What are the immediate compliance requirements for Part 382 as of January 2025?

As of January 2025, airlines must publish cargo hold dimensions prominently on their websites, implement standardized definitions for 'safe,' 'dignified,' and 'prompt' assistance, adopt rebuttable presumption of responsibility for wheelchair mishandling, reimburse passengers for accessible ground transportation when devices are delayed, and offer free rebooking when wheelchairs cannot be loaded on scheduled flights.

What does 'rebuttable presumption of violation' mean for wheelchair mishandling?

Airlines are now presumed responsible for any damage, delay, loss, or pilferage of wheelchairs and assistive devices from the moment they accept the device until it is returned to the passenger. The airline must assume responsibility first and can only rebut the presumption with evidence, rather than claiming the damage was not their fault.

What are the enhanced training requirements for airline personnel by June 2026?

By June 2026, all airline employees and contractors who assist passengers with mobility disabilities or handle wheelchairs must complete annual hands-on training. This requires in-person practice with real-life scenarios using life-size models or equipment in a safe, controlled environment, plus successful competency demonstration through assessments or certification exams. E-learning alone is no longer sufficient.

How quickly must airlines return delayed wheelchairs to passengers?

Effective June 2025, airlines must transport delayed wheelchairs to passengers within 24 hours for domestic and short international flights (12 hours or less) or within 30 hours for long international flights. Airlines must use whatever means necessary (including other carriers or courier services) and give passengers the choice of airport pickup or delivery to a reasonable location like home or hotel.

Part 382 ACAA updates on wheelchair handling, reimbursement, training, and passenger notifications.

Jan 23, 2025

Part 382 ACAA Updates: Wheelchair & Assistive Device Compliance Guide

WHAT ARE THE KEY CHANGES TO PART 382 OF THE AIR CARRIER ACCESS ACT?

Recent updates significantly strengthen protections for air travelers with disabilities using wheelchairs and assistive devices.

This webinar explains the phased implementation timeline (January 2025 through 2031), clarifies new definitions for "safe," "dignified," and "prompt" assistance, and outlines airline responsibilities for wheelchair mishandling, reimbursement, enhanced training, and onboard wheelchair standards.

WHAT DOES THE WEBINAR COVER?

Why the Update Was Implemented The U.S. Department of Transportation strengthened regulations to address serious problems with wheelchair and scooter mishandling, improper transfers, and inconsistent accommodation practices across carriers.
Phased Implementation Timeline Compliance dates are staggered from January 2025 through 2031, giving airlines time to implement operational changes, training programs, and equipment standards based on complexity.
Immediate Compliance Requirements As of January 2025, airlines must publish cargo hold dimensions on their websites, standardize definitions, implement rebuttable presumption of violation for mishandling, and update notification procedures.

January 2025 Implementation Requirements (Effective Now)

Safe and dignified assistance definitions: Standardized across all carriers
Prompt boarding/deplaning definitions: Clear timelines for assistance
Rebuttable presumption: Airlines presumed responsible for damage, delay, loss, or pilferage
Cargo hold publication: Dimensions must be prominent and easily accessible on carrier websites
Reimbursement requirements: Must cover accessible ground transportation costs when devices are delayed
Rebooking at no cost: When wheelchairs/scooters cannot be loaded on scheduled flights

March 2025 Implementation Requirements

Prompt repair or replacement: Passengers given reasonable time to inspect and file claims
Carriers must offer repair options (carrier handles or passenger chooses vendor)
Replacement devices must have equivalent or greater function and safety
Fare difference reimbursement: When passengers must take different flights same-day due to device accommodation issues
Passenger notification requirements: Written notification of rights when devices are mishandled, including CRO contact information

June 2025 Implementation Requirements

Prompt return of delayed devices: Must be transported within 24 hours (domestic/short international) or 30 hours (long international) by whatever means necessary
Passengers given choice of airport pickup or delivery to reasonable location (home, hotel)
Delay period starts when passenger arrives but device does not

December 2025 Implementation Requirements

Loading confirmation: Notify passengers before cabin door closes whether device has been loaded
Unloading confirmation: Notify passengers before deplaning when device has been unloaded from cargo
Device tracking: Must be specific to assistive device, separate from general baggage tracking
Seating accommodations: Provide safe and adequate seating for passengers waiting for delayed or loaner devices after consulting disability rights organizations

June 2026 Implementation Requirements

Annual hands-on training: Required for all employees and contractors who assist passengers with mobility disabilities or handle wheelchairs/scooters
Competency demonstration: Successful knowledge demonstration through assessments or certification exams
In-person practice: Real-life scenarios in safe, controlled environment using life-size models or equipment
No longer acceptable to rely solely on e-learning modules

October 2026 & 2031 Implementation Requirements

2026 requirement: All aircraft with 125+ seats must meet new performance standards for onboard wheelchairs
2031 requirement: All aircraft with 60+ seats must meet improved onboard wheelchair standards
Standards apply to both single-aisle and twin-aisle aircraft

Key Takeaways

Immediate Action Required: Ensure CROs are experts in the updated rule and have signed acknowledgment. Audit website compliance for cargo hold dimension publication.

Understand New Definitions: "Safe," "prompt," "dignified," and "mishandled" now have standardized meanings across all carriers—review and implement consistently.

Operational Coordination: Device tracking, boarding/deplaning notifications, and loaner accommodations require coordination between ramp, cabin crew, passenger services, and baggage teams.

Training Investment: Enhanced annual hands-on training requirements for 2026 will require budget planning and competency assessment programs.

Code-Share Agreements: Review and update agreements to clarify responsibility for reimbursements, fare differences, and mishandling claims between operating and marketing carriers.

Presented By

Richard Gomez (Senior Vice President, Aviation Products and Solutions, MedAire) • Tracy Gaunt (Medical and Disability Instructor, MedAire)