchairs.   The instructions/cautions are

incorporated in the airline's detailed wheelchair stowage procedure and

are designed to facilitate the loading process and avoid wheelchair

damage.  The instructions/cautions are presented below in an adapted

form.  



Prevent the wheelchair from tipping while it is on the belt loader

since, when a spillable wet-cell battery is involved, there is the

potential for a battery acid spill if the wheelchair is tipped.  



Place the wheelchair upright on the belt loader with the wheelchair's

brakes set and the belt bed positioned at the most level attitude

possible to minimize the tilt of the wheelchair.  



Reduce belt speed to avoid abrupt starting and stopping of the belt

which could tip over the wheelchair.  



Boeing 747 and 767 aircraft should be loaded via the container loader

which is not sloped, thereby allowing the wheelchair to remain level

during loading. 



It may be necessary to rotate the wheelchair approximately 30 degrees to

the side to fit through the bulkpit door.  (Note:  This step may

require battery protection measures discussed in other sections of this

technical paper)  



In addition to these instructions/cautions.  The airline's procedure

specifies locations for wheelchair stowage.  As an example, loading in

the forward cargo bulkpit is specified for Boeing 727 aircraft, while

loading in either bulkpit is specified for Boeing 737 aircraft.  



Notifying the Pilot of Powered Wheelchair Stowage  



According to United Airline's procedure, when a powered wheelchair is to

be stowed, passenger service personnel are required to complete a

"pilot notification" form.  United Airlines form is shown in Figure

11.  This form is placed in a special handling bag tag which, in turn

is placed on the wheelchair.  The form is later removed from the

wheelchair by ramp service personnel who deliver the form to the flight

crew.  



The sample form actually serves the combined purposes of (1) pilot

notification and (2) wheelchair stowage checklist.  It may be most

appropriate to use separate forms for these two purposes since the

procedures recommended in this technical paper for wheelchair stowage

and battery protection would suggest a more extensive checklist.  An

alternative notification form is provided as Figure 12.  



Securing the Wheelchair in the Cargo Compartment  



Wheelchairs are secured in a cargo compartment in one of several ways:  



netting 



straps 



surrounding luggage and walls  The method used depends largely on the

type of aircraft in use.  



Narrow body aircraft have what is termed a "bulkpit".  The bulkpit is

simply a large storage volume, the open space inside the belly of an

aircraft.  Cargo is secured in the bulkpit by the means of netting and

straps.  For wheelchairs, the use of straps is typically required

because netting tends not to provide the same degree of support.  The

goal is to avoid shifting of the cargo during flight.  However, netting

is effective where a folding wheelchair is placed between other pieces

of luggage, although merely bracing with other luggage is not

recommended, especially for powered wheelchairs.  



It should be mentioned that some aircraft are not equipped with tie down

hardware for netting for straps since an aircraft cargo compartment is

often customized to meet a client's requirements.  This work is

performed either by the original airframe manufacturer or an outside

fitter. Therefore, the provision of cargo compartment features that

facilitate wheelchair stowage and protection depends both on the

customer's requirements and the features that are offered by the cargo

compartment fitters.  



Some narrow body aircraft have an electrically driven partition wall

which partitions the cargo compartment as required to accommodate

cargo.  The partition wall can be used to create a small compartment in

which a wheelchair can be contained, perhaps by itself, and protected

from loads and impact by other cargo.  



Wide body aircraft employ container systems.  Cargo is placed in special

containers which match the section profile of the cargo compartment. 

The wheelchair is secured in the container which is then placed in the

aircraft.  Again, the wheelchair may be secured in the container with

netting or straps or may be sandwiched in place. Some wide body aircraft

still have a bulkpit cargo compartment in addition to the compartment

space allotted to the containers.  This bulkpit is accessed through a

separate door than the one that provides access to the container

holding section. If a wheelchair is stowed in this bulkpit compartment,

it is secured in the same manner used for bulkpit stowage in narrow body

aircraft.  



The stowage system described above may lead to damaged wheelchairs. 

