Mobility Aids and Air Travel Final Report

Prepared for:

Centre of Expertise for Accessible Transportation
Canadian Transportation Agency

Prepared by:

Dr. K.M. Hunter-Zaworski, P.E. (OR)

May 29, 2019

Executive summary

Summary Background

The Canadian Transportation Agency (CTA) is Canada's longest-standing independent, expert tribunal and regulator. One of its core mandates is to ensure that transportation services are accessible to persons with disabilities. As part of its Regulatory Modernization Initiative, the CTA consulted extensively with persons with disabilities and industry, including members of its Accessibility Advisory Committee, as well as the general public, on which regulatory measures can help make the federal transportation network more accessible for persons with disabilities. In the course of consultations related to this initiative, issues related to the storage and transportation of mobility aids on aircraft were identified as needing further examination as mobility devices have grown in size and complexity. As a result, the Agency launched an initiative that included the formation of an international working group (IWG) to develop recommendations for possible future action related to these issues. As the launch to this initiative, the CTA hosted an international forum in Toronto on June 12-13, 2018 to discuss the transport and stowage of mobility aids on aircraft with IWG members including airlines and their trade associations, aircraft manufacturers, mobility aid manufacturers, disability rights organizations, regulators, ground handlers and other interested stakeholders. The Forum served as a catalyst for follow up dialogue and innovation by the IWG members in the months that followed.

The safe transport of mobility aids is particularly acute on single aisle passenger aircraft because of the inability to safely load and transport many large mobility aids in the cargo compartments of some of these aircraft. Given Canada’s large size, small population, weather, and remote airport operations, single aisle aircraft form a significant part of Canada’s scheduled air services. The incompatibility between many mobility aids and passenger aircraft, specifically in terms of weight, width and height is a crucial issue identified by many of the IWG stakeholders and can result in damage to mobility aids during transport. The design of some of the mobility aids and some of the aircraft cargo compartments are incompatible.

Many of the aircraft were designed decades ago. The life cycle of aircraft is multiple decades and modifications to the existing fuselage to increase cargo door size is not realistic.  In addition, most mobility aids are not designed for air travel, and as a result, they cannot be easily modified to fit through the aircraft cargo compartment door and are often difficult to secure in the cargo compartment. There is a need to encourage the mobility aid industry to develop more mobility aids that can be transported by air and where appropriate, encourage rehabilitation professionals to prescribe these mobility aids.

Overview of Recommendations

The recommendations and actions from the IWG summarize the key issues of discussion. The IWG had many areas of common agreement and identified issues that require additional discussion and research. The areas of agreement are: the mobility aid passport, mobility aid handling checklist, communication, and training.

Mobility Aid Passport: The development of the Mobility Aid Passport that contains technical information on the mobility aid such as the dimensions and any special instructions for safe handling. The format and content of the Mobility Aid Passport should be determined by representatives of the stakeholder groups that include people with disabilities, mobility aid industry that includes representatives of the durable equipment industry or after market industry, the airline industry, ICAO, and IATA.^{Footnote 1}   ICAO and/or IATA need to be engaged so that it is standardized across the industry. There is consensus agreement among members of the IWG for electronic and hard copy passports for mobility aids, however, additional discussion is needed by all the stakeholders on the specific content of a passport that can be adopted across the aviation and mobility aid industries.  Ramp personnel, who may or may not be carrier staff and are key users of the passport, should be included in all the discussions on the key information and the format of the hard copy passport.

Creation of a Standard Mobility Aid Handling Checklist: The IWG discussed the need for a standardised checklist to identify the required steps in the proper handling of mobility aids at the origin and destination airport. It was recommended that this Mobility Aid Handling Checklist be used globally, standardized, simple, and use pictograms wherever possible. IATA offered to take leadership in developing the standard mobility aid handling checklist and then disseminating it to member airlines.

Communication: Improved communication at reservation, pre-trip and day of travel between passengers, airlines and airport ramp operations on the needs of the passenger with disabilities and the handling of their mobility aids was a key issue identified by many members of the IWG. The IWG agreed that more communication materials are needed in multiple formats and to multiple stakeholder groups.

Training: The IWG identified the need for the development of additional training materials for reservation agents, airlines and airport staff including ground handlers, on providing appropriate assistance to passengers with disabilities and the information contained in the Mobility Aid Passport and Mobility Aid Handling Checklist.  The training must include trainers with disabilities.

Other issues raised during the IWG deliberations that require additional discussion and development include issues related to the cargo compartment, ramp equipment, functional guidelines for securement and containment, and transportable mobility aid design. 

Cargo Compartment Design: There are no plans for aircraft manufacturers to change the size of the cargo compartment doors on existing certified aircraft.  However, with the work done by the IWG, the manufacturers are more aware of design changes that could be incorporated in new types of single aisle aircraft to accommodate larger mobility aids.

Ramp Equipment: Ramp equipment is expensive and has a long service life.  It is recommended that a feasibility study be conducted and include an economic evaluation, and consider the options for lifts and other devices to board heavy mobility aids from the tarmac to the belt loader or directly into the cargo compartment of the aircraft. This study could also include consideration of the European practice of using a special vehicle that assists with boarding of passengers with disabilities and the safe movement of the mobility aids into the aircraft

Functional Guidelines for Securement/Containment: Most members of the IWG recommend the development of new functional guidelines and/or performance standards for the securement and/or containment of mobility aids in the cargo compartment. Most of the members of the IWG were very supportive of developing these guidelines for the airline industry, however, the IWG has incomplete representation of the stakeholders impacted by this recommendation.

Transportable mobility aid design:  The population is very diverse and as a result so are mobility aids, and therefore it is difficult to develop standard maximum design envelopes (height, width, length, weight) of mobility aids.  More informed travel decisions can be made by increasing the awareness both of the airline industry and passengers of the constraints imposed by aircraft design and airport operations. Mobility aid innovation and redesign for air travel does not prevent customization (most commonly controls such as joysticks) and seating systems. It is recommended that ICAO, IATA and governments around the world encourage further development and marketing of air transport friendly mobility aids that meet the needs for people with reduced mobility. Governments should also facilitate additional research or greater access to travel-friendly mobility aids by providing research funding or subsidies to companies and/or mobility aid users.

Introduction

The Canadian Transportation Agency (CTA) is Canada's longest-standing independent, expert tribunal and regulator. One of its core mandates is to ensure that transportation services are accessible to persons with disabilities.  On May 26, 2016, the Canadian Transportation Agency (CTA) launched a Regulatory Modernization Initiative (RMI) to review and modernize the full suite of regulations it administers, including all accessibility regulations and related voluntary measures.

The CTA consulted extensively with persons with disabilities and industry, including members of its Accessibility Advisory Committee, as well as the general public, on which regulatory measures can help make the federal transportation network more accessible for persons with disabilities. In the course of consultations and analysis related to this initiative, it became clear that issues related to the storage and transportation of mobility aids on aircraft have become more serious as mobility devices grow in size, weight and complexity.

The safe transport of mobility aids is particularly acute for transport in single aisle passenger aircraft because of the inability to safely load and transport some of the large mobility aids in the cargo compartments of some of these aircraft. Given Canada’s large size and small population, single aisle aircraft form a significant part of Canada’s scheduled air services. The result is that people who use larger mobility aids:

• may be required to take more than one flight when a direct route is only serviced by a single aisle aircraft with smaller cargo doors;
• may need to fly from a different, less convenient airport; or
• may not be able to travel at all with their mobility aid, requiring them to make arrangements for the use of another mobility aid at their destination, which may not be feasible depending on how highly customized their mobility aid is.

In addition, there is a lack of communication between airline staff and passengers.  Often many mobility aids are damaged during transport. The incompatibility between many mobility aids and passenger aircraft, specifically in terms of weight, width and height is a crucial issue that was identified by many of the international working group stakeholders.

