Serious Concerns Raised as Two Short-Lines Petition for One-Person Train Crews

After years of hearings, public participation, and extensive review of rail operational safety concerns, the Federal Railroad Administration (FRA) finalized its Train Crew Size Safety Requirements Rule in April of 2024.

Establishing a federal minimum standard that requires two-person train crews (2-PC) except in narrowly defined circumstances, this rule was based on more than 13,500 public comments, including testimony from rail workers, emergency professionals, members of the public, and multiple labor organizations, including SMART-TD.

This common sense rule ensures that trains have a full crew on board, protecting communities and emphasizing what the FRA made clear: two-person crews are necessary to ensure baseline safety.

Now, this rule is under threat as two short-line railroads petition the agency to waive that federal standard and operate with one-person crews, a request that has the potential to result in deadly consequences.

Multiple Inconsistencies, Ambiguity in Petitions Raise Serious Concerns

Based on an operational model that removes the conductor from the locomotive and instead places them in a highway vehicle “shadowing” the train by roadway, Georgia Central Railway and First Coast Railroad’s individual petitions present a stunning lack of clarity around the concept of “close proximity” and how the conductor factors into it.

This includes…

• What distance is considered acceptable?
• How will compliance be gauged?
• What happens when uncontrollable situations (traffic, disabled vehicles, weather conditions, etc.) prevent the conductor from maintaining the vague “proximity?”

This is not a concept that should be left up to interpretation; doing so would make it nearly impossible for FRA inspectors to verify in real time whether this is happening, ultimately making it unenforceable.

Beyond that, the carriers’ reliance on the locomotive alerter system to fill the safety void when the conductor is removed from the cab is ridiculous.

Let’s be clear: an alerter is not even remotely close to having a certified conductor on board and only useful after the engineer has become incapacitated.

Removing the second human element from the cab is a recipe for disaster: conductors exist to help prevent emergencies from escalating into catastrophes, and the FRA’s own rule recognized the importance of both crew members.

There’s a reason why states across the country are locking 2-PC rules into law: nothing can substitute for having a certified conductor and engineer in the cab to make critical decisions in situations where every second counts.

SMART-TD Asks Questions That Deserve Thoughtful Responses  

In our public comments directly responding to the petitions, SMART-TD poses several questions, including…

• Do the carriers intend to equip company vehicles with hands-free communication technology specifically designed to minimize distracted driving hazards for conductors shadowing trains by roadway?
• If not, how do the railroads intend to mitigate the known safety risks associated with operating a motor vehicle while actively engaged in railroad radio communications?
• What procedures will govern situations requiring the crew to receive and copy mandatory directives or other dispatcher-issued instructions?

As we’ve always done, SMART-TD will continue fighting to ensure that trains have a full crew on board, protecting communities and underscoring the role that our members play in the safe operation of our nation’s rail network.

Now is the time for all of us to meet the moment and ensure that this rule withstands baseless challenges that jeopardize rail safety.

Read both public comments below