However, changes to the cargo compartment itself are highly unlikely. 

Therefore, the recommendations presented earlier for more delicate

treatment of wheelchairs during handling and placement inside the cargo

compartment are the areas of opportunity for improvement.  



A concept that could make securing wheelchairs more straightforward and

efficient would be to mark physically the least vulnerable and most

accessible location for the wheelchair inside the bulkpit (a marking

could be placed on the floor and/or wall).  Stowing the Battery  



The stowage of wheelchair batteries has been a continuing source of

passenger-airline dispute and technical challenge.  Some airlines

accept powered wheelchairs and their various types of batteries for

stowage with no reported problems, while other airline policies impose

restrictions.  Some will accept the powered wheelchair but not its

lead-acid battery.  Some will accept only a wheelchair powered by a

gel-cell battery.  Passengers who use wheelchairs have been frustrated

by the fact that effective solutions to the battery stowage problem

exist and are in practice and yet some airlines have not implemented

them.  The variation of service has been attributed to variation in the

interpretation of federal regulations governing battery stowage.  

 

 The technical root of the battery stowage issue is that batteries

contain a hazardous, acidic material (electrolyte) which can present a

safety risk to the aircraft if the material does not remain properly

contained during handling and during the flight itself.  The U.S. DOT

addresses the requirements for the transportation of wheelchair

batteries in the Code of Federal Regulations, 49 CFR Parts 171, 172,

and 173 and 175.  In the regulations, there is a distinction between

safety precautions that are required for wheelchairs which cannot be

stowed upright and use batteries that are "non-spillable" as opposed to

"spillable".  



Lead-acid batteries are generally considered "spillable".  Most

lead-acid batteries are constructed with vents that allow for the

addition or replacement of electrolyte and the escape of gases that

build up inside the battery.  (Note:  Gas discharge is greatest during

battery charging and discharging and virtually non-existent when the

battery is not connected to an operating motor.)  The concern is that

the fluid-state electrolyte can escape through the vents if the battery

is tipped over or subjected to certain types of impact, vibration or

acceleration. Removing the electrolyte from the battery has been a

practice with some airlines but the practice is fraught with problems

including:  



threat of fluid spillage 



hazardous waste disposal 



irreversible damage to the battery 



unavailability of fluid at the destination 



inconvenience  



Gel-cell batteries replace the fluid-state electrolyte with an

electrolyte that is in a gelatinous state.  The gel-cell is reportedly

not subject to spillage under the spillage conditions described above. 

Most new electric wheelchairs are designed to accept gel- cell use. 

However, the drawback to gel-cell batteries is their high cost and

reduced electrical performance in comparison to lead- acid batteries. 

Therefore, for the present and near future, it is expected that

airlines will face the problem of stowing powered wheelchairs equipped

with either type of battery.  Solutions have been developed by several

air carriers and are described below. 





Recommended Battery Stowage Procedure:  



The battery stowage procedure recommended here is a product of research

on (1) the most effective wheelchair battery stowage practices, (2) how

the airlines presently stow batteries, and (3) where airline policies,

procedures and practices need improvement to eliminate  mobility aid

stowage problems faced by disabled air travelers.  The research findings

have been correlated with U.S. DOT hazardous material regulations

affecting battery stowage (49 CFR Parts 171,172,173,174,175 and

supplementary information published in Federal Register/Vol.  47, No.

109/7 June 1982).  



A prototype battery stowage procedure is provided separately as

Attachment 1 due to its relatively long length.  The procedure is

designed to help airlines meet the hazardous material rules on battery

stowage.  It is intended to maximize the ease of transporting powered

wheelchairs (specifically the batteries) while  also achieving maximum

safety against battery spillage/leakage incidents.  Beyond helping

airlines to implement hazardous material rules effectively, the

procedure could help achieve  consistency in airline industry wheelchair

and wheelchair battery stowage practices.  Increased consistency in

airline practices will help handicapped people plan their travels

effectively, promoting confidence in mobility aids stowage services and

understanding of the rationale for any limitations.  