The design of many mobility aids and the design of some of the aircraft cargo compartments are incompatible. Many of these mobility aids are not designed for air travel and they cannot be configured to fit through the aircraft cargo compartment door and are difficult to secure in the cargo compartment.  The life cycle of aircraft is multiple decades, and modifications to the fuselage to increase cargo door size cannot be done.  There is a need to encourage the mobility aid industry to develop more devices that can be transported by air and also to encourage rehabilitation professionals to prescribe mobility aids that can be transported by air as well as other modes of public transportation. 

The CTA hosted an international forum in Toronto on June 12-13, 2018 (Forum) to discuss the issues related to the transport and stowage of mobility aids on aircraft. The Forum served as a catalyst for that dialogue and innovation. Participants in the Forum included airlines and their trade associations, aircraft and original equipment manufacturers, mobility aid manufacturers, disability rights organizations, regulators, ground handlers and other interested stakeholders.

The Forum had two parts. On the afternoon of June 12, senior leaders laid out their vision for issues related to mobility aids and air travel. The following day, members of the international working group convened by the CTA discussed practical ways of translating the vision into reality.  Following the Forum there were webinars and discussions of technical issues within sub-groups. The results of all these interactions are presented in the report.

Objective

The objective of the initiative was to convene an international working group (the International Working Group or IWG) to develop recommendations for the CTA for possible future action with respect to issues related to the transportation of large mobility aids on smaller aircraft including recommendations for aircraft manufacturers, ground handlers, airlines, airports and mobility aid manufacturers.

Background

The IWG explored the challenges of transporting large wheeled mobility aids on single aisle passenger aircraft. They considered many different aspects of the transport process and formulated recommendations and ideas for further consideration that address many of the challenges. Most of the members of the IWG have been aware of these challenges for years. A result of the deliberations is an increased awareness by members of the IWG of the many challenges faced by people who travel with mobility aids on single aisle aircraft and the overall impacts on the passenger aviation industry,  particularly ground handlers, the community of persons with disabilities and mobility aid manufacturers.

The project activities included: 

• Convening an IWG made up of mobility aid and aircraft and original equipment manufacturers, airlines, international organizations (such as aviation organizations), ramp personnel, and disability groups representing persons with mobility disabilities to explore this issue;
• Planning and facilitating a forum of the IWG;
• Planning and facilitating meetings of the IWG by web conferencing; and,
• Preparing project documentation including a final report that discusses the issues of transporting large mobility aids on single aisle aircraft, and recommends possible solutions and best practices for the passenger aviation industry, the community of persons with disabilities, and mobility aid manufacturers.

Formation of International Working Group (IWG)

The first task of the project included the formation of the IWG to develop recommendations for the safe transport of large wheeled mobility aids on single aisle aircraft.  The safe transport of large mobility aids on single aisle aircraft impacts many stakeholders, and it was important to have representation from all the impacted groups. Also, since air travel is international, the IWG included members from North America and Europe.

The IWG included representatives from Canadian and US advocacy associations, Canadian and US airlines, Canadian and US airline organizations, Canadian ground support providers, members from the International Civil Aviation Organization (ICAO) and the International Air Transport Association (IATA) and US DOT, and two manufacturers of wheeled mobility aids and a mobility aid rental organization.  Annex 1 contains a list of organizations represented on the IWG membership.

Working Group Meetings

Mobility aids and air travel forum

A one-and-a-half-day forum with members of the IWG was hosted by the CTA in Toronto on June 12-13, 2018.  The face to face meeting provided a venue for the IWG members to discuss the challenges associated with the safe transport of mobility aids on single aisle aircraft. The Forum provided an opportunity for representatives of Canadian and US advocacy associations to share their personal experiences of transporting mobility aids with members from the airline community, and  for the airline community to provide their feedback on the safety challenges associated with the loading of heavy mobility aids in smaller aircrafts. 

Key Points from the June 12-13, 2018 Forum

The key points listed below summarize the items of discussion at the Forum and do not indicate agreement or disagreement by members of the IWG. The discussion points indicate the diversity of technical and operational content.  Many of the key points were clarified and some eliminated during the follow up discussions and webinars. The key points are organized by organization and followed by the themes.

Advocates for people with disabilities

IWG members who represent people with disabilities asked for the following:

• Airlines commit to applying the same level of due diligence to transport of wheeled mobility aids as they do to safety and security;
• Carriers commit to immediately repair damage or if necessary replacement of mobility aid, as feasible and as per international conventions requirements;
• Burden of complaint resolution should be with airline not passenger;
• Public reporting of damage to mobility aids; and  
• A very long-term intention is that newly designed and certified aircraft accommodate larger mobility aids.

Aircraft and original equipment manufacturers

Publication of key information for cargo compartment specifications in very simple terms. More information in addition to clear door open dimensions: 

• Maximum concentrated weight for cargo area;
• Maximum size and weight limitations for stowage areas by aircraft type;
• Maximum total weight acceptable for weight balance guidelines for flight and ramp personnel;
• Information on typical belt loaders and aircraft doors;
• Specifications for containment and securement equipment (recommendations for airlines when procuring aircraft);
• Tie down equipment;
• Use of cargo nets;
• Use of containment or securement aids; and
• Cargo management systems to reduce damage to aircraft as well as damage to mobility aid.

Other issues that relate to the aircraft include:

• Impact of Internet of things (IoT) and communication equipment that is part of the mobility aid that may impact aircraft systems. IoT refers to everyday items which are embedded with electronics and connected to the Internet.  

Airlines and industry associations

• The Mobility Aid Passport issued by the mobility aid manufacturers and after-market equipment providers, who are the best placed to provide the information in standard form;
• The standard for the Mobility Aid Handling Checklist that will be developed by ICAO and/or IATA and implemented throughout by the industry;
• Both the Mobility Aid Passport and the Mobility Aid Handling Checklist are essential tools for airlines;
• Direct communication with the passenger at all passenger touchpoints from reservation through day of travel is important; and 
• Internal communication with different airline staff who are involved with handling of mobility aids at all touchpoints during journey is important.

Canadian airline special operating environments

Canada has unique geographic, and climate characteristics that impact all passenger air travel and in particular passengers with disabilities. The airport characteristics of remote or unimproved airports can complicate the challenges of safe handling and stowage of mobility aids.

• Unimproved airports are airports that may have gravel, snow or limited pavement on the runways, limited or no runway lighting and limited passenger airport terminal buildings and ramp areas with handling capabilities; and
• They face severe climates (impacts on mobility aids of high and low temperatures and humidity).

Mobility aid manufacturers

• Work with international air transport organizations, governments and associations who represent the mobility aid manufacturers and rehabilitation professionals to emphasize the need for the mobility aid industry and distributors to design and market mobility aids that are transportable and meet the needs of travelers with reduced mobility. Coordinate with international air transport associations and disability organizations in the development of transportable mobility aids;
• Develop guidelines for power sources used on powered wheeled mobility aids that are appropriate for air transport;
• Develop format, content, and standard instructions of the Mobility Aid Passport to be issued by mobility aid manufacturers, rehabilitation professionals and/or after-market suppliers;
• Develop parameters for maximum weight, height and width for modular components of transportable wheeled mobility aids that reflect any after-market modifications;
• Develop standardized QR code for downloading standardized placard^{Footnote 2} , and
• Investigate possibility of discreet labelling on mobility aids designed for air travel, such as for batteries, disassembly, lifting points.  However, the passengers’ wishes of preserving the aesthetic of their mobility aids must be considered.

The general thematic areas that were discussed included; Mobility Aid Passport and Mobility Aid Handling Checklist, safety, communication, training, special operating environments, innovations and opportunities, and standardization.

