Use of Safety Belts, Shoulder Harnesses, and Child Restraint Systems

Section 91.107 governs passenger use of seat belts and shoulder harnesses. It establishes who is responsible for compliance, when restraints must be used, and what counts as an acceptable restraint for which passenger.

The PIC's two-part briefing obligation (paragraph a)(1)(i) and (ii): Before each takeoff and landing, the PIC of a U.S.-registered civil aircraft must ensure each person on board is briefed on how to fasten and unfasten their safety belt and, if installed, shoulder harness. This is a required briefing — it cannot be skipped because passengers 'seemed experienced.' For Part 91 operations the briefing can be informal but it must happen.

The 'occupy a seat' rule (paragraph a)(2): Each person on board must occupy an approved seat with safety belt fastened during movement on the surface, takeoff, and landing. The exceptions are narrow: a child under 2 may be held by an adult, and a parachutist on an intended jump may stand. Otherwise, every person needs a seat and a belt during the critical phases of flight.

Shoulder harness for passengers: If the seat is equipped with a shoulder harness, the harness must be used during takeoff and landing (paragraph a)(3)). Same rule as crewmembers — if installed, must be worn.

One belt, one occupant: Each safety belt may be used by only one person — except the lap-child exception. Two adults sharing a belt is not legal under § 91.107.

Child restraints: Children under 2 may be held by an adult during takeoff and landing (statutory exception), but the FAA strongly recommends — and the AIM emphasizes — that all children regardless of age use an approved child restraint system (CRS). An FAA-approved CRS (look for the sticker stating 'This restraint is certified for use in motor vehicles and aircraft') is the safest practice; loose lap children are statistically the highest-injury passenger category in survivable accidents.

Reference: FAA Flying With Children Guidance; AC 91-62A on child restraint systems.

The Passenger Briefing That Actually Matters — § 91.107

Many pilots read § 91.107 and conclude only that passengers must be briefed on seatbelts. That is correct, but it is only one-third of the rule. Paragraph (a) imposes three separate duties on the PIC, and they are frequently conflated into "the briefing" — a distinction examiners use as a tripwire. All three follow.

(a)(1) — Brief. Before takeoff, each person on board must be briefed on how to fasten and unfasten the safety belt and, if installed, the shoulder harness. "Briefed" does not mean "told." A briefing is a demonstration — showing how the buckle works, how the harness routes, and how to release it under load. A first-time passenger may never have operated a lift-lever buckle, so familiarity should not be assumed.

(a)(2) — Notify. Before any surface movement, takeoff, or landing, each person must be notified to fasten the safety belt and, if installed, the shoulder harness. This is the verbal callout — confirming everyone is belted in. It is separate from (a)(1). The brief happens once. The notification happens three times: before taxi, before takeoff, and before landing.

(a)(3) — Occupy and fasten. Each person on board must occupy an approved seat or berth with the safety belt fastened — and the shoulder harness fastened if one is installed. That last clause matters. If the airplane has shoulder harnesses, they are not optional during taxi, takeoff, and landing — they are required. Personal preference does not enter into it.

The (a)(3) exceptions are narrow. A child under 2 may be held by an adult provided the child does not occupy or use any restraining device. Sport parachutists may use the floor. And approved child restraint systems — meaning FAA-approved and properly labeled — may be used by a child accompanied by a parent or guardian. Booster seats, vest-type harnesses, and lap-held restraints are prohibited. The regulation names them by name.

What an Examiner Asks About § 91.107

This regulation appears at every certificate level because the briefing is something the examiner watches the applicant perform before the flight begins. Common questions include:

• "Walk me through your passenger briefing."
  A complete briefing covers safety first — belts (demonstrated, not described), emergency exits, fire extinguisher location, and the sterile-cockpit request. It then explains what the pilot will be doing during taxi, takeoff, and landing so passengers are not surprised. § 91.107(a)(1) is the floor; a thorough briefing covers more.
• "What's the difference between the (a)(1) brief and the (a)(2) notification?"
  The brief is the one-time demonstration of how to operate the belt and harness — that happens before takeoff. The notification is the callout to fasten up — that happens before every surface movement, takeoff, and landing. Two duties, two different moments.
• "If the airplane has shoulder harnesses installed, when are they required?"
  During movement on the surface, takeoff, and landing — § 91.107(a)(3). The trigger is whether the harness is installed, not whether the passenger prefers to wear one. If it is there, it must be fastened.
• "Can a child sit on a parent's lap during takeoff?"
  Under § 91.107(a)(3)(i), a child under 2 may be held by an adult in an approved seat, provided the child is not using any restraining device. The FAA strongly discourages it — loose lap children are statistically the worst-injured passengers in survivable accidents — but the rule allows it. For anyone 2 and over, the answer is no — they occupy an approved seat with the belt fastened.

A Pre-Takeoff Brief, Under § 91.107

Consider a first-time general-aviation passenger climbing into the right seat of a Cessna 172, unfamiliar with the panel and the equipment. § 91.107 is the floor; the following describes what a competent briefing looks like.

Begin with the belt. Rather than simply saying "buckle up," the pilot should point out the lift-lever buckle, open and close it as a demonstration, then hand it to the passenger. Show the shoulder harness routing — over the shoulder, not under the arm. Have the passenger fasten and unfasten it once under observation. That is (a)(1) done properly.

Next comes the safety brief that the regulation does not require but that a thorough pilot covers anyway: door operation — where the handle is, how it opens, how to brace it open after a forced landing; fire extinguisher location; emergency exits if the aircraft has more than one; where the survival kit is stored; and ELT location. For flight over remote terrain, this list grows longer, not shorter.

Then the sterile-cockpit request: "From the moment the engine starts until cruise altitude, please hold any non-emergency conversation. If you see traffic, smell smoke, or feel something wrong, speak up immediately. Otherwise, let me work." The same applies again before landing.

Before advancing the throttle for taxi, the pilot confirms "belted in?" — that is (a)(2). It is repeated again at the hold-short line, and again on downwind. Three notifications, one briefing, every flight. The regulation is the floor. The competent briefing is what keeps a nervous first-time passenger from becoming a statistic.