Policy

August  16, 2023 Tracy Robinson Canadian National Railway 935 de La Gauchetière Street West Montreal, Quebec, Canada H3B 2M9 Ms. Robinson: On behalf of the Transportation Trades Department (TTD) of the AFL-CIO, we are writing to urge CN to swiftly join the Federal Railroad Administration (FRA)’s Confidential Close Call Reporting System, which enables workers to […]

August  16, 2023 Kathryn Farmer BNSF Railway Company 2650 Lou Menk Dr, Fort Worth, TX 76131 Ms. Farmer: On behalf of the Transportation Trades Department (TTD) of the AFL-CIO, we are writing to urge BNSF to swiftly join the Federal Railroad Administration (FRA)’s Confidential Close Call Reporting System, which enables workers to confidentially report “close […]

August  16, 2023 Keith Creel CPKC 427 W 12th St, Kansas City, MO, 64105 Mr. Creel: On behalf of the Transportation Trades Department (TTD) of the AFL-CIO, we are writing to urge CPKC to swiftly join the Federal Railroad Administration (FRA)’s Confidential Close Call Reporting System, which enables workers to confidentially report “close call” safety […]

August  16, 2023 Jim Vena Union Pacific Railroad 1400 Douglas Street, Stop 1550 Omaha, NE 68179 Mr. Vena: On behalf of the Transportation Trades Department (TTD) of the AFL-CIO, we are writing to urge Union Pacific to swiftly join the Federal Railroad Administration (FRA)’s Confidential Close Call Reporting System, which enables workers to confidentially report […]

August  16, 2023 Joseph Hinrichs CSX 500 Water Street, 15th Floor Jacksonville, FL 32202 Mr. Hinrichs: On behalf of the Transportation Trades Department (TTD) of the AFL-CIO, we are writing to urge CSX to swiftly join the Federal Railroad Administration (FRA)’s Confidential Close Call Reporting System, which enables workers to confidentially report “close call” safety […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding the Association of American Railroads’ (AAR) petition for a waiver of compliance from certain provisions of the federal railroad safety regulations contained at 49 CFR part 240 (Qualification and Certification of Locomotive Engineers) and 49 CFR part 242 (Qualification and Certification of Conductors). TTD consists of 37 affiliated unions, including those representing the totality of rail labor, and we therefore have a vested interest in this petition. For the reasons outlined below, we ask the FRA to grant this waiver while continuing to push the Class I railroads to join the Confidential Close Call Reporting System (C3RS). Additionally, we endorse the comments of our affiliates, the Brotherhood of Locomotive Engineers and Trainmen (BLET) and the International Association of Sheet Metal, Air, Rail and Transportation Workers, Transportation Division (SMART-TD).

The Confidential Close Call Reporting System (C3RS) is an important tool that allows rail workers to report safety incidents, or “close calls,” to the FRA that do not meet the mandated reporting threshold.[1] C3RS is designed to shield reporting employees from disciplinary action related to a close call event, where an Implementing Memorandum of Understanding (IMOU) is in place, in order to ensure accurate reporting and provide a more complete representation of the rail operating environment. The system can provide invaluable information about safety concerns and hazards previously unreported to the FRA due to gaps in reporting requirements, and has the potential to vastly improve the safety of our rail system. Increased data collection will allow the FRA and the Class I railroads to address known and emerging safety concerns and strengthen safeguards for rail workers and the communities surrounding rail lines.

The undersigned labor organizations are pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding BNSF Railway Company’s (BNSF) petition to extend its waiver from 49 CFR 232.213 to continue operating extended haul trains for distances of up to 1,702 miles, beyond the limit of 1,500 miles as stated in the regulation. Our unions represent BNSF freight rail workers across various crafts and therefore have a vested interest in this matter. For the reasons outlined below, we ask that the FRA deny BNSF’s petition to extend its waiver.

Current regulations stipulate that extended haul trains are permitted to move up to, but not exceeding, 1,500 miles between brake tests and inspections.[1] In addition, current rules require that equipment with defective or insecure power brakes only be moved from the place at which the defect or insecurity was first discovered to the nearest available place at which the repairs can be made.[2] BNSF is petitioning the FRA to extend its waiver, first granted in 2006, which permits extended haul trains to travel 1,702 miles between brake tests and inspections. It is apparent in the waiver request that BNSF is intent on aligning brake testing requirements with its own scheduling needs, rather than adhering to the regulation as prescribed, merely for the sake of convenience. This extension request comes at a time of widespread safety concerns within the freight rail industry, which should not be overlooked in favor of the convenience that BNSF claims this waiver provides.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding Union Pacific Railroad’s (UP) July 14, 2023, request to amend its Positive Train Control (PTC) safety plan. TTD consists of 37 affiliated unions representing the totality of rail labor, including both passenger and freight rail workers. For the reasons outlined below, we respectfully request that the FRA deny UP’s request. Additionally, we endorse the comments of our affiliate, the Transportation Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART-TD) and the Brotherhood of Locomotive Engineers and Trainmen (BLET).

TTD previously commented on how Positive Train Control (PTC) systems provide an additional layer of safety for rail workers and the public.[1] These systems are designed to prevent train-to-train collisions, over-speed derailments, incursions into established work zones, and movements of trains through switches left in the wrong position. The National Safety Transportation Board (NTSB) first recommended that PTC be required in 1969 and Congress subsequently mandated PTC systems in the 2008 Rail Safety Improvement Act (RSIA) to save lives and reduce injuries. TTD and its unions support FRA’s goal of implementing safe and effective PTC systems in a timely fashion in order to protect rail workers and the general public.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding a joint Request for Amendment (RFA) received from 20 rail carriers to modify their FRA-approved Positive Train Control Safety Plans (PTCSP). TTD consists of 37 affiliated unions representing the totality of rail labor and we therefore have a vested interest in this matter. For the reasons outlined below, we respectfully request that the FRA deny this joint request. Additionally, TTD endorses the comments of our affiliates, the Transportation Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART-TD) and the Transport Workers Union of America (TWU).

TTD previously commented on how Positive Train Control (PTC) systems provide an additional layer of safety for rail workers and the public.[1] These systems are designed to prevent train-to-train collisions, over-speed derailments, incursions into established work zones, and movements of trains through switches left in the wrong position. The National Safety Transportation Board (NTSB) first recommended that PTC be required in 1969 and Congress subsequently mandated PTC systems in the 2008 Rail Safety Improvement Act (RSIA) to save lives and reduce injuries.

The undersigned labor organizations are pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding Kansas City Southern Railway Company’s (now known as CPKC) petition to modify its waiver providing conditional relief from certain provisions of the federal railroad safety regulations contained at 49 CFR parts 215 (Railroad Freight Car Safety Standards) and 232 (Brake System Safety Standards for Freight and Other Non-Passenger Trains and Equipment; End-of-Train Devices). Our unions represent CPKC freight rail workers across various crafts and therefore have a vested interest in this matter. For the reasons outlined below, we ask that the FRA deny CPKC’s petition to modify its waiver.

Background

Existing regulations established in 49 CFR 232.205 require rail carriers to perform a rigorous Class I brake inspection at the border when trains cross into the United States.[1] This inspection is crucial in mitigating any potential deficiencies in the Mexican Government’s rail safety regulations, which are much weaker than U.S. rail safety regulations, and ensuring that all U.S. safety regulations are met before a train continues on.