Mobility aid passport and mobility aid handling checklist

• Suggest a generic type of placard to be used by all airlines (IATA) “Mobility Aid Passport”; this could be a digital solution that connects the mobility aid to the passenger once the booking is released.
• The Mobility Aid Passport should contain essential information only and mobility aid manufacturers and/or after market suppliers may provide a QR or similar download with appropriate information for passenger to share with Airlines.
• The Mobility Aid Handling Checklist would be a standard check list of actions that the sending station checks off to communicate what was done to the receiving station (e.g. disconnecting the battery or removing the headrest). The receiving station then undoes those same actions, ensuring that the mobility aid is handled properly.

Communication

Pre-trip, more and easier to find information for passengers

• Information on type of mobility aid, weight, dimensions, battery type, special information (Controller, Internet of things (IoT) devices, seating systems, other specialized equipment such as recline mechanisms etc.) should be easily available to carriers to make a determination on how to load the mobility aids;
• Information for passengers must be easy to find (one click from landing page on website); and
• Mobility Aid Passport and Handling Checklist need to be physically attached to the mobility aid so that they are consulted and followed by ramp handlers.

Training

The IWG discussed that training should include the following organizations: Rehabilitation Engineering and Assistive Technology Society of North America (RESNA), IATA, Airlines for America (A4A), National Airlines Council of Canada (NACC) and Northern Air Transportation Association (NATA).  

• Specific initial and recommended recurrent training of all personnel that interact with passengers and/or load mobility aids. Trainers should include people with disabilities;
• It has been suggested that CTA develop simple, clear training materials in collaboration with airlines and mobility aid manufacturers;
• Training format should be appropriate for audience;
• Visual and hands on learning;
• Instructions on lifting technologies for heavy mobility aids;
• Instructions from mobility aid manufacturers shown on Mobility Aid Passport on recommended lifting points for wheeled mobility device; and
• Recommend using mechanical lifts where feasible.

Safety

Create a safety culture for passengers, and airport and airline personnel.  Airlines confirmed that safety is number one priority for the airline industry.

Innovations/opportunities

• Encourage procurement and distribution of easy to use mechanical lifts for ramp personnel that will span the height from the tarmac to the aircraft door; and
• Economic justification is prevention of work loss injuries.

The location of wheelchair repair facilities at major hub airports was mentioned at the Forum, but in subsequent discussions was deemed to be impractical by other members of the IWG.  There were suggestions that contingency plans for mishandled mobility aids need to be in place, but these are better sourced in the community and not the airport.

Standardization

Use existing industry and professional groups to establish working groups to develop industry wide best practices or standards:

RESNA

• Work with A4A,  NACC and other industry associations to help with the development of standardized Mobility Aid Passport, try to engage more wheeled mobility aid manufacturers.
• Standardized Mobility Aid Passport: minimum information (overall dimensions, Length, Weight, and Height and battery type, “freewheeling instructions”, for motorized mobility aids, clear instructions (Pictorial not written) on disassembly and reassembly, Special instructions on protection of controllers and also putting all communication systems in non-transmit mode. 

IATA

• Work with air transport, mobility aid industries and travelers with disabilities to develop the standardized content for the Mobility Aid Passport to be issued by mobility aid manufacturers, rehabilitation professionals and after-market equipment provider;
• Encourage collaboration between mobility aid manufacturers to design mobility aids that are convenient for air travel as well as educating customers regarding mobility aids that are suitable for air travel;
• Develop communication materials for the general public based on the ICAO Dangerous Goods Panel (DGP) standards for acceptable power sources for mobility aids that are transported by aircraft;
• Develop a standardized format and content of the Mobility Aid Handling Checklist that will follow the mobility aid from beginning to end of the journey, identifying assembly/disassembly action to be taken and allowing the steps taken to be reversed; and
• Develop training materials for ramp handlers and front-line personnel on handling of the unoccupied mobility aids from the boarding gate to the aircraft cargo compartment until the mobility aid is reunited with the passenger.

Other topics discussed and clarified

There were several other topics discussed at the Forum or in subsequent IWG meetings that required clarification or were agreed as beyond the scope of the IWG. These topics include; third party ticketing and reservations, the development of an application, and airport design.

Third party ticketing and reservations

Further clarification by members of the IWG on third party ticketing and reservations has indicated that the business models of third-party ticketing and reservations make the sharing of passenger information very difficult. There is agreement that passengers with disabilities or their representatives must be strongly encouraged to communicate directly with the airlines from the time that the reservation is made and throughout the journey.

App development and data privacy

There have been suggestions that an Application (APP), or program be developed that links the passenger identification with the Mobility Aid Passport. However, any APP or program must be protected and adhere to data privacy issues and global data privacy regulations.  The passenger would be responsible for sharing the Mobility Aid Passport.  Data privacy issues of the App were agreed as a topic that was beyond the scope of the project.

Airports

Airport design is beyond the scope of the IWG but there are issues that were discussed at the Forum that provide additional background to the challenge of accommodating mobility aids.

There were discussions on the challenges of some airport designs in the movement of mobility aids from the boarding lounge or boarding bridge down to the tarmac.  Elevators near or on boarding bridges are one solution to this problem. However, airlines do not have control over airport infrastructure in Canada and airport authorities are not responsible for handling mobility aids.

Any new requirements for rails on both sides of the belt loaders may increase the challenge of loading large wheeled mobility aids into the cargo compartment.  At the Forum, tarmac based lifting aids for heavy mobility aids and baggage that are designed for single aisle aircraft were shown. There are suggestions for a feasibility study to be conducted into future procurements of ramp equipment or lifting equipment based at the ramp for handling larger mobility aids. The feasibility study needs to involve airports, ground handlers and airline representatives.  The feasibility study would require research and development steps and also include inventory of appropriate technologies and a cost/benefit analysis of deployment. 

Webinars

Summary materials were prepared following the Forum for the IWG members to discuss.  In addition to the summary notes from the Forum, a list of questions (Follow up Questionnaire) was prepared and sent to all members of the IWG on July 11, 2018. The responses to these questions were shared with the IWG prior to the two webinars on September 11 and 14, 2018. A power point presentation was used to structure the discussion which included responses to the Follow up Questionnaire. Not all the questions received responses.  Additional clarification and responses were received and were shared with the IWG members. Some of the items listed below were removed from further discussion after the September webinars.  This includes airport-based wheelchair repair facilities, and clarification that there will be new belt loader regulations for the use of two side rails and this will further decrease the available width of the belt loader.   

Below is a summary of the Questionnaire

CTA Forum Phase 1 Follow up Questionnaire

The response to this request for additional information will be compiled and used for discussion on a web conference call

1. Follow up with Airlines – Approach IATA or Airlines for America(A4A) for leadership in developing

1. Information on mobility aid that passenger should provide for Special Service Requests (SSR) and Placard
2. Standard Placard to be used by all airlines
   1. Discussion if this is an appropriate approach? Please provide discussion points that are pro and con
    
3. What is the minimum standardized passenger information that should be requested?
   1. For SSR
   2. For Passport
4. Guidelines on power sources for mobility aid that are acceptable for transport on aircraft
   1. What information can be provided to the public that is clear and unambiguous?
5. Should 3rd party vendors (Expedia, etc.) be required to provide passenger information for passengers who travel with mobility aid to carriers?
6. Basic Training standards on accepting and handling mobility aid for ramp and front line personnel
   1. What is the basic content that must be included? Who is responsible for this?

