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1. Introduction
This document is intended to provide guidance to airline operators or airports in assisting passengers travelling with mobility aids. It is not intended to be binding on airline operators or airports.
1.1 Current Regulatory Framework
The Civil Aviation Act 1988, Civil Aviation Safety Regulations 1998, Civil Aviation Regulations 1988 and related subordinate instruments, constitute a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents. A number of aspects of the aviation safety regulatory framework relate to the facilitation of travel by passengers with disability.
The Disability Discrimination Act 1992 (DDA) is national, uniform legislation which outlines the obligations of individuals and organisations to not unlawfully discriminate against people with disability in a number of areas of life, including the provision of services such as public transportation and access to premises. The Disability Standards for Accessible Public Transport 2002 (Transport Standards) specify levels of service, measures, and actions that public transport operators must undertake to meet their obligations under the DDA.
Generally speaking, all airline and airport operators must comply with the requirements set out in the Transport Standards for conveyances, infrastructure and premises. There are however a number of exclusions from certain aspects of the Transport Standards that apply to airline and airport operators, in the case of:
- Small aircraft (fewer than 30 seats).
There are technical problems associated with making a small aircraft accessible, such as the size of the aircraft cabin, insufficient luggage space and limited weight carrying capacity. - Airports that do not accept regular public transport services.
Many small airports do not have regular staff and are mostly used by non-commercial or charter flights. Many are not licensed to accommodate regular public transport services and do not generate the volume of revenue necessary for capital improvements.
There are also provisions in the DDA and the Transport Standards that provide that certain conduct by airline and airport operators does not constitute unlawful discrimination—such as reasonableness and unjustifiable hardship ‘defences’, and the provision of equivalent access and direct assistance.
Definitions
A ‘disability aid’ is broadly defined in the DDA as equipment that is used by a person with disability and provides assistance to alleviate the effect of a disability. A disability aid may be a palliative or therapeutic device. ‘Mobility aids’ are devices designed to assist walking or otherwise improve the mobility of people with a mobility impairment. Examples include walking aids (e.g. walking sticks, crutches and frames), manual or electric wheelchairs, and electric mobility scooters.
2. Information Sources
Airline and airport operators provide a range of information to assist people with disability, including information about airport facilities and services, and flight requirements and limitations.
This information may be presented through a number of mediums, such as:
- electronically, via email and through the airline and airport websites;
- as part of information provided during the booking process;
- by telephone, including a comparable information service for people with hearing impairment;
- in-person at airline customer service counters; and
- in Disability Access Facilitation Plans (DAFPs), published on airline and airport websites.
3. Pre-flight—Booking
3.1 Advance Notification Requirements
Airline and airport operators may need to request passengers with disability who require assistance to travel, including those passengers who intend to travel with manual or electric wheelchairs and scooters or who will require other assistance, to provide advance notice of their requirement for accessible travel.
It is recommended that airline and airport operators require at least 48 hours" notice of a need for accessible travel to ensure that the necessary accommodations can be made to support the passenger's needs. However, where less than 48 hours" notice is provided, airline and airport staff should endeavour to accommodate the needs of the passenger.
It is recommended that airline operators provide an opportunity for passengers with disability to provide advance notice of any additional needs, including the need to travel with a mobility aid, through the booking process.
Airline customer service, travel and other booking agents could request the following information from passengers in advance:
- number of mobility aids;
- type of mobility aid;
- size dimensions of mobility aid;
- weight of mobility aid;
- type of battery, if battery-powered;
- whether the aid is collapsible or foldable; and
- any assistance that the passenger will require during any period of travel they are unable to use their mobility aid.
3.2 Dangerous Goods approval requirements for portable power supplies
Airline operators must ensure battery powered mobility aids and spare batteries are transported in accordance with aviation safety regulations. Guidance on how to prepare battery powered mobility aids is available on airline operator websites and the Civil Aviation Safety Authority (CASA) website at www.casa.gov.au.
Airline operators can request that passengers provide advance notice and information about their mobility aid and battery type at the time of booking. Airline operators should provide information about transporting battery powered mobility aids and batteries in their DAFPs.
3.3 Limits on the number of passengers requiring wheelchair assistance permitted per flight
Wherever possible, airlines should adopt a flexible approach to the carriage of passengers requiring wheelchair assistance and, subject to the operational and safety requirements (such as limitations of the aircraft and staff availability), aim to carry as many passengers as possible requiring wheelchair assistance on each flight.
However, there may be circumstances where it is necessary for an airline to limit the number of passengers requiring wheelchair assistance carried on a particular flight due to operational and safety requirements.
Factors that could be taken into account in determining the number of passengers requiring wheelchair assistance that can be carried on a particular flight include, without limitation:
- the extent of the passenger's disability and the level of assistance to be provided by the airline;
- whether the passenger is travelling with a personal wheelchair to be loaded into the aircraft;
- the size and weight of the passenger's personal wheelchair (as small manual foldable wheelchairs will be easier to load and unload compared to electric wheelchairs and scooters which may also be accompanied by a spare battery that will need dangerous goods approval or may exceed the size and weight restrictions of the aircraft);
- the nature of assistance required for passengers already booked on the flight;
- the airport infrastructure available at the departure and arrival airports; and
- the type of aircraft allocated to the passengers preferred flight, including the capacity of the cargo hold and any aircraft weight limitations.
