Train Crew Size Safety NPRM
ASLRRA Comments on NPRM
Chuck Baker Comments, FRA Hearing December 14
SBA Office of Advocacy Comments
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.
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.
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.