Follow-up with Airports and Ground Operators and ICAO for more information:

1. New belt loading standards please provide standards organization and reference numbers
2. Guidelines for using mechanical lifts for mobility aid to belt loaders or aircraft
   1. What is the weight of mobility aid when only mechanical devices should be used?
   2. What are the key specifications for these devices?
3. Guidelines for airport based mobility aid repair
   1. What is base number of enplanements to trigger an airport based Mobility aid facility?
4. Guidelines for ground time operations
   1. What is maximum time on departure between relinquishing mobility aid to stowage
   2. What is maximum time on arrival between docking at gate to reuniting Mobility aid with passenger

Follow up with Aircraft Manufacturers: (Airbus, Boeing, Embraer and Bombardier)

1. Development of key parameters or framework
   1. Establish base standards for aircraft cargo door opening suggest that the B737 is the most critical design aircraft
      1. Width, height (clear space)
2. Establish maximum acceptable concentrated weight for cargo area by aircraft type
   1. Ask each aircraft manufacturer to supply maximum size and weight of Mobility aid for stowage areas
3. Provide information on belt loader or lift device requirements
4. Identify any internet of things (Iot) or communication systems based on the Mobility aid that may impact A/C systems
5. Provide any information that is available to airlines on cargo management systems
   1. Securement (tie down points)
   2. Cargo nets etc.

General Questions for all:

1. Should guidelines be developed that recommend the following:
   1. Maximum size of Mobility aid that can be safely transported on single aisle passenger aircraft?
   2. Battery technologies that can be safely transported on single aisle passenger aircraft?
   3. Standard Placard for all airlines?
   4. Requirements for securement or containment in cargo hold?

At the two webinars, Air Canada was invited to present on their submissions made on August 2, 2018 in response to the CTA Forum Phase 1 Questionnaire. Air Canada did not respond directly to the questions asked but suggested the following five main points:

1. The need to inform and manage passenger expectations;
2. The need for clear and standardized communication in the multi-actor process required to transport mobility aids on aircraft;
3. The content and format of the information included in the Mobility Aid Passport, and the Handling Checklist;
4. The multiple methods of communication required;
5. The need for advance notice.

The outcome of the webinars was a summary document that was distributed to members of the IWG and this document also provoked further clarification by specialist group discussions.

Related Activities

In addition to this Canadian project, there are two aviation industry committees that are also discussing particular aspects of the challenge of transporting large mobility aids on aircraft (i) RESNA Assistive Technology for Air Travel (ATAT) committee that is focused on advocacy concerns and training of ramp personnel, and (ii) an IATA group that is addressing the dangerous goods issues related to the transportation of batteries such as those used on powered mobility aids. Several members of the IWG are also members of the other committees which provides two-way liaison and opportunities for leveraging expertise. 

RESNA committee

At the Forum, some of the IWG members identified a parallel effort in the US by the RESNA. RESNA has formed the Assistive Technology for Air Travel (ATAT) committee that is addressing similar issues related to the safe accommodation of mobility aids on aircraft.  There has been continued dialogue between members of the IWG who also serve on the RESNA ATAT committee. After meeting with RESNA liaison members in early November 2018, it has been determined that the RESNA ATAT committee is not addressing the same issues identified by the IWG and it is not expected to complete its work until 2019. 

IATA

In late 2018, IATA published “Battery Powered Wheelchair and Mobility Aid Guidance Document.”  This material provides a technical background on safety requirement applicable to the carriage of battery powered wheelchair and mobility aids carried by passengers traveling by air. The requirements are detailed in the IATA Dangerous Goods Regulations, which are based on the ICAO Technical Instructions.

Additional Research

International supporting documents

UK Civil Aviation Authority (CAA) Safety Notice Number SN-2012/003, “Safety requirements Applicable to the Carriage of Electric Mobility Aids”^{Footnote 3}

In 2008 an incident occurred at a British Airport where a powered wheeled mobility aid burst into flames after it was removed from the aircraft and placed on the belt loader. This incident and others prompted the UK Civil Aviation Authority (CAA) to issue a Safety Notice Number SN-2012/003, “Safety requirements Applicable to the Carriage of Electric Mobility Aids”. The Safety Notice is based on the same ICAO document referenced in this document as well as relevant European PRM regulations [EC No.1107/2006]^{Footnote 4}. The CAA is concerned with most of the same issues that have been discussed by the IWG such as the need for good communication and the need to consider floor contact load limitations that may be compromised by heavy powered mobility aids.

The Appendix A of the Safety Notice covers in detail many of the issues discussed by the IWG and the Safety Notice and Appendix A are referenced in this report.

In support of the UK Regulations from the Civil Aviation Authority, the “Access to Air Travel for Disabled Persons and Persons with Reduced Mobility Regulations 2007,” came into force in July 2007 and are enforced by the Civil Aviation Authority (CAA). Supporting documents were prepared to ensure that people providing assistance were not exposed to increased risk of injury.  In addition, a training video was prepared for all airport and airline staff that demonstrates all the key provisions in the Safety Notice, One Team One Goal.

A flow chart of the Procedure for the Carriage of “electric mobility aids” is included^{Footnote 5}.

ISO 15845:2014 Aircraft Ground Equipment- Boarding Vehicle for Persons with Reduced Mobility-Functional and Safety Requirements.   ^{Footnote 6}

ISO 15845:2014 specifies the minimum functional and safety requirements for enclosed self-propelled boarding vehicles designed for transporting and boarding/de-boarding persons with reduced mobility onto/from the main deck or upper deck of main line civil transport aircraft on which they are travelling as a passenger.  The intent of ISO 15845:2014 is not to specify equipment design, but rather to define minimum functional and safety requirements and highlight those criteria which are known to be essential to an efficient and safe operation on civil transport aircraft in the environment of international airports. ISO 15845:2014 specifies the worldwide requirements recognized by aircraft and vehicle manufacturers as well as airlines and airport authorities. In addition, it shall be applied with due reference to the national governmental regulations of the country where the vehicle is to be operated.

Results of working group meetings and discussions:

The IWG had many areas of common agreement and identified issues that require additional discussion and research.

The areas of agreement are:

1. Development of a Mobility Aid Passport
2. Creation of a Standard Handling Checklist
3. Improved Communication and
4. Development of training materials for ramp handlers and airport front line staff.

Mobility Aid Passport

The IWG discussed the need for a “passport” for the mobility aid that contains technical information on the mobility aid such as the dimensions and any special instructions for safe handling. There is need for further discussion on who should have “ownership” of the passport.  Some members of the IWG have suggested that the mobility aid manufacturers should be responsible for the passport. However, there needs to be recognition that many mobility aids have “after-market” modifications that need to be reflected in the passport. The recommendation for ownership of the Mobility Aid Passport is expanded to include rehabilitation professionals and the after-market vendors. The mobility aid original equipment manufacturers are referred to as the MA-OEM.

Another suggestion is for the MA OEM to include a picture of the mobility aid as it leaves their facility, but even that will be a rudimentary depiction of the device. The Mobility Aid Passport could have empty pages for the rehabilitation professional or after-market vendors to document the changes to the mobility aid, but the modifier/provider has to be knowledgeable on the characteristics that are important to the airline for transporting the mobility aid.

The idea of a Mobility Aid Passport is not new to the mobility aid industry. Public Transportation providers throughout Great Britain and other regions such Hong Kong have adopted, “The Code of Practice for Wheelchair Passport Schemes (BS 8603:2013).”  Due to the success the 2010 Code of Practice for the Wheelchair Passport Scheme, a full British Standard was published in 2013. The British Standard also includes a discussion on risk management for public transportation providers, which was part of the motivation for the development of the standard in the first place. For air transport, the Passport scheme as described in the Code of Practice contains more information on both the occupant and mobility aid than is needed, but it is also missing key information required for air travel. The Passport is defined in the British standard,

“2.13 passport-document attached to a wheelchair, containing key instructions and information regarding provisions for the needs of an individual and their wheelchair in transport”

The format and content of the Mobility Aid Passport should be determined by representatives of the stakeholder groups that include people with disabilities, mobility aid industry that includes representatives of the durable equipment industry or after market industry, the airline industry, ICAO, and IATA.  ICAO and/or IATA need to be engaged so that it is standardized across the industry. The RESNA ATAT committee is working to address documentation (Passport) information and the RESNA ATAT committee members should be engaged in discussions with ICAO and/or IATA. Members of the RESNA ATAT committee are also members of the IWG.

