Why regulations and guidance matter.
US air travel regulations and guidance concerning airport and airline responsibilities towards, protocols for, and rights of air travelers with hidden disabilities are deficient.
EU and UK regulations and guidance are directly supportive or air travelers with hidden disabilities. In the UK, this is partly due to the difference in the healthcare system.
DFAWG is working towards adoption of protocols that emulate UK regulations and guidance, without requiring legislative changes in the US. This is pragmatic, because we do not foresee significant legislative changes as possible.
To identify and understand clear targets for supportive US protocols, it is important to become familiar with appropriate regulations and guidance. This section aims to assist readers in acquiring that familiarity.
Be aware that regulations and guidance changes. It is necessary to identify the latest version of any particular document. This includes paying attention to when something will be implemented, as in the new Canadian Transportation Authority regulations.
If you are aware of additional regulations and guidance, or updates that should be identified in this section, please send details to [email protected] subject: regulations.
Included below:
“… Regulation EC1107/20061 (the Regulation) concerning the rights of disabled persons and persons with reduced mobility when travelling by air is to ensure that disabled people have the same opportunities for air travel as non-disabled people, in particular that they have the same rights to free movement, freedom of choice and non-discrimination. A disabled person and person with reduced mobility is defined in the Regulation as “any person whose mobility when using air transport is reduced due to any physical disability (sensory or locomotor, permanent or temporary), intellectual disability or impairment, or any other cause of disability, or age”. It is the CAA’s view, based on engagement with disability organisations, that ‘hidden disabilities’ should be considered to include, but not be limited to, dementia, autism, learning disabilities, anxiety issues, mental health conditions, visual impairments and hearing loss.”
The UK Civil Aviation Authority (CAA), European Commission, and European Civil Aviation Conference (ECAC) guidance documents clarify the requirements of the Regulation in relation to providing assistance to people with hidden disabilities, setting appropriate quality standards for this assistance, and providing information to this group of passengers.
EU Regulation (EC) 1107/2006 places responsibility for delivery of services and facilities to persons with disabilities and PRMs on the airport (except for on board services and facilities).
US Air Carrier Access Act Regulation (14 CFR Part 382) places this responsibility on the airlines.
CAA policies for providing air travel assistance to people with hidden disabilities, setting appropriate quality standards for this assistance, and providing information to this group of passengers far exceeds any US policies or practices.
Policies that are immediately applicable to the needs of US air travelers with dementia (hidden disabilities), focusing on changes of practical benefit, which may need legislative changes for implementation in the US include:
Regulations and Guidance for Hidden Disabilities Air Travel
United States
United Kingdom / Civil Aviation Authority
European Union
Canada
International Air Transport Association (IATA)
EU and UK regulations and guidance are directly supportive or air travelers with hidden disabilities. In the UK, this is partly due to the difference in the healthcare system.
DFAWG is working towards adoption of protocols that emulate UK regulations and guidance, without requiring legislative changes in the US. This is pragmatic, because we do not foresee significant legislative changes as possible.
To identify and understand clear targets for supportive US protocols, it is important to become familiar with appropriate regulations and guidance. This section aims to assist readers in acquiring that familiarity.
Be aware that regulations and guidance changes. It is necessary to identify the latest version of any particular document. This includes paying attention to when something will be implemented, as in the new Canadian Transportation Authority regulations.
If you are aware of additional regulations and guidance, or updates that should be identified in this section, please send details to [email protected] subject: regulations.
Included below:
- Short summary of relevant EU, UK, and US air travel regulation and guidelines.
- Policies that are immediately applicable to the needs of US air travelers with dementia (hidden disabilities), focusing on changes of practical benefit, which may need legislative changes for implementation in the US.
- References: relevant regulations and guidelines – EU, UK, US.
“… Regulation EC1107/20061 (the Regulation) concerning the rights of disabled persons and persons with reduced mobility when travelling by air is to ensure that disabled people have the same opportunities for air travel as non-disabled people, in particular that they have the same rights to free movement, freedom of choice and non-discrimination. A disabled person and person with reduced mobility is defined in the Regulation as “any person whose mobility when using air transport is reduced due to any physical disability (sensory or locomotor, permanent or temporary), intellectual disability or impairment, or any other cause of disability, or age”. It is the CAA’s view, based on engagement with disability organisations, that ‘hidden disabilities’ should be considered to include, but not be limited to, dementia, autism, learning disabilities, anxiety issues, mental health conditions, visual impairments and hearing loss.”
The UK Civil Aviation Authority (CAA), European Commission, and European Civil Aviation Conference (ECAC) guidance documents clarify the requirements of the Regulation in relation to providing assistance to people with hidden disabilities, setting appropriate quality standards for this assistance, and providing information to this group of passengers.
EU Regulation (EC) 1107/2006 places responsibility for delivery of services and facilities to persons with disabilities and PRMs on the airport (except for on board services and facilities).
US Air Carrier Access Act Regulation (14 CFR Part 382) places this responsibility on the airlines.
CAA policies for providing air travel assistance to people with hidden disabilities, setting appropriate quality standards for this assistance, and providing information to this group of passengers far exceeds any US policies or practices.
Policies that are immediately applicable to the needs of US air travelers with dementia (hidden disabilities), focusing on changes of practical benefit, which may need legislative changes for implementation in the US include:
- disability awareness training packages (including dementia (hidden disability) awareness) for key customer facing staff including those at security search areas as well as those who provide direct assistance to disabled people, established/enhanced in conjunction with disability and advocacy organizations
- implementation of policies that never separate persons with hidden disabilities from accompanying persons when receiving the necessary airport assistance under Annex I of the Regulation e.g. during a security search.”
- changes to security screening to accommodate people with dementia (hidden disabilities)
- never separate persons with hidden disabilities from accompanying persons during security screening
- airport designation of special security lanes accessible to people with hidden disabilities, such as “family or assistance lanes” or “fast track” lanes for disabled passengers, also ensuring access to a less pressurized security screening
- Implementation of mechanisms for people with hidden disabilities to discretely self-identify themselves to airport staff, including security staff
- Introduction of “optional lanyards or wristbands (or similar discrete identifiers), which are available to be worn by people who may not need one-to-one assistance for the whole passenger journey, but who would like to be able to more easily identify themselves to staff so that they can get extra help at the more stressful touchpoints of the passenger journey, such as security search.”
- where possible, modification of airport environment re needs of people with disabilities and reduced mobility, e.g. during design of new airports, terminals and major refurbishments
- establishment of “quiet areas” throughout the terminals
- establishment of “a ‘quiet route’ through the airport, for example bypassing the retail area, which can be used by those with sensory impairments or sensory processing issues, for whom the terminal environment can be disorienting and stressful.”
- improved signage and wayfinding
- regular on-site accessibility audits; airports to provide training records and other documentary evidence of regulatory compliance
- implementation of formal accreditation schemes through disability organizations
Regulations and Guidance for Hidden Disabilities Air Travel
United States
United Kingdom / Civil Aviation Authority
European Union
Canada
International Air Transport Association (IATA)