The stepwise instructions in Attachment 1 are designed as guidelines

from which more detailed, airline-specific procedures for wheelchair

battery stowage can be developed.  Pending review by the industry, the

procedures are offered as an effective solution to the battery stowage

problem since (1) they meet the hazardous materials rules and (2) they

are based on existing airline practices.  The overall approach requires

no development of new technology and, therefore, introduces no

technical barriers to implementation.  



The stepwise approach involves:  



determining the orientation of the wheelchair during loading and stowage



determining if the wheelchair battery is "spillable" or "non-spillable" 



selecting the correct method for wheelchair battery stowage based on the

wheelchair loading and stowage orientation and battery type.  In

addition, personnel at the destination must have adequate policy

guidance and instructions on how to properly unpack and re-connect the

batteries.   



5.2  Service Dogs  



With few exceptions, there appears to be high level of consistency among

airlines regarding the method for transporting service dogs.  (Note: 

The term "service dog" applies to dogs which serve as mobility aids to

blind and deaf persons.)  The common practice is described below.  



The words "and guide dog", "and hearing dog" or "and service dog" follow

the name of the passenger as printed on the airline ticket.  



The dog must be properly harnessed and must always remain with the

passenger.  



The dog may be required to wear a choke chain for the purpose of

controlling the dog in the unlikely event that the dog gets out of

control in the cabin.  



an identification tag showing the owner/passenger's name and seat number

must be placed on the dog's collar.  



The passenger is often provided a bulkhead seat location under the

assumption that this provides more room for the dog to sit or lie at

the passenger's feet.  If the passenger wants seating in another

location, the request if frequently granted.  The passenger is ideally

seated next to the window so that other passengers do not have to step

over the dog to reach the cabin aisle.  Seating is generally not

allowed in an emergency exit aisle since the dog could interfere with

the movement of other  passengers in the event of an emergency.  It is

recommended that bulkhead seating no longer be designated as a

""default" seating location for persons traveling with service dogs

since this location actually provides less room for the dog.  



In small aircraft with insufficient space for the dog to lie down under

the seat, the dog is allowed to sit or lie in the aisle.  



Some airlines recommend that the attendant discourage other passengers,

especially children, from petting the dog (unless invited by the

passenger traveling with the dog).  



dogs are not allowed to occupy seats.  



One foreign airline requires that the passenger provide an absorbent mat

for the dog to lie on.  However, this step is not considered to be

needed and is not a requirement among domestic airlines.  



5.3  Crutches and Canes  



Few airlines document specific procedures for handling crutches and

canes, leaving stowage procedures flexible and up to the cabin

attendants.  Although canes and crutches can vary in type and length,

they all share the same general physical stowage requirements.  Several

appropriate solutions to the stowage of crutches have been implemented

by various airlines. They include:  



stowage between the seat and aircraft cabin wall (the outboard side

walls), placed so the aid(s) fit under the passenger's seat at an

angle.  This method is not allowed in emergency exit rows.  The method

also requires that the passenger be seated in a window seat.  



stowage under any series of passenger seats in a single row (not in

including emergency exit rows) if the object does not intrude into the

aisle.  



stowage in the overhead compartment if possible.  Some aircraft have

overhead compartments that have openings between individual bins. 

Others do not have openings between overhead compartments and,,

therefore, do not accommodate crutches and longer canes such as the

long "white cane" used by blind persons.  



if it fits, the cane may be placed in the garment bag compartment or

similar closet.  



Collapsible canes can be stowed in the same way that an item such as a

collapsible umbrella or pocketbook might be stowed, under the seat or

in the overhead compartment.  



All of these methods are consistent with FAA regulations on stowage of

on-board articles (14 CFR 121.589 and 135.87).  Note: Regulations

provided in Attachment 2.  



5.4  Miscellaneous Equipment  



Personal Oxygen Equipment  



Most airlines do not permit passengers to use their personal oxygen

supplies during flights. airlines usually provide their own oxygen

equipment for in-flight use and have detailed procedures to assure safe

and effective service to the passenger.  However, some airlines do not

provide in-flight oxygen and will allow passengers to use their own

oxygen supplies while in flight.  One such airline requires that the

passenger's oxygen bottle not exceed 22 inches in length so that it can

stow under a seat.  