The information required for air transport includes details on the total and concentrated weight at the wheels of the unoccupied mobility aid, the required floor dimensions need to include width, length and height. The Passport should include photos of the mobility aid to document tie down locations. A key addition to the passport is detailed information on batteries and special instructions for disassembly and reassembly. 

There is consensus agreement among members of the IWG for electronic and hard copy passports for mobility aids, however, additional discussion is needed by all the stakeholders on the specific format and content of a passport that can be adopted across the aviation and mobility aid industries.  Ramp personnel, who may or may not be carrier staff and are key users of the passport, should be included in all the discussions on the key information and the format of the hard copy passport.

The Mobility Aid Passport would be printed on water resistant paper and firmly attached to the mobility aid. The electronic copy would be linked to the passenger’s medical record with a specific airline. Currently, there is no universal traveler’s record that can be shared between airlines, nor can airlines send whole documents to other airlines in an itinerary: airlines only communicate using SSR codes. The possibility of having this information be readily available to all airlines through a common platform is worth exploring in the future, subject to all applicable privacy concerns.  Currently, a number of airlines have mobility aid passport type documents on their websites but these are specific to each airline and are not universal. These range from very simple to very detailed. It is suggested that the Mobility Aid Passport be available both electronically and in hard copy.

The Council of Canadians with Disabilities (CCD) recommends that the passport documentation should be a microchip type device that is installed on the mobility aid by the MA OEM prior to release of the product to the consumer.  The microchip would be linked to a web-based registry electronic file that contains all written and illustrated information. Such an electronic file could also carry instructions for handling and storage.  This is analogous to the microchip installed on a companion animal that can also be linked to the animal’s medical history.  Further the CCD recommends that all the technical information respecting the mobility aids must be provided by the MA OEM and the after-market manufacturers, and that persons with disabilities should not be burdened with the costs of preparing and maintaining the information in such an electronic database.

This proposal of using a microchip would require further study. This solution would require significant infrastructure to ensure commitment and participation from MA OEM and after-market manufacturers, maintain the database and ensure that all ramp personnel around the world have the ability to access these microchips.

The RESNA ATAT committee is also working on developing, “Labeling and Design Requirements for Wheelchairs Designed for Storage and Transport in Commercial Aircraft”.

Items of content identified for passport by the international working group

The items that were identified for a possible development of a passport of mobility aids are the following

• Owner Contact Information: The CCD indicated that providing detailed passenger information such as name or address may increase the passenger’s vulnerability. There is a need to engage people with disabilities and their representatives in a discussion on the need to protect personal information including trip destination while at the same time, linking the mobility aid to the passenger. 
• Mobility Aid Manufacturer supplied information:
  • Mobility Aid: Model Number and Serial number
  • Weight (with batteries and without)
  • Mobility Aid Dimensions (include after-market dimensions)
  • Battery, number, type and method(s) of disconnecting or powering off the battery for safe transport.
  • Lifting and tie-down points (with photos).
  • Instructions on safe disassembly and reassembly.

The British Health Trades Association has a website,  Air Transport Advice^{Footnote 7} , that provides details on many common wheeled mobility aids. However, not all mobility aid manufacturers and products are included in the data base. Items from the trade association data base are listed below.

The information listed on the BHTA log includes:

• Manufacturer
• Model
• Tare (un-laden) weight
• Dimensions
• Number of batteries
• Type of battery (wet acid, non-spill able or lithium)
• Instructions for preventing accidental activation. {Appendix A Section 6 of the CAA Safety Notice}

Width

This is important information for airport ramp operations. The typical powered mobility aids are 24.5 inches (620 mm) and some are 25.5 inches (647.7mm) wide.  One of the challenges for ramp personnel are the powered mobility aids that are wider than the standard belt loader conveyor that has a belt width of 23.6 inches (600 mm).  There are wider belt loaders, but several airlines expressed concern that the wider belt loaders may damage the aircraft. The wide belt loader is 31.49 inches (800mm) and would accommodate almost all powered mobility aids and also fit most aircraft cargo doors (see Annex 2 for cargo door dimensions of common single aisle passenger aircraft).

Height

The height of mobility aid prepared for stowage in cargo compartment is a critical element. Most powered mobility aids cannot be placed on their side without incurring significant damage to the mobility aid.  The height of the mobility aid is a key dimension for stowage of the mobility aid in the cargo compartment. Although there is a range of clearance heights for cargo stowage areas depending on aircraft type (see Annex 2), the most constrained clearance height for cargo stowage areas is 31 inches (0.78m). This height accounts for variations in aircraft design including whether the cargo door opens in or out.  Most adult powered mobility aids have seat backs that are taller than 31 inches and since many of these mobility aids can be damaged if they are tipped on their side it is important for airlines and passengers to discuss the cargo door clearance when the reservation is made. 

Weight of mobility aid

There are three impacts of the weight of the mobility aid:

1. The weight of the mobility aid that needs to be lifted from the tarmac to the aircraft by manual or mechanical lifts. There is concern for safety of the ramp personnel handling mobility aid.
2. The concentrated load of the mobility aid on the three or four wheels and the location of the concentrated load in the aircraft cargo compartment with respect to the structural design of the cargo compartment^{Footnote 8}.
3. The overall weight of the mobility aid may impact the weight and balance of the aircraft.

Mobility aid weight and dimensions may be modified when accessories and specialized seating are added. The Passport should include the information on any after market modifications or customizations such as specialised seating systems and controllers or additional equipment added to the mobility aid.  

Mobility Aid Handling Checklist

The airline industry represented organizations have suggested the Mobility Aid Handling Checklist which is a simple, standardized generic handling form.  The Mobility Aid Handling Checklist is in addition to a Mobility Aid Passport which is the sole source of reliable, detailed information on the mobility aid.  The Mobility Aid Handling Checklist is for ground handlers and is intended to enable the sending station to communicate with the receiving station regarding what actions were taken on the mobility aid with respect to disassembly/assembly, disconnection/connection of batteries and return the mobility aid to its original state.

The Mobility Aid Handling Checklist will be used by third party handlers throughout the world and ICAO and/or IATA have expressed interest in leading the development of the checklist so that it is standardized and then have it implemented worldwide throughout the industry. Because of international users, a strong knowledge of English cannot be assumed and so the checklist must be simple and use pictograms wherever possible.  The adoption of a single Handling Checklist will ensure that third party handlers will become accustomed to the Mobility Aid Handling Checklist and this will promote more consistent handling of mobility aids.

The Mobility Aid Handling Checklist should only include:

• Method used to disconnect and turn off batteries; and
• Which parts (if any) were removed and where they are located (with the mobility aid in the cargo compartment or with the passenger in the cabin).

All other information specific to the mobility aid such as the following items should only be included in the Mobility Aid Passport that is attached to the mobility aid.

• Mobility aid lifting points (if relevant);
• Weight of the mobility aid – This should trigger whether a tarmac based lifting device needs to be used to lift the mobility aid  into aircraft;
• Mobility aid tie-down areas, or other information relevant to securing the mobility aid in the cargo compartment;
• Batteries (incorporate basic information from the IATA Battery Powered Wheelchair and Mobility Aid Guidance Document^{Footnote 9} );
• Electronic disconnects;
• Suggest that airlines or passengers provide an extra bag for stowage of loose parts that are taken into cabin;
• Photos of device (recommended);
• Photos showing details for tie down locations.

