Crew Size Mandates

Our Ask:

  • Avoid staffing mandates with no safety benefit that shift resources away from critical and needed infrastructure upgrades, technology implementation and operational efficiency.

The Federal Railroad Administration (FRA) is moving forward with a proposed rule that could require railroads to hire more personnel or operate with more people on a train than necessary. It would be the first time in the nearly 200-year history of railroading in this country that there has been a federal rule on the number of people needed to operate a train. Crew size has long been handled via labor negotiations, and should remain so.

The Notice of Proposed Rulemaking (NPRM) imposes a requirement to have two persons in the cab of a locomotive. This requirement, by the admission of the FRA, does not address any safety concern when using single person crews. It imposes significant burdens for short lines, and risks bankruptcy for many.

ASLRRA, and others, have strongly discouraged a rulemaking regarding crew size on prior occasions (2016), and have done so again with the current rulemaking.


“This new prescriptive crew size rulemaking would threaten the ability of short lines to survive and thrive in the future by adding major new costs and regulatory burden for no attendant safety benefit. From the short line viewpoint, this proposed rule continues to be a drastic solution in search of a problem.”

Chuck Baker, President, ASLRRA

As detailed in Chuck Baker’s oral testimony at the December 14, 2022 hearing, this rulemaking will immediately impact hundreds of small business short line freight railroads operating single person crews safely today – and all for no safety benefit.

  • Short lines will need to make artificial and inefficient economic and management decisions. They’ll be forced to put their limited resources toward increasing operating staff on the train — when they’re already struggling to hire enough of those qualified individuals — instead of putting that capital where it may be better used, like making improvements to track and structures that are critical for the efficient movement of goods and freight.
  • It risks the short line industry’s ability to service their customers and provide an economic engine to the communities in which they operate, and the modal shifts that it would inadvertently cause would not serve the American public well.
  • This is particularly troubling, as other forms of transportation are being incentivized to develop operational practices where no persons are involved.
  • Ill-conceived mandates — especially those that aren’t backed up by safety data — are misguided and exacerbate problems instead of creating solutions.
  • Several states have also proposed legislation dictating crew size. ASLRRA has encouraged the FRA to exert pre-emption in this matter, so that a patchwork of regulations across the U.S. does not impede interstate traffic. ASLRRA has commented in several proceedings, including the State of Kansas DOT.

Key Takeaway:

ASLRRA opposes any federal mandate absent a documented safety improvement. We urge the FRA to withdraw the Crew Size Safety NPRM or completely exempt short line railroads from any crew size and crew location mandate.