September 2, 2025
Kyle D. Fields
Chief Counsel
Federal Railroad Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
RE: Administrative Updates to the Bridge Safety Standards Regulations
Docket No. FRA-2025-0105
Mr. Fields:
On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) final rule regarding administrative updates to its bridge safety standards. TTD consists of 39 affiliate unions representing workers in all modes of transportation, including rail workers who will be affected by this rule.[1] We object to the process by which the FRA chose to promulgate this rule and encourage the Agency to undertake more transparent rulemaking processes with regard to modifications to bridge safety regulations in the future. In addition, we endorse the comments filed in this docket by our affiliate, the Brotherhood of Maintenance of Way Employes Division of the International Brotherhood of Teamsters (BMWED).
Earlier this year, TTD expressed our concerns regarding the repeal and modification of regulations outside of the normal regulatory processes in our response to the Department of Transportation’s request for information regarding regulatory reform. We must reiterate that federal safety regulations should be repealed, revoked, or modified only through the full notice and comment process in accordance with the Administrative Procedure Act (APA). In general, the APA requires published notice and opportunity for comment for most rulemakings, including for the repeal and substantive modification of regulations. 5 U.S.C. 553(b)(B) exempts a proceeding from these requirements “when the agency for good cause finds that notice and public procedure thereon are impracticable, unnecessary, or contrary to the public interest.” As the BMWED notes in its comments in this docket, bridge safety is certainly not a marginal issue, as evidenced by several high-profile incidents that called attention to the importance of enhancing the safety of railroad bridges. There are over 100,000 railroad bridges in the United States, and ensuring the safety of these structures is a foundational component of the national railroad safety framework. Thus, all regulatory updates in this area warrant a process that includes those responsible for implementing the regulations: railroad workers, engineers, inspectors, and safety professionals who ensure compliance every day in the field.
Safety regulations exist for a reason, and stakeholders and the public must be permitted to fully assess the costs of repealing the regulations that were put in place to protect their communities. Rail workers in particular, many of whom have direct experience with the tragedies that have precipitated so many of the FRA’s safety regulations, must be allowed to examine and subsequently provide meaningful comments in response to attempts to modify and substantively change these regulations.
We appreciate the FRA taking these comments into consideration and look forward to working with the agency in the future.
Sincerely,
Greg Regan
President
[1] Attached is a complete list of the unions affiliated with TTD.