Standard Checklist of Passenger Questions

Initially the IWG considered a standard checklist of questions that are asked at the time of reservation that are linked to the traveler record including information that is not included in the Passport. Discussions were held with members of the IWG who outlined the relationship of the airlines and business models of the 3^rd party reservation entities.  This consideration has been removed due to personal and data privacy issues.  However, this is replaced with the very strong recommendation that passengers travelling with mobility aids contact the airline directly when the initial reservation is made, in advance of travel and at the airport.

Examples of approaches taken by a wheelchair manufacturer and airlines

Hera are a few examples of traveler checklists and guidance materials provided by Permobil,(a wheelchair manufacturer), WestJet and Air Canada.

• Permobil has supplied a wheelchair travel checklist^{Footnote 10}.
• WestJet also has a similar travel checklist on the airline webpage^{Footnote 11}.
• Air Canada also provided a link to its powered mobility aid information form^{Footnote 12}.

IATA has supplied a battery powered mobility aid guidance document that includes questions and answers and guidance for lithium batteries in the dangerous good regulations^{Footnote 13}.

Communication Materials

A key issue identified by representatives of the advocacy groups was the need for improved communication at pre-trip and day of travel between passengers, airlines and airport ramp operations on the needs of the passenger with disabilities and the handling of their mobility aids. The IWG was in agreement that more communication materials are needed in multiple formats and to multiple stakeholder groups as described below:

General public communication

At Time of Reservation

There was strong consensus that passengers must be informed of the need to communicate directly with airlines when the reservation is made, prior to the trip and at the airport.   Most airlines require passengers with mobility aids or disability-related needs to call in 48 hours in advance of flight. However, if a passenger requires a different itinerary due to size conflicts between the mobility aid and aircraft, 48 hours may not be sufficient.  The communication materials must emphasize the need for passengers with mobility aids to communicate their needs directly to airlines at the time of reservation.

Specific Information for Passengers with Mobility Aids

There is a need to develop simple and easy to understand communication materials for passengers with mobility aids. These materials should be very clear, accessible, and available in multiple languages and include graphical information. The communication materials should include:

• Information regarding mobility aid size and weight limitations due to aircraft cargo door clearance of the assigned aircraft on the trip itinerary. 
• An example of a Mobility Aid Passport and an explanation of why it should accompany the mobility aid.
• The Mobility Aid Handling Checklist for mobility aids and an explanation of its use.
• Description of mobility aid batteries that are safe for travel by air. The IATA /ICAO Documents, “Battery Powered Wheelchair and Mobility Aid Guidance Document” that is based on the (2019-2020 Edition) ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air should be the basis for the communication materials.  As referenced above, Air Canada has a form that requires passengers to fill out and attach to their mobility aids during travel.
• Accessible, simple and easy to access web-based information for travelers with mobility aids.  Direct access to the accessible traveller web materials should be available from the air carrier landing pages and include a minimal use of menus or pages to find an example of a Mobility Aid Passport and the Handling Checklist, battery limitation and other traveler information.
• Work with the United Kingdom Civil Aviation Authority and other international aviation organizations to link the British Health Trade Association Information on mobility aids.  Expansion of the data bases is needed to include more manufacturers and products and make it available worldwide.

Airlines and airport ramp operators

Develop simple communication materials for stakeholders that include front line air carrier, airport, and ground handling staff on the safe handling and loading of mobility aids. The Mobility Aid Handling Checklist should be developed in partnership with representatives of the stakeholder groups to ensure that the content and format satisfy the specific needs of the stakeholder groups.  The Mobility Aid Handling Checklist should be a simple document that allows the sending station to check off what was done and should include:

• Method(s) used to disconnect or turn off the batteries; and
• Which parts (if any) removed from the mobility aid and location of these parts (with the mobility aid in the cabin or in the cabin with the passenger).

Training for Employees and Contractors

The IWG identified the need for additional training materials for travel agents, airlines and airport staff including ground handlers, on providing appropriate assistance to passengers with disabilities and the information contained in the Mobility Aid Passport and Handling Checklist.  It was also suggested that training must include trainers with disabilities as well as MA OEMs and after market suppliers.

Section 8 of Appendix A of the CAA Safety Notice outlines British training requirements. One Team One Goal is a good example of a training video.

The CTA's proposed Accessible Transportation for Persons with Disabilities Regulations will require carriers to make sure their employees and contractors who provide transportation-related services to persons with disabilities are properly trained. This includes requiring that persons who handle mobility aids must receive training that provides an adequate level of knowledge to carry out those functions including training with respect to appropriate methods for carrying and storing mobility aids, including the disassembling, packaging, un-packaging and reassembling of mobility aids.  In addition, the proposed regulations will require that persons with disabilities be consulted in the development and implementation of a training program.

Airlines reservations staff

Airline reservations staff need additional training materials that are focused on asking people with disabilities appropriate questions on the mobility aid when a reservation is made to ensure that the mobility aid will fit onto the aircraft that are most likely to serve the flights on the complete itinerary. Critical information is related to the overall dimensions of the “collapsed or folded” mobility aid, and the type of batteries.

The initial reservation should be flagged by the airline to check flight details and aircraft type to ensure the maximum height of the mobility aid, taking into consideration whether the backrest can be folded, or the mobility aid height reduced in some other way, does not exceed the clearance height for the scheduled aircraft.

Ramp employees and ground handler staff

Ramp employees and ground handler staff require additional training materials that are focused on the safe handling, loading and securing of mobility aids. These training materials should include proper manual lifting techniques of mobility aids to protect the ground handling staff and also the use of mechanical lifting equipment for mobility aids that are too heavy to lift manually. Some airports in the UK have adopted a policy that prohibits manual lifting of powered wheeled mobility aids and provides vehicles, or lifting aids.

The training materials should be developed with ramp employees and ground handling agents providing significant direction on format, and learning styles, and people with disabilities who travel with powered mobility aids should also be consulted.  There are special operating environments such as remote airports that have limited operations and a lack of ground handling equipment. The Canadian special operating environments should be considered in developing the training modules.

The types of mobility aids are very diverse and each type of mobility aid has specific locations on the frame for tie downs and disassembly and assembly information. The training materials should focus on communicating general principles rather than focus on any particular type of mobility aid.

Issues that require additional discussion and development

Cargo compartment

Cargo Door Clearance

The aircraft manufacturing industry is highly regulated and the life cycle for new aircraft is declared in decades rather than years. When many of the current single aisle aircraft were designed there were very few choices for powered mobility aids and they were smaller than those on the market today.  Mobility aids are very diverse as are the people who use them and therefore it is very difficult to standardize the dimensions and weights of mobility aids. Mobility aids have a shorter life-cycle than aircraft, and it will be extremely difficult to identify the most appropriate cargo door size for future aircraft to support future mobility aids.

Aircraft cargo door clearance are influenced by multiple factors, including:

• Aircraft size (fuselage height and width)
• Cargo compartment position (above-floor or under-floor)
• Intended loading scheme (bulk / hand-loaded or containerized / palletized loading)
• Design of the door opening system

There are no plans for aircraft manufacturers to change the size of the cargo doors on existing certified aircraft.  However, with the work done by the IWG and the US Air Access Committee, the manufacturers are more aware of design changes that could be incorporated in new types of single aisle aircraft to accommodate larger mobility aids.

In looking forward it is important to note that cargo door size is not dependent on the size of the aircraft. It can be influenced by a variety of factors such as the purpose of the aircraft, and should be an important point for future design. In Canada, many of the aircraft flying to more rural areas actually have larger cargo door openings as a major part of the carrier’s business is freight and not passengers.

The cargo door size is only one aspect of loading a mobility aid into an aircraft cargo compartment. Other aspects include:

• compartment dimensions (height, width and length),
• compartment shape,
• weight bearing capacity of the cargo floor / structure and availability of restraining equipment and tie-down points in the cargo compartment to ensure the mobility aid does not move during flight, and
• location of the aircraft engines, which could restrict access to a cargo compartment.