Advanced notice (between 48-72 hours) is usually required so that the

airline can make arrangements for in-flight oxygen services.  There is

usually a charge for the oxygen service (on the order of $40.00).  



One airline requires that the oxygen equipment be prepared for stowage

as checked baggage as follows:  



The oxygen cylinder must be empty and packed in a container that will

protect it from damage due to normal handling.  



The oxygen cylinder regulator must be detached.  



The problem this procedure creates is that the passenger will lack an

oxygen supply upon deplaning since the personal oxygen bottles will

have been emptied for stowage purposes. No resolution to this problem

has been determined.  However, airlines that permit the use of personal

oxygen during the flight also permit stowage of filled oxygen bottles

both under passenger seats and in overhead compartments.   



Walkers  



Walkers, due to their bulk, are typically stowed as checked baggage.  It

is likely that an airline would accept stowage of a walker in the

aircraft cabin (in a garment compartment or closet) if the walker were

collapsible.  



Infant Respirator/Heart Rate Monitor  



One airline addresses the use of an infant respirator/heart rate monitor

in its operating manual. the airline states that such equipment can

produce an electrical signal (30 kilohertz square wave) that has the

potential to disrupt the aircraft's navigational system.  The airline

requires that the electrical signal generating capability of the

equipment be disabled for the duration of the flight.  



Incubator/Respirator/Portable Dialysis Equipment  



While airlines do not provide incubators, respirators or portable

dialysis equipment, several airlines have general policies and/or

procedures for acceptance of such equipment for in-flight use.  The

aircraft cabins generally are equipped with a 110 V/AC outlet which can

power the devices.  Specific stowage procedures are developed on an

individual basis.  No specific discussion of electrical interference

problems was found.   



One airline recommends that delicate equipment such as an infant

incubator, even when it is not in use, be stowed in the aircraft cabin

(given proper arrangements) since stowage as cargo presents too great a

risk of damage to the equipment.                                        





ATTACHMENT 1



Proposed Wheelchair Battery Stowage Procedure



Step 1:  Determine the Orientation in Which the Wheelchair Will be

Stowed



A wheelchair should be stowed standing upright if possible.  If it

cannot fit in the cargo compartment standing upright, it can be laid on

its side so that it does fit. The stowage position most often

determines how the battery must be stowed. The dimensions of the cargo

compartment access door may require the wheelchair to be tipped

sideways to fit through the door - a factor which also influences

battery stowage.



You need to compare the dimensions of the wheelchair to (1) those of

the cargo compartment in which the wheelchair will be placed and (2)

the cargo compartment access door.



Therefore:



You need to determine if the wheelchair can be loaded and stowed:



standing upright vs. on its side vs. not at all



You can determine the overall wheelchair dimensions  by one or more of

the following methods:



a) Ask the passenger b) Measure the chair



You can determine the aircraft cargo compartment and  access door

dimensions by one or more of the  following methods:

  

a)  See the Operating Manual, Page ---------.(to be supplied by each

airline) b)  Ask cargo handlers to take measurements



If the wheelchair can be loaded and stowed upright 



GO TO STEP 3



If the wheelchair cannot be loaded or stowed upright:



GO TO STEP 2



Step 2:  Determine if the Wheelchair Battery is                 

"SPILLABLE" or "NON-SPILLABLE"



Batteries are categorized as a hazardous material by the U.S.  Dept. of

Transportation's Material Transportation Bureau (MTB).  U.S. DOT

regulations specify methods for battery stowage on aircraft partially

as a function of the battery type.  There are two major types of

batteries used in electric wheelchairs:



Most common type:  Lead acid batteries                   "Spillable"



A lead acid battery is filled with a fluid called  electrolyte. 

Electrolyte is highly corrosive.  It can  leak or spill out of the

battery unless the battery is  packaged and handled properly.





