Commenting on Rule of 2 a call to action for our members, allies

September 7, 2022

Most topics divide our organization to varying degrees. It’s a healthy debate that assists SMART to formulate majority-based positions on the many issues for which they advocate on our membership’s behalf.

TD Indiana State Legislative Director Kenny Edwards

The belief that there should be a minimum of two persons on a train crew is not one of those topics. Overwhelmingly, the most-common topic that my fellow Transportation Division brothers and sisters ask about is the status of a two-person crew legislation/regulation. A consensus of our membership strongly believes in the necessity of legislative or regulatory action requiring rail carriers to crew trains with a minimum of two people in the locomotive cab.

Here is some great news: The FRA has announced its intent to make a formal federal regulation mandating the minimum crew size on most trains to be no less than a crew of two in locomotive cab. SMART TD paved the way to get the process to this point by ensuring elected and appointed officials were both educated and aware of our position on the topic.

The next step in the process is the public comment period that expires on Sept. 26.

Years of work have gone into getting us to this point. Through this comment process we are going to bring it all home. We respectfully request that every SMART member submit a comment to the FRA website.

A poor comment turnout will play into the carriers’ narrative that a minimum crew size regulation is unneeded and sends a message that this isn’t a topic of interest to rail workers.

A robust or overwhelming turnout for the comment process sends a loud and clear message: There should be a minimum of two persons on a train crew.

Who can and should comment? All rail employees, regardless of craft and labor organization. All our allies and stakeholders, including legislators, community leaders, first responders, neighbors and business leaders should comment. Our family members and friends are also persons of interest whose comments the FRA wants to hear.

Please don’t be intimidated by the process. I assure you it’s quick, easy and painless. I completed my comments and the entire process in less than five minutes.

What should you say? If you work on the railroad you can speak from the heart. Express what you see at work every day and the catastrophic reality of what anything less than two-person rail crews would bring to the industry. If you would rather, SMART-TD has made a video available on this site that will guide you through the process. Family members, allies and stakeholders should be encouraged to describe the reality from their perspective.

This is it. I can’t state strongly enough the importance of this process. Everyone has done a lot of work to get us to this point. Pulling together as a team is what unions do!! Let’s all pitch in and get this past the finish line.


Kenneth O. Edwards

SMART Transportation Division Indiana State Legislative Director