All of these characteristics will influence the ability of a given aircraft type to carry cargo items such as mobility aids.

Annex 2 includes a Table and Chart of Select Single Aisle Passenger Aircraft Cargo Door Dimensions

Ground handling equipment

Procurement of ramp equipment

Ramp equipment is expensive and can have a long service life.  There was limited support of recommending the addition or replacement of ramp equipment that would assist with the loading and unloading of large mobility aids. It was also suggested that wider belt loaders be used for larger mobility aids, however the airlines were concerned that the equipment may damage the aircraft. One airline member of the IWG showed an electric lift that is used by ramp staff to prevent injuries resulting from manual lifting of for mobility aid and heavy baggage.

It is recognised that many of the larger mobility aids are wider than the standard belt loaders that interface directly with different types, sizes and models of aircraft.  The standard width of the belt loader is designed to fit these aircraft. An example of a vehicle used at Glasgow Airport, that meets ISO 15845:2014 was presented as an example of another way to assist ramp personnel by moving the mobility aid directly into the aircraft.

Example from Glasgow Scotland

Glasgow Airport has introduced a safe handling procedure across the airport following guidance from the United Kingdom Civil Aviation Authority, Safety notice 2012/003.  Glasgow Airport reached agreement with the Airport Operating Committee (AOC) that the airport would follow this guidance almost to the letter. The airport special assistance provider will make the mobility device safe for travel and sign part 1 of the (Electric Mobility Aid) EMA document on behalf of Glasgow Airport. The airline/handling agent will then verify that the device has been made safe to load and sign part 2 of the document and accept for carriage on the flight before the device is loaded. The ultimate responsibility remains with the airline to ensure that all mobility aids are made safe before carriage is accepted.

The special assistance provider and Glasgow Airport use Air Transport Advice in determining how to make each EMA safe based on information provided by the airline or passenger.  

Further study is needed of ground handling equipment to provide better loading options of mobility aids into single aisle aircraft. It is also recommended that a feasibility study, including an economic evaluation, consider the options for lifts and other aids to board heavy mobility aids from the tarmac to the belt loader or directly into the cargo compartment of the aircraft. This study could also include consideration of the European practice of using a special vehicle that assists with boarding of passengers and also with the safe movement of the mobility aids into the aircraft. However, it must be remembered that in the European Union, the airport authorities are responsible for handling mobility aids, which is an important contributing factor to this example.

Develop functional guidelines for securement or containment 

Most members of the IWG recommend the development of functional guidelines and/or performance standards for the securement and/or containment of mobility aids in the cargo compartment. Most of the members of the IWG were very supportive of developing guidelines for the airline industry, and many were surprised that the standards did not already exist. 

The IWG does not have complete representation of all the stakeholders impacted by this recommendation. The aircraft manufacturers represented on the IWG indicated that the specification of the cargo compartment for securement is up to the airlines and all aircraft have options for securement systems in the cargo compartment. The aircraft cargo compartment information is publicly available in the Airport Planning Manuals that are produced for each aircraft. IATA indicated that it has initiated some work and A4A also offered to help facilitate this effort.  The CCD recommends that appropriate tie down positions on aircraft must be an essential installation for aircraft manufacturers and not an option for the air carrier.

Transportable mobility aids

At the Forum, members of the IWG who used mobility aids conveyed how important their mobility aids are for self determination and independence.  Several members also demonstrated both the complexity and customization of their personal mobility aids.  During the discussions some members of the IWG suggested that innovation and redesign of mobility aids for air travel is needed and this could be compatible with customization of mobility aids. The base dimensions of height, width, and weight of the many of the mobility aids present the largest difficulty for air travel. Simple modifications that make a mobility aid more transportable include:

• Fold down or collapsible back rests that also meet the safety requirements for safe transport in vehicles;
• Protected controllers that can be collapsed into the main frame of the mobility aid;
• Clearly marked tie down locations and lift points;
• Easily disconnected batteries; and
• Clearly labelled batteries that meet ICAO transportation regulations.  

The elements of mobility aids that are most often customized are seating systems and controls. If these limitations are taken into account when mobility aids are designed, many of the barriers to transportation by air are removed. For example, customized seating systems could be easily detached or folded down, reducing the height of mobility aids. As another example, complicated and expensive controls (joysticks) could be easily disconnected, thus reducing the width of mobility aids.

Many of the airlines and their representatives serving on the IWG recommend that innovative and appropriate design of air transportable mobility aids should be a top priority. Airlines strongly recommend that ICAO, IATA and State Governments around the world should focus their energies on providing research grants and opportunities to mobility aid manufacturers, as well as subsidies to mobility aid users.

Recommendations

The recommendations can be categorized into the following subject areas:

1. Development of the format and content of the Mobility Aid Passport, by appropriate stakeholders, to be issued by mobility aid manufacturers, rehabilitation professionals or after-market equipment providers. IATA, A4A and RESNA have offered to lead in this effort.
2. Development by ICAO and/or IATA of the Mobility Aid Handling Checklist to be used by ramp handlers for tracking disconnection/connection and disassembly/assembly actions taken throughout the travel itinerary.
3. Development of communication materials for passengers, airlines and airport ramp handlers;
   • acceptable batteries for air travel
   • size and weight limitations of mobility aids due to air craft cargo door clearance and structural limitations of cargo compartment
   • Mobility Aid Passport and Mobility Aid Handling Checklist purpose and content.
4. Development of training materials for airline reservations, airline and airport front line and, ramp handlers that focuses on general principles, the Mobility Aid Passport and the Mobility Aid Handling Checklist.
5. Development of functional or performance guidelines for securement or containment of mobility aids in the cargo compartment.
6. Development and promotion of air travel friendly mobility aid designs.

Other long-term goals include the design of future certified aircraft to more easily accommodate large mobility aids.

The recommendations that have complete agreement from the IWG are: the Mobility Aid Passport, the Mobility Aid Handling Checklist, enhanced communication and additional training materials designed to assist airline reservations and ramp handlers.

Not all air carriers have policies regarding the securement or containment of mobility aids in the cargo compartment and consequently this recommendation did not receive unanimous agreement. There was general agreement of the need to develop additional functional or performance guidelines for airlines.

Most members of the IWG did not want to recommend changes in the procurement of ramp equipment. Some airlines consider that overly large and heavy mobility aids are an issue and not the ramp equipment which may be inadequate.  As such, many airlines believe that the focus should be more properly directed at redesigning mobility aids rather than replacing ramp equipment which are adequate for all other purposes.  However, some of the IWG members recommend that a feasibility study be done that considers ramp handlers safety and a cost/benefit analysis of new ramp equipment for mobility aids and heavy baggage.

Short Term Recommendations (1 to 3 years)

Recommendations that could be completed in one to three years include the following:

1. Development of format and content of Mobility Aid Passports

Leadership

ICAO/IATA, Airlines, Airline industry organizations, RESNA and Mobility Aid Industry and Advocates for Persons with Disabilities

Audience

General Public, Ground Service Providers, and Airlines

2. Development of Standard Mobility Aid Handling Checklist

Leadership

ICAO/IATA, Airlines, Airline industry organizations and ground service providers

Audience

Ground Service Providers, General Public and Airlines

3. Development of Communication materials for passengers, airlines and airport ramp operations

Leadership

Advocates for Travelers with Disabilities, ICAO/IATA, Airlines, and ground service providers

Audience

Passengers, Airport, Airline and Ramp Personnel, Airline reservation staff and ground service providers

4. Develop Training Modules including best practice materials for airlines, airport front line, and ramp handlers

Leadership

RESNA, A4A, NATA, airlines, ground service providers

Audience

Airport, Airline and Ramp personnel, Airline reservation staff and ground service providers

Medium Term Recommendations (3 –to 5 years)   

Recommendations that could be completed within three to five years include the following

5. Investigation of securement or containment of mobility aid in the cargo compartment

Development of functional or performance guidelines for the airlines on the securement or containment of mobility aid in the cargo compartment. There was general agreement among the different groups of stakeholders participating on the IWG that mobility aids need to be secured or contained in the cargo compartment. The IWG noted that there is a lack of consistent policies across the airline industry on the requirements for securement or containment of mobility aid in the cargo compartment.  It is recommended that a working group led by IATA and that involves the airline industry including ground services, wheelchair manufacturers, aircraft manufacturers, airlines and representatives of disability rights organizations be formed to investigate possibilities for securement or containment of mobility aid in the cargo compartment. The performance guidelines should reference the airframe manufacturer’s weight and balance manual.