Airlines might also consider other factors relevant to their operation in determining the carriage of passengers that use wheelchairs (such as operational and safety considerations). Information on an airline's policy regarding the carriage of passengers using wheelchairs and other mobility aids should be made available through the airline's website and DAFP.
Where circumstances necessitate that an airline is not able to carry a passenger using a wheelchair on a particular flight (for example, where a change to the operating aircraft type prohibits the carriage of a particular mobility aid), the airline should contact the passenger as soon as possible to discuss and to try to arrange suitable and timely alternative travel arrangements with them.
4. Arrival at Airport
4.1 Kerbside Arrangements
Airport operators should ensure ample arrangements are in place to maximise accessibility, including accessible set-down and pick-up areas, accessible ramps and pathways and accessible car parking. Airline and airport operators should provide information about any kerbside arrangements in their DAFP and, if possible, as part of the booking process.
5. Check-in at the Airport
Airline operators should provide information about check-in and boarding times in its DAFP, ‘conditions of carriage’ and as part of the booking process, particularly where these differ from the timings provided as part of an airline's general passenger information.
Airline staff should assist passengers with disability with the check-in process and confirm any assistance requirements at this point. Check-in staff should also provide the passenger with information on how their mobility aid will be carried, whether and at what point the passenger will need to hand over their mobility aid to airline staff, and what support will be available to the passenger during any periods they are not able to use their mobility aid.
5.1 Allowance on mobility aid items
Passengers with disability are generally able to carry up to two mobility aids in addition to airline baggage allowances at no extra cost. Airline operators that charge additional fees to transport more than two mobility aid items should make this information available in their DAFP and at the time of booking.
5.2 Provision of mobility aids to airline staff prior to boarding the aircraft
Where passengers are required to check-in their mobility aids with any other baggage, the airline operator should seek to maintain the passenger's independence. This could include assisting them to transfer to an airline supplied wheelchair and onto the departure area if required. The airline operator should discuss any requirements that the passenger may have after handing over their mobility aid, as well as continue to offer assistance if required.
Provisions for checking-in mobility aids vary with respect to airport facilities and airline operational restrictions. It is strongly recommended that airline operators provide this information to passengers in their DAFP and, wherever possible, as part of the booking process or subsequently if more practicable.
5.3 Assembly and Disassembly of Mobility Aids
Where mobility aids are disassembled to be loaded into the aircraft cargo hold, airline and airport handling operators can request further instruction from passengers. This will ensure that a passenger's mobility aid is handled appropriately.
The airline should take all reasonable steps to ensure that a passenger's mobility aid is handled with care and returned to the passenger in the condition it was received in. An airline's liability for damaged or lost property is limited and subject to provisions of the Civil Aviation (Carriers" Liability) Act 1959.
Airline operators should provide information about compensation policies for damaged or lost mobility aids in their conditions of carriage, DAFP and as part of the booking process.
Once the aircraft arrives at its destination, every effort should be made by the airline to ensure that the mobility aid is reassembled and returned to the passenger as soon as possible after arrival. The process for having their mobility aid returned, including what assistance will be provided by the airline while the passenger awaits the reassembly of their mobility aid, should be discussed with the passenger at check-in and at the point of disembarking the aircraft.
6. Security Screening at the Airport
Under the Aviation Transport Security Act 2004 (ATSA), passengers, baggage and cargo departing on regular passenger transport services, and any other flight departing from the same apron during the operational period, must undergo security screening.
This includes mobility aids such as walking aids and wheelchairs (including airline supplied wheelchairs) which must be screened using an x-ray and/or explosive trace detection test before being loaded onto an aircraft. The designated screening authority must ensure that seating and walking aids are available at screening points to assist passengers whilst their mobility aid is being screened.
Passenger screening may include walking through metal detectors and body scanners. If passengers are not independently mobile or unable to stand still with their hands raised above their head for the body scanners, the designated screening authority should utilise alternative screening methods that are best suited to the passenger.
Training is to be provided to security screening officers to ensure everyone is treated fairly and with respect when going through security screening at the airport.
The Office of Transport Security, in conjunction with aviation industry participants and disability advocacy groups, has developed the Screening Practice Guidelines. The Guidelines provide practical advice on screening customers with special needs and are provided to airports and security service providers.
Airport and airline operators responsible for security screening must ensure that these guidelines are implemented effectively. This will promote awareness of people who may require assistance with the security screening process and ensure a nationally consistent screening experience for passengers with a disability.