Less common type:  Gel-cell battery "Non-Spillable"



A gel-cell battery is filled with electrolyte which is formulated in a

gel or "jelly" state.  The gel will not  leak or spill out of gel-cell

batteries.



You can determine what type of battery powers the wheelchair by one or

more of the following methods:  a) Inspect the battery for the label

"Gel-cell"; b) Ask the passenger;  c) Open battery vents to determine

if they are filled with electrolyte fluid or a gelled substance



Step 3:  Implement the Proper Method for Stowing the Battery



Based on the findings from Steps 1 & 2, you need to determine the

proper method for stowing the battery from the chart.



METHOD A:  PREPARE BATTERY FOR STOWAGE IN WHEELCHAIR



IMPORTANT:  Use this stowage method only when the wheelchair with

spillable or non- spillable batteries will be loaded and stowed  

standing upright. 



1. Make sure the battery is firmly secured to the  wheelchair. If

holder bracket appears to be loose,  either (1) tighten holder bracket

screws, bolts or  belts or (2) strap the battery to the wheelchair 

frame with strong tape such as duct or electrical tape.



2. Disconnect the power supply using one of the  following methods:

 

First choice: Disconnect the plug on the main power cable   which runs

from the battery case to the motor.   Depending on the wheelchair

brand, the cable   will be labeled "power" or will be color-coded red.



Second choice:   a) If there is no main power plug, disconnect  the

battery terminal cables from both the positive (+) and negative (-)

poles.



CAUTION:   When performing this task, you must wear eyeglasses and use

the proper size wrench and pliers.  To avoid damage the terminal

connectors should not be "jerked" loose, but rather, loosened

sufficiently to be detached without using excessive force.  You must

not let metal tools touch the metal frame and the battery terminal pole

at the same time or you could generate sparks or enough heat to pose a

burn hazard.



3. If the battery is in its own container (bucket)  equipped with a

lid,no further preparation is needed  (if the lid has been removed to

disconnect the battery cables, put it back on).  Proceed to step 4.

 

a) If the battery container does not have a lid, terminals must be

capped or taped to protect the battery from accidental contact with

metal objects during transit or reinstallation in the  wheelchair;

contact could cause sparks and high heat.



b) If the battery is not in a container which would serve to contain

minor seepage of battery acid, the battery's regular vent caps (which

are not "spill-resistant") should be replaced with "spill resistant"

vent caps. Package the regular vent caps in a plastic bag and attach

the bag to the   wheelchair.



WARNING: Regular vent caps must be replaced before reconnecting the

battery to avoid dangerous pressure buildup in the battery during

subsequent use.



4. Stow the wheelchair in the aircraft cargo compartment in a manner

that assures it will remain standing upright, using cargo straps or

netting.



END OF PROCEDURE



METHOD B:  REMOVE BATTERY FROM WHEELCHAIR AND PACKAGE IN APPROVED

CONTAINER



IMPORTANT:  Use this stowage method when the wheelchair with spillable

batteries must be turned sideways to fit it through the cargo

compartment door or if it will be stowed on its side.  Both are

conditions that could cause battery acid to spill or leak from the

battery.



1. For batteries placed in separate containers/housings, remove the

container from the wheelchair (if practical) and remove the battery

from its container.  You may have to perform the next step first,

before removing the battery from the container.



2. Disconnect the power supply by disconnecting the battery terminal

cables from both the positive (+) and negative (-) poles. CAUTION: When

performing this task, you must wear protective gloves and eyeglasses

and the proper size wrench and pliers.  To avoid damage, the terminal

connectors should not be "jerked" loose, but rather, loosened

sufficiently to be detached without using excessive force.  You must

not let metal tools touch the metal frame and the battery terminal pole

at the same time or you could generate sparks or enough heat to pose a

burn hazard.



3. Cap or tape the battery terminals/poles to prevent  contact with

metal objects during transit or  removal/installation.