Leadership

ICAO, IATA, Ramp Personnel, Mobility Aid Manufacturers, and Advocates for Travelers with Disabilities, Cargo containment and stowage industry

Audience

Airport Ramp Personnel and Airlines

Impact

Travelers with Disabilities, Mobility Aid Industry.

6. Conduct a feasibility study including a cost benefit analysis of ramp handling equipment for larger and heavier mobility aids. 

It is recommended that a feasibility study be considered for the procurement of special lifting equipment or special purpose vehicles that comply with ISO 15845:2014 for larger or heavier mobility aids and baggage.

Leadership

Airport Ramp Operations, Airlines, and Aircraft manufacturers

Audience

Airport Ramp and Air Carriers Airport Operations

Impact

Travelers with Disabilities, Ramp Handlers

Issues That Require Further Consideration

Immediate consideration

Mobility aids designed for air travel

It is recommended that ICAO, IATA and governments around the world encourage further development and marketing of transport friendly mobility aids that meet the needs for people with reduced mobility that can be safely transported by air. 

It should be remembered that mobility aids are as diverse as the population and therefore it is difficult to develop standard maximum design envelops (height, width, length, weight) of mobility aids.  There are mobility aids available that some travellers can use, but it must be remembered that travelers who require mobility aid customization such as seating systems are not able to use many of the mobility aids that are designed for travel and currently available.But increasing the awareness by the airline industry and passengers of the constraints imposed by aircraft and ramp handling will enable more informed travel decisions.

Mobility aid innovation and redesign for air travel does not prevent customization (most commonly controls (joysticks) and seating systems. Knowing that many mobility aid users require customization, this should be built into the innovation and design process, and taken into account as a necessary objective.

Governments should also facilitate additional research or greater access to travel-friendly mobility aids by providing research funding or subsidies to companies and/or mobility aid users.

There is also a need for rehabilitation professionals and prescribers of mobility aids to consider all the transportation needs of people with reduced mobility when developing mobility aid prescriptions.

Leadership

Mobility Aid Manufacturers, Advocates for Travelers with Disabilities ICAO/IATA, and State Governments

Audience and Impact

Travelers with Disabilities, Mobility Aid Industry, Aircraft Manufacturers, Airlines.

Long term goals

In light of the life cycle of aircraft, the long -term intention concerns the design incompatibility between mobility aids and aircraft cargo compartment clearances. It is suggested that aircraft and original equipment manufacturers consider larger cargo doors for future designs of new type certified aircraft. Increasing the door size may accommodate more mobility aids.

Leadership

Aircraft Manufacturers, Mobility Aid Manufacturers

Audience and Impact

Travelers with Disabilities

References

• British Standards Institute, (2013) “The Code of Practice for Wheelchair Passport Schemes) (BS 8603:2013)”
• [British] Civil Aviation Authority, “Safety requirements Applicable to the Carriage of Electric Mobility Aids” Safety Notice Number SN-2012/003, March 2012
• Canadian Transportation Agency, (2007) “Code of Practice for Air Terminal Accessibility”, Report number TT4 10/2 2007
• Canadian Transportation Agency, (2016)” Aircraft Accessibility for Persons with Disabilities: Code of Practice for Fixed-Wing Aircraft with 30 or More Passenger Seats” Report number TT4-16/2016E
• International Air Transport Association and International Civil Aviation Organization 2019(“Battery Powered Wheelchair and Mobility Aid Guidance Document” that is based on the (2019 Regulations) ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air is the basis for the document.
• International Standards Organization, “ISO 15845:2014 Aircraft ground equipment - Boarding vehicle for persons with reduced mobility - Functional and safety requirements”

Other Documents

Airport Planning Manuals for: Airbus A 320 Family of Aircraft, Boeing B737x family of aircraft, Bombardier Q series (e.g. Q 400) and Dash 8, and CRJ families of aircraft, and Embraer 175x and 195 x families of aircraft and new Bombardier (C series) now referred to as Airbus A220 and SAAB 340.

Abbreviations

A4A

Airlines for America

ATAC

Air Transport Association of Canada

CCD

Council of Canadians with Disabilities

CEAT

Center of Expertise in Accessible Transportation

CRJ

Canadian Regional Jet (Bombardier)

CTA

Canadian Transportation Agency

FAA (US DOT)

Federal Aviation Administration

IATA

International Air Transport Association (Trade Association)

ICAO

International Civil Aeronautics Organization   (Standards and Regulatory

ISO

International Standards Organization

MA–OEM

Mobility Aid Original Equipment Manufacturers

NATA

Northern Air Transportation Association

NACC

National Airlines Council of Canada

PVA

Paralyzed Veterans of America

RESNA

Rehabilitation Engineering and Assistive Technology of North America

Annex 1:  International Working Group Members and Observers

Air carriers and organizations

• Alaska/Horizon Airlines
• Air Canada
• Air Transat
• Porter Airlines
• Sunwing Airlines
• United Airlines
• WestJet
• Airlines for America
• Air Transport Association of Canada (ATAC)
• International Air Transport Association (IATA)
• International Civil Aviation Organization (ICAO)
• Northern Air Transportation Association (NATA)
• National Airlines Council of Canada (NACC)
• Swissport Canada Handling Inc.

Aircraft manufacturers

• Aerospace Industries Association of Canada
• Airbus
• Boeing
• Bombardier

Disability rights organizations

• Council of Canadians with Disabilities (CCD)
• National Accessibility and Inclusion Committee
• National Pensioners Federation
• Paralyzed Veterans of America
• Spinal Cord Injury Canada

Mobility aid manufacturers

• Invacare
• Permobil

Mobility aid rental

• Scootaround

Canadian and US government

• U.S. DOT
• Transport Canada
• Canadian Transportation Agency

Annex 2: Aircraft Door Dimensions of Select Single Aisle Aircraft (metric)

Note: Acceptable dimensions for mobility aids may be even smaller due to the placement of the engine, the direction of the door opening, a protective covering around the doorframe, or other factors.

Data is derived from Airport Planning Guides for each Aircraft.

Table 1 : Aircraft cargo door dimensions (clearance)

Aircraft Type	Forward Height (m)	Forward Width (m)	Aft Height (m)	Aft Width (m)
Airbus A220	1.1	0.81	1.1	0.81
Airbus A-319	1.81	1.224	1.81	1.02
Airbus A-320/321	1.81	1.24	1.81	1.02
Boeing 737x	1.22	0.89	1.22	0.83
Boeing 757-x	1.39	1.079	1.39	1.1
DC-9-x	1.35	0.79	0.91	0.76
Bombardier CRJ all	0.51	1.06	1.06	0.86
Bombardier Q 400	1.75	0.76	1.52	1.29
Bombardier Dash 8	0.76	1.65	1.1	0.81
Embraer 170/175	1	0.9	0.98	0.87
Embraer 190/195	1	0.9	0.98	0.87
SAAB 340			1.35	1.3