7. Boarding the Aircraft
7.1 Mobility Aid Size and Weight Requirements for Carriage in the Aircraft Cabin
Generally, walking aids and collapsible devices which are better able to be carried in the aircraft cabin, include:
- canes;
- crutches;
- collapsible walking frames; and
- prosthetic devices.
Airline operators should assist passengers to store and retrieve mobility aids in the aircraft cabin.
Size and weight requirements for storing mobility aids in the aircraft cabin can vary between flights due to different aircraft sizes and types. Airline operators should make this information available to passengers in their DAFP and at the time of booking.
7.2 Mobility Aid Size and Weight Requirements for Carriage in the Aircraft Cargo Hold
A range of mobility aids can be stored in the aircraft cargo hold, depending on safety and space requirements. Walking aids and collapsible devices will be stored in the aircraft cargo hold, rather than in the cabin, when they exceed size and weight requirements or there is insufficient space to store them safely in the aircraft cabin. In all cases, electric mobility aids are stored in the aircraft cargo hold as there is insufficient space to store them appropriately in the aircraft cabin.
Size and weight requirements for cargo storage can vary from flight to flight due to different cargo door dimensions, safe weight capacity of different aircraft types, and workplace health and safety requirements. Airline operators should make this information available in their DAFP.
Where an airline operator is unable to transport a passenger's mobility aid due to space, safety or operational considerations (e.g. size, weight, workplace health and safety), the airline operator may determine it necessary to transport the mobility aid separately or together with the passenger on the next available flight.
When this occurs, airline operators should work with the passenger to make alternative arrangements that, as far as possible, meet the needs of the passenger.
Any alternate arrangements made with the passenger should, wherever possible, make it
a priority to transport a passenger's mobility aid on the same flight as the passenger.
7.3 Check-In of Mobility Aids at the Time of Boarding
Wherever possible, passengers should be able to use manual wheelchairs and other types of non-collapsible mobility aids (excluding electric devices) up to the departure area. Where it is necessary to transfer to an airline/airport supplied wheelchair, the airline operator should provide any necessary assistance to the passenger in order to board the aircraft. If available and agreed to by the passenger, airline operators and airport handling operators should utilise a high lift vehicle or boarding ramp to assist passengers with disability to board the aircraft. To ensure the necessary equipment is available, airline operators should discuss and confirm these arrangements with the passenger at the time of check-in and as part of the booking process.
Walking aids and other devices can also be collected from the passenger at the departure area if there is insufficient space to stow them in the aircraft cabin, or at the request of the passenger. Where this occurs, the airline should discuss with the passenger and provide any assistance they may require once the passenger hands over their aid.
Provisions for collecting mobility aids from passengers at the departure area may vary with respect to airport facilities and operational restrictions. It is strongly recommended that airline operators make this information available in their DAFP and at the time of booking wherever possible.
7.4 Access to Mobility Aids between Connecting Flights
When there is a significant period of time between connecting flights, passengers may request that their mobility aid be returned to them. If this is not possible, the airline should discuss with the passenger and provide any requested assistance, including assisting passengers to transfer to an airline supplied wheelchair. If a manual self- propelled wheelchair is not available, airline staff should ensure the passenger is able to access and utilise the facilities in the airport terminal.
8. Disembarking the Aircraft
Prior to disembarking the aircraft, airline staff should discuss with the passenger the process for disembarking the aircraft and the support that will be provided to the passenger whilst disembarking the aircraft.
If available, airline operators and airport handling operators should discuss with the passenger the use of a high lift vehicle or boarding ramp to assist with disembarking.
Wherever possible, the same device used to assist a passenger with a mobility aid to board the aircraft should be used to assist the passenger to disembark the aircraft.
Airline operators should also discuss with the passenger the process for transferring back to their mobility aid, including where the passenger will be transferred to an airline/airport supplied wheelchair as part of the disembarkation process.
9. Collection of Mobility Aids Upon Arrival
The process for the collection of mobility aids upon arrival should be discussed with the passenger to ensure they are aware of what steps are required and so they are able to agree with the airline any additional support they will need while awaiting the return of their mobility aid.
Mobility aids stowed in the cargo hold should be given priority over cargo and baggage when unloading aircraft. It is encouraged that manual mobility aids be returned at the gate inside the terminal wherever practicable, unless otherwise requested by the passenger. In such cases, the mobility aid should be specially tagged at check-in.
Where airport infrastructure or airline operational arrangements do not allow collection at the gate, mobility aids may be taken to the oversize baggage collection area. If the mobility aid is being collected from the oversize baggage collection area, airline staff should assist passengers to the baggage carousel, with the collection of baggage and the mobility aid, and with the transfer to the passenger's mobility aid, if available and if required.
10. Contingency Planning
If unexpected events impact on the airline's ability to carry a passenger's mobility aid, the airline operator should contact affected passengers as soon as possible to discuss and arrange suitable and timely alternative travel arrangements with them.
11. Complaints Resolution
Airline and airport operators should have effective complaint handling procedures in place and provide information about how to make a complaint in their DAFPs as well as through the complaints handling section of airline and airport websites.