August 15, 2022

FAA Seeks Comments on Aircraft Seat Size

Holland & Knight Aviation Law Blog
Anita M. Mosner
Aviation Law Blog

The Federal Aviation Administration (FAA) on Aug. 3, 2002, issued a Request for Comments (RFC) on the possible issuance of minimum aircraft seat size requirements for passenger aircraft. The FAA issued the RFC in order to comply with the FAA Reauthorization Act of 2018, which, among other things, directed the FAA to solicit information about how such a requirement might be needed in the interest of passenger safety and might be required to ensure that an aircraft can be quickly and safely evacuated in the event of an emergency.

In the RFC,1 the FAA emphasized that its query is directed to questions of safety and the ability to ensure that a broad range of passengers, including "children, people over 60, and individuals with disabilities" can be safely evacuated from the aircraft in the event of an emergency. The FAA specifically asked for comments on how seat width, seat pitch, seat length and other seat dimensions might affect passenger safety by delaying evacuation times.

Doubtless aware of endless news stories and consumer complaints about cramped passenger aircraft cabins, the FAA emphasized that its query is not directed toward "passenger comfort and convenience." This solicitation of information from the public is in addition to simulated emergency evacuations performed by the FAA, which were summarized in a study presented to Congress earlier this year.2

Any changes to the rules, if made, would apply to operations of U.S. air carriers. Interested parties are directed to file comments with the FAA by Nov. 1, 2022.


1 Request for Comments in Minimum Seat Dimensions Necessary for Safety of Air Passengers (Emergency Evacuation, 87 Fed. Reg. 47494 (Aug. 3, 2022).

2 See, Federal Aviation Administration, Civil Aerospace Medical Institute, "Effects of Airplane Cabin Interiors on Egress I: Assessment of Anthropometrics, Seat Pitch, and Seat Width on Egress."


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