Does Each Occupant Over The Age Of Two Have To Have His Or Her Own Seat Belt?

by Greg Reigel

The FAA’s Office of the Chief Counsel was recently asked the question “whether § 91.205(b)(l3) requires that each occupant over 2 years of age have their own individual seat belt in light of the fact that § 91.107 allows the shared use of seat belts in certain situations?” The short answer, according to the Legal Interpretation issued by the Chief Counsel’s office, is “no.”

The Interpretation observed that FAR 91.107 provides the minimum standards for seat belt use in Part 91 flight and permits aircraft occupants to share seat belts in certain situations. It then noted that FAR 91.205(b)(l3) prohibits operation of a powered civil aircraft with a standard category U.S. airworthiness certificate under VFR during the day unless it has “[a]n approved safety belt with an approved metal-to-metal latching device for each occupant 2 years of age or older.”

Reading these two regulations together, the Interpretation concluded “that § 91.205(b)(13) does not mandate that each aircraft occupant have their own individual seat belt,” but rather “permits aircraft occupants to share an approved safety belt with an approved metal-to-metal latching device as long as each occupant who is sharing the safety belt is securely restrained by the approved safety belt.”

However, the Interpretation added that FAR 91.107 permits the use of a seat belt and/or seat by more than one occupant “only if the seat usage conforms to the limitations contained in the approved portion of the Airplane Flight Manual (AFM).” As a result, in order to allow this use of a seat belt or seat by more than one occupant, the Interpretation states that the pilot in command “must also check whether: (l) the seat belt is approved and rated for such use; and (2) the structural strength requirements for the seat are not exceeded,” assuming that information is available to the pilot in command.

For more information on FAA interpretation of seat belt requirements, you can also read the FAA’s May 24, 2012 “Clarification of Prior Interpretations of the Seat Belt and Seating Requirements for General Aviation Flights.”

EDITORS NOTE: Greg Reigel is an attorney with Reigel Law Firm, Ltd., a law firm located in Hopkins, Minnesota, which represents clients in aviation and business law matters (, 952-238-1060,

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