In order to perform the next task properly, an approved battery

container including the following items are needed:



1 roll electrical tape



2 roll 2" masking tape



1 roll packing tape



1 roll putty



2 battery terminal/pole caps



6 "spill resistant" screw caps



6 "spill resistant" push caps



3 sheets absorbent material



1 large polyethylene bag to hold the battery & container



1 small polyethylene bag for regular battery caps



1 cardboard shipping box



1 special wheelchair shipping tag (Note:  These items are included in

the Air Canada battery package list.)



4a. If the battery is "spillable" and is equipped with regular vent

caps (which do not resist spills), replace these caps with the "spill

resistant battery" vent caps.  Package the regular caps in a plastic

bag.



4b. If the battery is "maintenance free" type, seal the  vent slots

with putty and hold the putty in place with  the 2" masking tape.

 

WARNING:  Putty must be removed from vent holes before operating the

chair.



5. Wrap the battery with three layers of absorbent  material. Three

layers will be enough to absorb the  entire fluid contents of the

largest wheel chair  batteries.



6. If the battery container has been removed from the wheelchair, place

the wrapped battery back in its  original container, place the battery

(and container)  in the plastic bag, twist the top of the bag, and

seal  the plastic bag with tape.



7. Place both the plastic bag containing the battery and  the smaller

plastic bag containing the regular battery  caps in the shipping box. 



8. Seal the box with shipping tape.



9. Attach a wheelchair shipping tag to the box.



10. Stow the box in the aircraft according to the proper orientation as

defined by the "THIS SIDE UP"  instruction and arrows printed on the

box.  Stow the  box near the wheelchair to avoid their separation. 



END OF PROCEDURE



METHOD C:  REMOVE BATTERY FROM WHEELCHAIR AND STOW



IMPORTANT:  Use this stowage method when a wheel- chair with

non-spillable batteries must be stowed on its side. Non-spillable

batteries will not leak if the wheelchair must be tipped during loading

or must be stowed on its side.  However, the batteries should be

removed to prevent shifting of the battery and potential damage to the

wheelchair during transit.



1. Disconnect the main power plug (remove cables  from the battery

terminals only if necessary to  remove the battery from the

wheelchair). 



2. For a battery in a separate container which can be  easily removed

from the wheelchair, remove the  container with the battery left inside

the container.



3a. If the container has a lid which prevents the battery terminals

from contacting other metal objects, make  sure the lid is secure (put

the lid back on the  container if it was removed to detach the battery 

cables).



4. Place the battery (and the battery container if provided) in a

shipping box and seal the box with  shipping tape.



5. Attach a wheelchair shipping tag to the box.



6. Stow the box and the wheelchair close together in  the aircraft. 

Secure the box and wheelchair with cargo straps or netting.



END OF PROCEDURE



ATTACHMENT 2               



Federal Regulations on Stowing On-board Articles 

 

14 CFR 121.285 Carriage of cargo in passenger compartments 



14 CFR 121.589 Carry-on baggage 



14 CFR 135.87 Carriage of cargo including carry-on baggage       



14 CFR 121.285 Carriage of cargo in passenger compartments  



121.185  Carriage of cargo in passenger compartments  



(a)Except as provided in paragraph (b) or (c) of this section, no

certificate holder may carry cargo in the passenger compartment of an

airplane. 



(b)  Cargo may be carried anywhere in the passenger compartment if it is

carried in an approved cargo bin that meets the following requirements:



(1)The bin must withstand the load factors and emergency landing

conditions applicable to the passenger seats of the airplane in which

the bin is installed, multiplied by a factor of 1.15.  using the

combined weight of the bin and the maximum weight of cargo that may be

carried in the bin. 



(2) The maximum weight of cargo that the bin is approved to carry and

any instructions necessary to insure proper weight distribution within

the bin must be conspicuously marked on the bin.



(3) The bin may not impose any load on the floor or other structure of

the airplane that exceeds the load limitations of that structure. 



(4) The bin must be attached to the seat tracks or to the floor

structure of the airplane, and its attachment must withstand the load

factors and emergency landing conditions applicable to the passenger

seats of the airplane in which the bin is installed, multiplied by

either the factor 1.15 or the seat attachment factor specified for the

airplane, whichever is greater, using the combined weight of the bin

and the maximum weight of cargo that may be carried in the bin.



(5) The bin may not be installed in a position that restricts access to

or use of any required emergency exit. or of the aisle in the passenger

compartment. 



(6)The bin must be fully enclosed and made of material that is at least

flame resistant. 



(7) Suitable safeguards must be provided within the bin to prevent the

cargo from shifting under emergency landing conditions. 



(8) the bin may not be installed in a position that obscures any

passenger's view of the "seat belt" sign "no smoking" sign, or any

required exit sign.  Unless an auxiliary sign or other approved means

for proper notification of the passenger is provided. 



(c) Cargo may be carried aft of a bulkhead or divider in any passenger

compartment provided the cargo is restrained to the load factors in

25.561(b)(3) and is loaded as follows: 



(1) It is properly secured by a safety belt or other tiedown having

enough strength to eliminate the possibility of shifting under all

normally anticipated flight and ground conditions. 



(2) It is packaged or covered in a manner to avoid possible injury to

passengers and passenger compartment occupants. 



(3) It does not impose any load on seats or the floor structure that

exceeds the load limitation for those components. 



(4) Its location does not restrict access to or use of any required

emergency or regular exit.  or of the aisle in the passenger

compartment. 



(5) Its location does not obscure any passenger's view of the "seat

belt" sign "no smoking" sign or required exit sign,  unless an

auxiliary sign or other approved means for proper notification of the

passenger is provided.  



(Secs. 313,314, and 601 through 610 Federal Aviation Act of 1958, as

amended (49 U.S.C.  1354, 1355, 1421 through 1430); sec.

6(c),Department of Transportation Act (49 U.S.C. 1655 (c))).  



[Doc. No. 6258, 29 FR 19202, Dec. 31, 1964, as amended by Amdt. 121-179,

47 FR 33390, Aug. 2, 1982] 



14 CFR 121.589 Carry-on baggage 



121.589 Carry-on baggage.  



(a)  No certificate holder may allow the boarding of carry-on baggage on

the aircraft unless the baggage can be stowed in accordance with this

section.  No certificate holder may allow an aircraft to take off or

land unless each article of baggage carried aboard the aircraft is

stowed - 



(1) In a suitable closet or baggage or cargo stowage compartment

placarded for its maximum weight and providing proper restraint for all

baggage or cargo stowed within, and in a manner that does not hinder

the possible use of any emergency equipment; or  



(2) As provided in 121.285(c): or 



(3) Under a passenger seat. 



(b) Baggage, other than articles of loose clothing, may not be placed in

an overhead rack unless that rack is equipped with approved restraining

devices or doors. 



(c) Each passenger must comply with instructions given by crewmembers

regarding compliance with paragraphs (a),(b), and (e) of this section. 



(d) Each passenger seat under which baggage is allowed to be stowed

shall be fitted with a means to prevent articles of baggage stowed

under it from sliding forward.  In addition, after August 31, 1983,

each aisle seat shall be fitted with a means to prevent articles or

baggage stowed under it from sliding sideward into the aisle under

crash impacts severe enough to induce the ultimate inertia forces

specified in the emergency landing condition regulations under which

the aircraft was type certificated. 



(e) In addition to the methods of stowage in paragraph (a) of this

section, flexible travel canes carried by blind individuals may be

stowed-  



(1)  Under any series of connected passenger seats in the same row, if

the cane does not protrude into an aisle and if the cane is flat on the

floor; or  



(2) Between a non emergency exit window seat and the fuselage, if the

cane is flat on the floor; or 



(3) Beneath any two nonemergency exit window seats, if the cane is flat

on the floor; or 



(4) In accordance with nay other method approved by the Administrator. 



[Doc. No. 17897, Amdt. 121-159, 45 Fr 41594, June 19, 1980, as amended

by Amdt. 121-174, 46 FR 38051, July 23, 1981]





.TCEL.

.